PN083 - EOTAS (Education Other than at School) Privacy Notice

Torfaen County Borough Council is committed to protecting your privacy when you use our services. This Privacy Notice is designed to give you information about the data we hold about you, how we use it, your rights in relation to it and the safeguards in place to protect it.

TCBC Service Area: Children and Family Services
Work area: Additional Learning Needs (ALN)
Contact Details: Donna Lewis
Privacy Notice Name: EOTAS (Education Other than at School)

Data Controller: Torfaen County Borough Council, c/o Civic Centre, Pontypool, NP4 6YB

If you wish to raise a concern about the handling of your personal data, please contact the Data Protection Officer on 01495 762200 or email

Each Local Authority (LA) is required to provide the Welsh Government with pupil level data for all pupils for whom the LA has a financial responsibility to provide an education for who are Educated Other than at School.

Who provides your data to the Council?

We receive personal information indirectly from school’s data, and the Capita ONE database

How does the Council collect this information?

  • School’s data/systems e.g. SIMS
  • Capita ONE database

What information does the Council collect about you?

The ALN Team collects:

  • UPN (Unique pupil number)
  • Former UPN
  • ULN (Unique learner number)
  • Surname
  • Forename
  • Date of birth
  • Gender
  • Middle Name
  • National identity
  • Ethnic Group
  • Source of ethnicity data
  • Free school meal eligibility
  • Year Group
  • Home Postcode
  • Pupil SEN provision
  • Special Needs SEN (Special Educational Needs) Type
  • Category of provision
  • Hours of provision
  • LA establishment name and Establishment number
  • Other category of provision
  • Exclusion reason
  • Exclusion category
  • Start date of exclusion
  • LA number
  • Number of sessions missed
  • Age and gender of home educated pupils (anonymised numbers only)

Why does the Council process your personal data?

Under Article 6 of the UK General Data Protection Regulation (GDPR), the lawful basis we rely on for processing this information is:

(e) We need it to perform a public task.

Each LA is required to provide the Welsh Government with pupil level data for all pupils for whom the LA has a financial responsibility to provide an education who are educated other than at school.

Special categories of personal data:

We collect the following special category data:

  • personal data revealing racial or ethnic origin

We collect this under Article 9 of the UK GDPR.

We do not collect criminal data

Who has access to your data?

Your data is shared internally only with the appropriate staff where it is necessary for the performance of their roles.

Your data may also be shared externally with organisations for the completion of the annual EOTAS return. These may include, but not be limited to:

  • Welsh Government

Apart from where previously stated, we do not pass your details to third parties unless we are lawfully required do so.

Is the Data transferred out of the UK?


How does the Council keep your data secure?

The Council has internal policies in place to ensure the data it processes is not lost, accidentally destroyed, misused or disclosed. Access to this data is restricted in accordance with the Council’s internal policies and in compliance with the UK GDPR. Data will be stored securely in;

  • In secure pupil files on the Council’s education directory on a secure drive
  • Via the Capita ONE secure database

How long does the Council keep your data?

The Council will hold your personal data only for the period that is necessary and will follow organisational and Local Authority standards in this area. At the end of the retention period the Council will securely destroy or dispose of the data in line with retention schedules.

  • We will keep your information in line with our Local Authority retention schedules of 35 years from closure of record.

Are we making automated decisions/profiling with your data?


Your rights

You have a number of Rights you can exercise:

  • Access - to obtain a copy of your data on request
  • Rectification – to require the Council to change incorrect or incomplete data
  • Object, Restrict or Delete - under certain circumstances you can require the Council to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
  • Data portability – to receive and/or transmit data provided to the Council to other organisations (this applies in limited circumstances))
  • Withdraw your consent at any time (where consent has been given)
  • To know the consequences of failing to provide data to the Council
  • To know the existence of any Automated Decision-making, including profiling, and the consequences of this for you.
  • To lodge a complaint with a supervisory authority (Information Commissioners Office)

If you would like to exercise any of these rights, please contact please contact Donna Lewis, Senior ALN Manager

The Information Commissioner can be contacted at: The Information Commissioner’s Office (Wales), 2nd Floor, Churchill House, Churchill Way, Cardiff, CF10 2HH. Telephone 0330 414 6421 or e-mail

Last Modified: 04/10/2023 Back to top