The Data Protection Health Check: Is Your School Ready for the Year Ahead?

If someone were to carry out a data protection health check at your school or trust tomorrow, how confident would you be?

The start of a new academic year is one of the busiest times for schools. New pupils arrive, staff join and leave, systems are updated, and large amounts of personal and special category data are collected, shared and processed every single day. That makes September the ideal opportunity to review whether your current data protection arrangements remain fit for purpose.

Over the past 12 months, there have been significant developments in data protection, alongside ongoing risks for schools and trusts. Reviewing these changes and checking the strength of your current processes can help identify areas that may need attention.

 

 

Data Protection Changes Since Last Academic Year?

The ongoing implementation of the Data Use and Access Act 2025 (DUAA) is one of the biggest developments in data protection over the past year. While it introduces changes to the existing framework, it does not replace UK GDPR or remove schools' existing responsibilities around personal data.

For schools, the focus should be on reviewing existing arrangements and ensuring they remain up to date. This includes checking privacy notices, policies, staff understanding and records of processing activities.

The DUAA has also brought greater focus to data protection complaints. From 19 June 2026, schools must provide a clear way for individuals to make a complaint, acknowledge complaints within 30 days, and investigate and respond without undue delay while keeping the individual informed.

Good documentation is particularly important. Schools should be able to evidence how decisions were reached, what information was considered, who was involved and what action was taken. A clear audit trail can be invaluable if a decision is later challenged.

 

A Back-to-School Data Protection Check

Data protection compliance is not a one-off exercise. Changes to pupils, staff, suppliers, systems and technology can all affect how personal data is handled.

A few straightforward checks can help schools make sure their processes still reflect how they operate. This could include checking that user accounts and records are up to date, reviewing new software or learning platforms, and making sure policies are still current.

These changes may seem minor individually, but together they can affect a school's data protection risk profile. Regular reviews, clear documentation, staff training and effective oversight can help schools identify gaps early and keep their arrangements fit for purpose.

 

 

Biggest Risks Facing Schools This Year

The biggest data protection risks facing schools aren't always sophisticated cyber-attacks. Many incidents stem from everyday processes that have not kept pace with changes within the organisation. Some of the key areas for schools to keep in mind include:

Human Error

Many data protection incidents are caused by simple mistakes, such as sending information to the wrong recipient, attaching the wrong document to an email or discussing personal information with someone who should not have access to it.

These incidents are often unintentional, but a mistake can still result in a data breach. Regular staff training and ongoing awareness therefore remain important, rather than treating data protection as something that only needs to be covered during induction.

Staff Changes and Access Management

September brings changes to staffing, from new starters and temporary staff to colleagues changing roles or leaving the organisation. During a busy period, small but important tasks around system access can easily be overlooked.

Schools should have clear processes in place to ensure new starters have the access they need, unnecessary permissions are removed when roles change, and accounts are disabled promptly when staff leave. Applying the principle of least privilege, by giving individuals access only to the information they need for their role, can also help reduce unnecessary risk.

Third-Party Suppliers and Educational Technology

Schools increasingly rely on third-party suppliers, from MIS and safeguarding systems to payment platforms, parent communication tools, educational applications and AI-powered tools. These services may process significant amounts of personal data on a school's behalf, so it is important to understand what information is being shared and whether appropriate agreements and checks are in place.

New classroom apps and online tools should also go through appropriate due diligence before personal data is entered or shared. A system being popular or widely used does not automatically mean it is suitable for use within a school.

Artificial Intelligence

AI continues to develop rapidly across education, with schools using or exploring tools for tasks such as lesson planning, administration, communications and research. However, these tools can also create data protection risks if staff enter personal information or do not understand how the information they provide will be processed.

Schools don't necessarily need to ban AI. Instead, clear guidance, appropriate policies and staff training can help ensure these tools are used safely and responsibly. For DPO clients, Judicium also provides AI-related policy templates and training resources through the JEDU portal.

Cyber Security and Data Breaches

Cyber security remains an important part of protecting personal data, although not every data breach begins with a cyber-attack. Schools should regularly review measures such as multi-factor authentication (MFA), password management, device security, access controls and backup arrangements.

It is also important to have a clear breach response process in place. Knowing who to contact and what steps to take before an incident occurs can help schools respond more confidently and effectively if a breach does happen.

Ultimately, strong data protection is not about one particular control. It comes from consistently applying good practices across the organisation, supported by regular training, appropriate access management, supplier oversight, clear governance and effective security processes. Most schools already have many of these foundations in place; the key is making sure they continue to work effectively as the organisation changes.

 

 

The Data Protection MOT: How Healthy Are Your Current Arrangements?

With a new academic year underway, it is worth taking a moment to check that your school’s data protection processes are still working as they should. A few simple checks can highlight any gaps and help identify where attention may be needed.

Policies and Privacy Information

Are key documents, including privacy notices, data protection, breach and retention policies, up to date?

Check that they reflect current practice, have been reviewed recently and cover any new systems or processes.

Staff Training and Awareness

Do staff understand their data protection responsibilities?

Check that new starters receive appropriate training and that existing staff receive regular refreshers. Staff should also know how to recognise and report SARs, FOI requests and data breaches, as well as the data protection considerations when using AI.

Data Mapping and Suppliers

Do you know where personal data is stored and who it is shared with?

Data maps, Records of Processing Activities (ROPA) and supplier records should be kept up to date as systems and services change.

Access and Security Controls

Are the right people accessing the right information?

Check user accounts, permissions, leavers’ access and administrator rights, alongside measures such as multi-factor authentication, strong passwords, secure devices and backups.

Breach Readiness

If a data breach occurred, would staff know what to do?

Schools should have clear reporting routes, defined responsibilities and an up-to-date breach procedure, with relevant contact details readily available.

 

 

Keeping Data Protection on Track

These checks can help schools identify gaps and keep their data protection processes up to date. Where there are areas that need further work, a DPO partner can help review existing processes, provide advice and identify practical next steps.

For Judicium clients, this includes dedicated support from our DPO team and access to updated policies and privacy notices through JEDU. Our regular data protection newsletter also provides advice and updates throughout the academic year, helping schools and trusts keep up with changes and developments.

Strong data protection does not have to mean complex processes. What matters is that policies, processes and controls are understood, kept up to date and reflected in day-to-day practice. Regular reviews can help schools spot gaps early and keep their approach effective as circumstances change.

 

You can find information regarding our Data Protection services here.

If you would like to talk to someone about some support for your school or trust, do not hesitate to call us on 0345 548 7000 or email enquiries@judicium.com

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