Privacy notice relating to the processing of personal data by Rhondda Cynon Taf County Borough Council for the purpose of Free School Meals (FSM) eligibility and administration
Introduction
This privacy notice explains how Rhondda Cynon Taf County Borough Council ("the Council") uses personal information to identify, assess and administer eligibility for Free School Meals (FSM). It explains what information we use, where we get it from, who we share it with, and your rights in relation to that information.
We also explain how we may use information to identify children and young people who may be eligible for FSM and, where appropriate, automatically register them so that they do not miss out on their entitlement.
Where we use the Low Income Family Tracker (LIFT) to help identify children and young people who may be eligible for FSM, further information about how personal data is matched and analysed through LIFT is available in our LIFT Programme Privacy Notice.
This notice should be read in conjunction with the Council’s main privacy notice.
The Data Controller
The Council is the data controller for the personal data processed for the purposes of identifying, assessing and administering eligibility for Free School Meals (FSM), including operating automatic registration arrangements where applicable.
The Council is registered with the Information Commissioner’s Office (ICO) as a controller under reference Z4870100.
Queries relating to this privacy notice
If you have any questions or queries relating to this privacy notice please contact the Benefits Service:
By email : FreeschoolmealsEnquiries@rctcbc.gov.uk
By telephone : 01443 425002
In writing : RCTCBC, Free School Meals, Council Offices, Ty Oldway, Porth, CF39 9ST
Who we are what we do
The Council is responsible for administering Free School Meals for eligible children and young people.
Although some children and young people are entitled to receive a free school meal regardless of their household circumstances, there are still benefits to being registered as eligible for FSM based on household income or benefit entitlement. This can help children and families access other support and can also affect funding available to schools.
We use personal information to identify children and young people who may be eligible for FSM, check their eligibility and register them for FSM where appropriate. This may include using information already held by the Council and carrying out data matching to help identify eligible families.
Being registered as eligible for FSM may also help children and families access other support and benefits. Where appropriate, we may use or share a child or young person’s FSM eligibility information within the Council to help identify other support they may be entitled to.
Whose personal data we process
We may process personal data relating to the following individuals:
- Children and young people who receive, or may be eligible to receive, FSM.
- Parents, guardians or other individuals with parental responsibility for those children and young people.
- Other household members where their information is relevant to assessing eligibility for FSM.
The categories of personal data we process
We may process the following categories of personal data:
- Personal details and contact information, such as names, addresses, telephone numbers, email addresses and dates of birth.
- Information about children and young people, including their school and educational details.
- Information needed to assess eligibility for FSM, including household information, income, benefit entitlement and other relevant financial information.
- Information about FSM eligibility, including eligibility checks, applications, registrations and correspondence.
- Information obtained through data matching and from organisations that help us check or confirm eligibility for FSM.
Why we process the personal data
We process personal data to identify, assess and administer eligibility for FSM. This includes:
- Identifying children and young people who may be eligible for FSM.
- Checking and confirming eligibility for FSM.
- Carrying out data matching to help identify potentially eligible children and young people.
- Registering eligible children and young people for FSM, including automatic registration where appropriate.
- Maintaining accurate records of FSM eligibility and entitlement.
- Communicating with families, schools and other organisations involved in administering FSM.
- Dealing with enquiries, complaints and the prevention and detection of fraud.
Our lawful basis for processing the personal data
Under the General Data Protection Regulation (GDPR), our lawful basis for processing personal data for the purpose of administering FSM is:
- Legal Obligation – Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the Council is subject.
- Public Task – Article 6(1)(e) – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Council.
The primary legislation, regulations and guidance that supports this includes, but is not limited to;
- Education Act 1996.
- School Standards and Framework Act 1998.
- Welfare Reform Act 2012.
- The Education (Free School Lunches) (Prescribed Tax Credits) (Wales) Order and associated Welsh Government regulations and guidance relating to FSM eligibility.
- Welsh Government guidance relating to FSM.
Who or where we get the personal data from
We may receive personal data from:
- Children and young people, parents, guardians and other individuals with parental responsibility.
- Schools and other educational establishments.
- Government departments and public sector organisations, including the Department for Work and Pensions (DWP), HM Revenue and Customs (HMRC) and Welsh Government, where permitted by law.
- Information already held by the Council in connection with other services, benefits or support provided to you.
- Data matching carried out to help us identify children and young people who may be eligible for FSM.
Who we share personal data with
We may share personal data with the following organisations where this is necessary to administer FSM.
We only share the minimum amount of personal data necessary for the purpose.
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Who
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Purpose
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Schools and educational establishments
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To administer FSM and ensure eligible children and young people receive their entitlement.
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Welsh Government
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To support the administration, monitoring and funding of FSM.
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Department for Work and Pensions (DWP) and HM Revenue & Customs (HMRC)
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To assess and verify eligibility for FSM.
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Other Council services
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We may share information confirming a child or young person’s FSM eligibility where this may help identify or confirm their eligibility for other Council benefits or support.
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Cabinet Office
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For the purposes of the National Fraud Initiative and the prevention and detection of fraud.
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Data Processors
A data processor is a company or organisation that processes personal data on our behalf. Our data processors act only upon our instruction. They cannot do anything with the personal data unless we instruct them to do so. They will not share the personal data with any organisation apart from us or use it for their own purposes. They will hold it securely and retain it for the period we instruct.
The categories of data processors we use for the purpose of administering FSM include:
- Policy in Practice – provides the LIFT platform and carries out data matching and analysis to help the Council identify children and young people who may be eligible for FSM.
- IT system suppliers and software providers.
How long we retain the personal data
We retain the personal data contained within FSM records for:
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Length of time
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Reason
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7 years after FSM entitlement ceases or the record is closed
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To administer FSM and deal with any queries, complaints or disputes that may arise.
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In keeping with the GDPR storage limitation principle, records are periodically reviewed. We only retain personal data that is necessary for the administration of FSM, including eligibility assessments, registrations, decisions and correspondence. Information that is no longer required is securely destroyed in accordance with the Council’s retention arrangements.
Your data protection rights
The General Data Protection Regulation (GDPR) gives individuals important rights, including the right of access to the personal data that the Council holds about you.
Click here for further information on your information rights and how to exercise them.
Your right to make a data protection complaint to the Council
You have the right to complain to the Council if you believe we have not handled your personal data responsibly and in line with good practice.
You can do this by contacting the Benefit Service directly via one of the following communication methods. Most concerns can be resolved relatively quickly through a simple phone call or email;
- By telephone : 01443 425002
- In writing : RCTCBC, Free School Meals, Council Offices, Ty Oldway, Porth, CF39 9ST
Alternatively, you can raise a formal complaint via the Council’s Customer Feedback Scheme using the following link (Make a comment, compliment or complaint online) or you can contact the Council’s Data Protection Officer at Information.management@rctcbc.gov.uk.
Your right to make a data protection complaint to the ICO
You also have the right to complain to the ICO if you are unhappy with how we have used your data. However, we encourage you to contact us first and provide us with an opportunity to look into your concern and put things right.
The ICO can be contacted:
- Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Helpline number: 0303 123 1113