Policy anomaly – Use of Unique Pupil Numbers within DPA

This may be of interest to anyone working in a local authority (or a school). I have noticed an anomaly in the DfE UPN Guidance, which arises because there is another guidance document which clarifies things.

I was recently asked for advice by the Systems Development Manager who is responsible for the ICS (Integrated Children’s System – children’s social care system) in Trafford. Her question was about whether a Unique Pupil Number, collected for the purpose of the annual Children In Need census return to the DfE. I checked the UPN Guidance update 2010 which suggested that you could not store the number.

I came to this conclusion through reading the document, and in particular the paragraph which states that “The UPN should not be regarded as an automatic adjunct to the pupil’s name, routinely appearing on any record or document relating to them”. It goes on to state that ” the UPN to be designated a “general identifier” under the Data Protection Act 1998, rendering its use by any organisation for any purpose unrelated to education illegal”.

However, (this is the interesting bit) the second para of page 14 the Guidance Notes for the completion of Children In Need Census 2012-13 actually states that “Once obtained, the child’s UPN may be retained on the Local Authority Social Services database for the purposes of returning the information to the Department.” Since the census is annual and social care cases may well be open for longer than a year, and because it doesn’t state that you should remove it once the return is sent, this would seem to imply that the number can continue to be stored there.

We have decided that this usage in the guidance for this year is in line with the general UPN guidance from 2010, in that this is not “routinely” using the number, and is for a specified purpose. It is still in line with the Privacy Notice issued for schools to issue to pupils and parents. I have checked the guidance for previous years, and this has been the case since 2010! This will save a lot of work for the team responsible for the return, as they will now be able to keep UPNs and those children who are unfortunately included on the CIN census for more than one year will automatically be available, reducing the number of children who will need UPNs populating.

I just WISH that the guidance issued by the same departments would be consistent!!!
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