Data Protection considerations for schools as polling stations.

The advent of the 12 December General Election 2019 has posed some interesting problems for schools as Polling Stations. Many schools close to students for the day, and some do so for all but essential staff, whilst others try to maintain ‘school as normal’ and remain open as much as possible.

Download our checklist to help ensure you are taking all the necessary actions before and on election day to protect the personal data in your school.

Important considerations

Control of access

Many areas across the school contain personal data and, in all likelihood, it will be impossible to remove everything from all areas. You need to consider where voters are likely to be, what supervision is required of voters and electoral administrators and ensure staff are aware of their responsibilities to keep areas secure. If the school is still open then interaction between voters/electoral administrators and children will already be a safeguarding concern, but data protection/privacy should also be considered.

Visibility of personal data

Displays on walls with children’s names on now carry high risk. At parents’ evening and other times, the visitors are known to the school and have been invited – on polling day they haven’t.

In many areas of the school, there will be personal data visible on classroom displays, meeting rooms, office spaces, staff rooms, corridors etc. Schools should already be aware of what they should or shouldn’t put in ‘public’ spaces, but additional care should be taken during this time. Where information should not be seen by visitors then appropriate action should be taken. This will vary from school to school.

Devices

Anyone visiting the polling station should be advised, at point of entry, of expectations of the school with regards to the use of mobile devices, taking of photos etc. This is doubly important should the school still be open to students. Consider putting up posters to remind visitors what is expected of them.

Housekeeping

You should already be emphasising good practices around ensuring personal data is kept appropriately secure at the end of the day/when it is not in use. This is another opportunity to remind staff about keeping personal data secure, whether paper records or access via computers. Consider a refresher session of your role-based training before election day.

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