PN113 - ALN Individual Development Plan (IDP) 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 & Family Services
Work area: ALN
Contact Details: Tracy Tucker
Privacy Notice Name: Individual Development Plan (IDP)

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

Who provides your data to the Council?

The personal information we process is provided to us directly by you, when parents have directly requested support for children or young people, but it can also be received from schools and other agencies who have requested support with parental consent

How does the Council collect this information?

  • Via the online Portal
  • Directly from the parent/carer
  • Via a 3rd party

What information does the Council collect about you?

The ALN team collects and processes a range of information about you;

This includes:

  • Name
  • Date of Birth
  • Address
  • Email address
  • Summary of the child, child’s parent or young person’s views, wishes and feelings in relation to their ALN, ALP and education and training.
  • Parent/carers names
  • Parent/carers address and contact numbers
  • School name
  • Education information
  • Looked after status
  • Disability/additional need information
  • Attendance data
  • Attainment data
  • Exclusion data
  • Ethnicity
  • Religion
  • Other agencies involved
  • Health information
  • Social Care information
  • Gender
  • Information relevant to the IDP

Why does the Council process your personal data?

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

(c) We have a legal obligation (Article 6c), The Welsh ALN Act

(e) We need it to perform a public task. (Article 6e)

(a) When we are requested to commence the creation of an IDP, we request consent to contact other Agencies e.g. health/social care to gather information as part of a multi-agency process. However, consent can be withdrawn at any time.

Please note consent is not the legal basis we rely on to process your personal data.

Special categories of personal data:

We collect the following special category data:

  • personal data revealing racial or ethnic origin
  • personal data revealing religious or philosophical beliefs
  • data concerning health

We collect this under Article 9 of the UK GDPR.

Who has access to your data?

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

Your data may also be shared externally with organisations as ALN Officers conduct regular consultations and problem-solving sessions with third parties to explore any barriers to pupils' learning and wellbeing in order to create positive outcomes for all.

These may include, but not be limited to:

  • School staff - To provide advice, recommendations and reports.
  • Other Local Authorities if you were to move to/from another Authority - To provide advice, recommendations and reports.
  • Local Authority Support Services, such as Educational Psychologist; Social Care; SENCOM - To provide advice, recommendations and reports.
  • Health Authorities - To support ongoing assessment of individual needs
  • Non-Maintained Schools – To provide reports and information to support a successful placement for a child/young person.
  • Maintained schools within other Local Authorities – To provide advice, recommendations and reports

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:

  • secure electronic filing systems
  • secure Management Information System

Where the Council engages third parties to process personal data on its behalf, they do so on the basis of written instructions. These third parties are also under a duty of confidentiality and are obliged to implement appropriate measures to ensure the security of data

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.

  • The ALN Service retain records in line with the council policy of 35 years following the closure of records

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 Tracy Tucker, ALN Manager, Education Service,

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: 02/08/2023 Back to top