HomeData Protection GuidelinesSensitive Personal DataSensitive Personal Data – Students

Sensitive Personal Data – Students

A school may collect sensitive personal data relating to its students

Some examples of sensitive data school might collect about its students:

  • Information regarding religious or philosophical beliefs: Schools require this data for the provision of religious instruction/education and/or for facilitating a parent/guardian or student (where the student is over 18) where they do not wish the student to receive religious instruction or religious education.  Denominational schools may request information or documentation in respect of religious belief on application, for the purposes of determining priority in accordance with the school’s enrolment policy.
  • Information regarding health including psychological assessment and information regarding disability: Schools require this data, subject to parental consent from the parent/guardian, for the provision of special needs education and learning support to make reasonable accommodations for the individual needs of students see DES CL 0038/2010 (184KB) .

  • Information on commission/alleged commission of an offence, any proceedings for an offence criminal convictions or the alleged commission of an offence, any proceedings for an offence committed or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings:  Students engaged in work experience where they will have unsupervised access to children or vulnerable adults must undergo Garda vetting with parental consent. 
  • Membership of the Traveller Community: The Department of Education and Skills requires schools at both primary and post-primary levels to identify students who are members of the Traveller Community for the purpose of allocating appropriate resources to schools to meet the individual needs of these children. Schools must therefore obtain  explicit written consent to record a student as a member of the Traveller Community. For post-primary schools the Department of Education and Skills have prepared a consent form to be used for this purpose which is included in DES CL 47/2010 (157KB).
  • Medical Card Holder – First year post-primary students only: The Department of Education and Skills requires schools at post-primary level only to provide data on medical card eligibility for statistical and policy purposes and it may inform indicators for the classification of schools for the purposes of Delivering Equality of Opportunity in Schools (DEIS). Schools must therefore obtain explicit written consent to record a student as a medical card holder or whose family are medical card holders.

Primary Level

Sensitive information may be sought at the time of enrolment.  This information is sought and retained for the purpose of inter alia, the allocation of resources and/or the completion of the Annual Census (or the Primary Online Database 'POD').  Recognised primary schools must return an Annual Census to the Department of Education and Skills (or input data via POD). Where such information is collected for completing these returns, this information should not be used for any other purpose and should be deleted when no longer required. 

Data on primary school students enrolled as at 30th September is returned to the Department of Education and Skills on an annual basis. Data on students in the census is only returned in an aggregated format. In respect of data entered via POD, the data contains individualised information on pupils, and a Fair Processing Notice was introduced in September 2015.  See POD Fair Processing Notice

Other relevant circulars include:

  • Fair Processing Notice for Boards of Management of Primary and Special Schools was introduced in 2014, see  DES CL 17/2014

Post-primary Level

Each year, each recognised post-primary school makes a return to the Department of Education and Skills via the online Post-Primary Online Database (P-POD), the data from which allows the Department of Education and Skills calculate the teaching posts and core funding to be allocated to each recognised post-primary school for the following school year.

These returns are made in accordance with  DES CL38/2014. In making their respective returns to the Department, post-primary schools transfer personal data and personal sensitive data on each of their enrolled students. A Fair Processing Notice was introduced to explain data collection on P-POD The only purpose for which post-primary schools may collect some of this data is to meet the data requirements for its October Return, to the Department.