STHC Process - Data Protection Issues
We take the issue of data protection very seriously:-
- Both Knowledge Mappers Ltd. and Travel Health check Ltd. are fully registered on the official register of Data Controllers maintained by the Office of the UK Information Commissioner –
see it online at www.ico.gov.uk (our registration numbers are Z1303712 and Z2735279 respectively).
- The data supplied to us is at all times the property of the client authority and they are free to inspect our offices to ensure that it is being
processed in accordance with due diligence.
- A number of technical measures have been undertaken by us to de-personalise what
is already very de-personalised data -
- use of postcode centroids not home address
- dispersal of points around the postcode centroid point
- assigning our own unique pupil identifier to each of the census records before we undertake the analysis process
- We are bound by rules as your contractor to only use data you supply for the stated purposes, to only allow authorised personnel to have access to it and not
to share it with 3rd parties. We are happy to sign any additional data sharing protocols that your authority requires.
- Analysis Data is returned directly to client contacts and they will have control over what is released to whom and in what form.
That said the whole purpose of the STHC service is to produce analysis data that can be shared by all the stakeholders interested in how children travel to school and how far they travel to get there. Thus we publish all the school-level and authority-level data on the STHC website and encourage clients to point as many people as they think may be interested towards it. This is completely ‘safe’ in data protection terms. The issue comes with the pupil-level data, which is basically the mapping output (MapInfo GIS and Google Earth files, and the screenshots of the paper maps from the STHC School Packs). These cannot be made available for public download, either on our website or a local authority website, yet need to be made available to authorised stakeholders at the local level - in particular schools - in order to effect behaviour change on the ground.
In our extensive experience when resources are "locked away" behind password-protected websites they don't get used as often as they should do (if at all), by everybody that should be using them. Often when the password-holder moves on from the school they forget to leave a note of the password behind them and then nobody can get access (if they told anybody else about it in the first place of course!). Such websites are also usually an expensive option from the client authorities point of view, with annual subscription costs which soon mount up when multiplied by the number of schools in the whole authority (which they will have to pay for, even if the school never uses the website). Once it becomes evident that the website is being under-used, it becomes difficult for client officers to justify the coninued cost to management and so the plug gets pulled the next year and everybody is back where they started!
The most straightforward (and cheapest!) option all round is to put the details of a named contact on all the publicly available resources, which is either a relevant officer from within the client authority or ourselves at STHC, with instructions that interested stakeholders contact them directly to request the pupil-level mapping digital resources. This has the additional benefit of opening up a direct channel of communication with stakeholders that are showing the most interested in the school travel process and so lead on to further engagement with them.
We think our measures strike a sensible balance between maintaining pupil anonymity yet still allowing us to produce accurate enough distance analysis calculations for strategic purposes in a process that can be carried out for any local authority in the UK. If you have any concerns about Data Protection then please get in touch and we will be happy to discuss them with you.
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