The guidance is relevant for leaders within educational institutions, as it outlines the legal and ethical responsibilities involved and helps you to navigate compliance with Data Protection laws, and provides best practices for implementing biometric technologies in a way that safeguards students and staff members personal information.

What is Biometric Data?
Biometric data is a type of personal information. Article 4(14) of the UK GDPR defines biometric data as:

“Personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm someone’s unique identification of that natural person, such as facial images or fingerprint data.”

This means that personal information is only biometric data if it:

• relates to someone’s physical, physiological, or behavioural characteristics (e.g. the way someone types, a person’s voice, fingerprints, or face);
• has been processed using specific technologies (e.g. an audio recording of someone talking is analysed with specific software to detect qualities like tone, pitch, accents, and inflections); and
• can uniquely identify (recognise) the person to whom it relates.

Who Can Consent to Biometric Data
Consent for biometric data needs to be treated differently than other consents and has specific, stringent criteria.

The Data Protection Act gives pupils rights over their own data when they are considered to have adequate capacity to understand. Most pupils will reach this level of understanding at around age 13.
​
However, the Protection of Freedoms Act 2012, which governs the use of biometric data in schools in the UK, has different requirements. Under this Act, the consent of at least one parent is required to process the biometric data of a child under 18. If the child or any parent objects, the school cannot process the child's biometric data.

Schools must notify each parent of a pupil or student under the age of 18 if they wish to take and subsequently use the child’s biometric data as part of an automated biometric recognition system.
As long as the child or a parent does not object, the written consent of only one parent will be required for a school or college to process the child’s biometric information.
​A child does not have to object in writing but a parent’s objection must be written.

What does this mean for MAT’s and Schools?
The decision to implement automated biometric technology is the decision of MATs and schools. However, careful consideration should be taken to assess the purpose of its use, the necessity and proportionality of processing, and consider the potential implications, such as operational requirements, handling of personal information, possible data breaches, and legal obligations.
It is also important for schools to reflect on the ethical considerations around the use of biometric data, including privacy concerns and the potential for future misuse of such data, even when collected in a lawful manner.

Schools should consider whether biometric data is truly necessary and proportional for the task at hand.

Here are some key actions for schools considering or already using biometric data:

1. Conduct a Data Protection Impact Assessment (DPIA)
Before implementing any biometric system, schools should carry out a DPIA to assess risks and determine whether biometric data processing is necessary and proportionate. This should be reviewed regularly to account for any changes in technology or usage.

2. Obtain Proper Consent
Ensure written parental consent is obtained in compliance with the Protection of Freedoms Act 2012. Schools should also have a clear, documented process for managing consent withdrawals or objections from either the student or their parents.

3. Be Transparent with Parents and Students
Provide clear, accessible information explaining how biometric data will be used, stored, and protected. Schools should offer regular opportunities for parents and students to ask questions or raise concerns.

4. Implement Robust Security Measures
Ensure that any biometric data collected is stored securely, with encryption and access controls in place to prevent unauthorised access. Schools should also regularly review their security practices to ensure they remain adequate in light of evolving risks.

5. Choose Vendors Carefully
When selecting a third-party contractor, schools must perform due diligence to ensure that the vendor complies with UK GDPR and has strong Data Protection measures in place. A contract should clearly outline Data Protection responsibilities and require the vendor to carry out DPIAs.

6. Regularly Audit Data Practices
Conduct regular audits of how biometric data is processed, ensuring that all practices remain compliant with relevant legislation. This includes reviewing how data is stored, who has access to it, and how consent is managed.

7. Prepare for Data Breaches
Develop a clear plan for managing data breaches involving biometric data, including informing affected students, parents, and the ICO if necessary. Ensure that all staff members are aware of the procedure for reporting a breach.

By incorporating these steps, schools can ensure they not only comply with legal requirements but also protect the privacy and rights of their students.

For more detailed information, including lawful basis considerations and best practices, please read
​full guidance provided by the ICO.

By Soton Soleye, SchoolPro TLC

We are pleased to bring you this next EVENTS newsletter with details of professional development opportunities.

Supporting your Professional Development 
This issue includes the following programmes, courses and events from our partners for your professional development intended to support and enhance the work of your school: 

• When the Adults Change - Behaviours Change
• Primary Staff Meeting Series
• TA Training: Supporting pupils with SEND
• AQA Writing for GCSE English Language Paper 1 & 2 | Stretching Grade 3 to 4
• Two Day Paediatric First Aid
• Professional Communities
• Primary Subject Leader Briefings
• Teaching & Assessment in Primary Science Focus4TAPS 3 Day Programme
• Events for your diary

Teach Like a Champion (TLAC): Building a Strong Classroom Culture
Training led by US-based Trainers from Dough Lemov's Worldwide training team, using some of the strategies included in the best-selling book 'Teach Like A Champion 3.0'.

​Structured as a series of five 90-minute online Tuesday train-the-trainer interactive training sessions with the following intentional and appealing titles:
 
SESSION 1
Radar/Be Seen Looking | 5 November 2024 | 1600 - 1730

SESSION 2
Least Invasive Interventions | 10 December 2024 | 1600 - 1730

SESSION 3
What to Do and Do It Again | 11 February 2025 | 1600 - 1730

SESSION 4
Systems and Routine and Strong Voice | 25 March 2025 | 1600 - 1730

SESSION 5
Positive Framing and Precise Praise | 10 June 2025 | 1600 - 1730

Each session is led by Teach Like a Champion Trainers based on an impactful implementation model to encourage a motivating momentum for your TLAC Champions-in-the-making. In addition, there will be opportunity to attend optional termly Professional Community Forums to review impact and share good practice with fellow programme members. 

We are pleased to bring you this first EVENTS newsletter of school year 2024 - 2025.

Supporting your Professional Development 
This issue includes the following programmes, courses and events from our partners for your professional development intended to support and enhance the work of your school: 

• National Professional Qualifications 
• Primary Staff Meeting Series
• Advanced Coaching Programme for School Leaders
• '12 Dialogues for Boys & Young Men' Being Safe & Safe to be Around
• Teach Like a Champion (TLAC): Building Strong Classroom Culture
• Professional Communities
• Primary Subject Leader Briefings
• Teaching & Assessment in Primary Science Focus4TAPS 3 Day Programme
• Events for your diary

SWIFT Membership 2024 - 2025
We would also like to take this opportunity to welcome you to SWIFT Membership for 2024 – 2025 and we are delighted that so many Schools, Federations, Multi Academy Trusts and other organisations have joined or renewed for this school year.

SWIFT Membership can provide your school with significant cost savings on our programme of professional development - a number of which are free for members.

You can find our full range of courses for 2024 – 2025 HERE
You can register for 2024 – 2025 SWIFT Membership HERE 

On behalf of us all at SWIFT and our Partners, we look forward to working with you and supporting your professional development this year.