PN121 - Torfaen Pupil Referral Unit 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: Education
Work area: Torfaen Pupil Referral Unit (PRU)
Contact Details: Richard McQuillan
Privacy Notice Name: Torfaen Pupil Referral Unit

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

This privacy notice identifies the data the Torfaen Pupil Referral Unit collects and also explains the purposes for which personal data is collected and used, how the data is disclosed, how long it is kept and the controller's legal basis for processing.

Who provides your data to the Council?

The personal information we process is provided directly by you when you ask us to refer you for intervention in your child’s education and indirectly from agencies and professionals who are involved with your child’s needs and education. We use this information to provide teaching to suit the pupil’s needs and to ensure the health and well-being of the pupil.

How does the Council collect this information?

  • Documents via secure email
  • Hard copy such as referrals
  • Meetings
  • CCTV
  • Dashcam

What information does the Council collect about you?

The Torfaen Pupil Referral Unit collects:

  • Names
  • Address
  • Contact details
  • Date of birth
  • Gender
  • School year
  • Unique Pupil Number
  • Ethnic code
  • Source of ethnic code
  • National identity
  • Welsh language ability
  • Child in Care status
  • Medical referral
  • Medical records
  • Details of family circumstances
  • Education statements
  • Additional Learning needs records
  • Agency support
  • Agency contact details
  • Free School meal eligibility
  • Educational reports
    • PRU attendance
    • Engagement
    • Exclusion dates
    • Attainment data
  • CCTV footage/images
  • Dashcam footage/images
  • Photographic images

Why does the Council process your personal data?

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

(a) Your consent. This is required if you/your child appear in photographs or videos taken for information or publicity purposes. Consent only relates to the specific purpose for which it has been given and you can withdraw your consent at any time. We do not rely on consent as a legal basis for any other processing.

(c) We have a legal obligation. Education Act (1996/2002); Special Educational Needs Code of Practice for Wales (2002)

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

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
  • data concerning a person’s sex life
  • data concerning a person’s sexual orientation

We collect this under Article 9 of the UK GDPR together with any associated DPA2018 Schedule 1 conditions where required.


Where we collect criminal data this is processed within the Council under Article 10 of the UK GDPR.

Where CCTV is in operation there is clear signage around and within the building.

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:

  • Meeting the Educational needs of the learner
  • Ensuring the well-being of the learner
  • Providing support to local authority panels to enable appropriate decisions to be made
  • Sharing learner targets with the EAS.
  • Sharing with the Educational Welfare Service
  • Detection, Prevention and the conviction of a crime.

We may share your data with external agencies. These may include, but not be limited to:

  • Careers Wales
  • Health Boards
  • Education Advisory Service (EAS)
  • Welsh Government
  • Special Education Needs Tribunal Wales
  • SNAP Cymru
  • Maintained schools and educational Settings
  • Non- maintained schools and Independent Specialist Settings / Schools
  • Other Local Authorities
  • Other Educational establishments and examining bodies such as WJEC,
  • Appropriate professionals involved in aspects of an individual child’s education e.g. Coleg Gwent and Coleg Cymoedd Colleagues
  • CCTV footage identifying criminal behaviour may be shared with the Police
  • Dashcam footage may be shared with Insurance companies, Solicitors and the Police for insurance/legal claims or criminal prosecution purposes

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?

The majority of your data is not transferred out of the UK.


We share your names, date of birth and quiz results attained for Hegarty Maths which is stored in the EU. Details of the Hegarty Maths privacy notice can be found here.

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:

  • Locked cabinets
  • Secure electronic files, with access via passwords
  • CCTV is stored on a secure local server
  • Dashcam footage is stored within locked vehicles or secure buildings

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.

Pupil Information

Pupil information - Data retention
Basic file descriptionRetention Period
Admission Register Date of last entry in book (or file) + 6 years
Attendance Registers Date of register + 3 years
Pupil record cards When the child leaves the school Secondary
DOB of the pupil + 25 years
Pupil Files DOB of the pupil + 25 years
Special Educational Needs files, reviews and Individual Education Plans None DOB of the pupil + 25 years
Letters authorising absence Date of absence + 2 years
Examination results Year of examinations + 6 years
Internal examination results Current year + 5 years
Any other records created in the course of contact with pupils Current year + 3 years
Statement maintained under the Education Act 1996 – Section 324 DOB + 30 years
Proposed statement or amended statement DOB + 30 years
Advice and information to parents regarding educational needs Closure + 12 years
Children SEN Files Closure + 35 years
Records created by head teachers, deputy head teachers, heads of year and other members of staff with administrative responsibility (except child protection records) Closure of file + 6 years
CCTV footage CCTV footage is overwritten every 28 days unless there is a need to retain it
Dashcam footage Dashcam footage is overwritten every 31 days unless there is a need to retain it

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: Torfaen Pupil Referral Unit, Ty Glyn, Albion Road, Pontypool, Torfaen, NP4 6GE, 01495 742859

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: 09/05/2023 Back to top