… please use them 😫
A secondary school has recently had it’s knuckles rapped by the ICO over its solution for cashless lunch payments.
Life has obviously moved on from when I was at school, when we used cash – you know notes and coins! 👛
My daughters’ school had an electronic card which I would load money onto, and that seemed to work.
But a school in Essex have taken it a step further and used facial recognition.
They rolled this out in March 2023, but failed to consider the data protection implications of this technology.
The scheme operated on “assumed consent” from parents or carers, giving them the opportunity to opt their child out if they wished.
Despite having a Data Protection Officer (DPO), they didn’t consult him! 🤔
When he became aware in November 2023, he completed a Data Protection Impact Assessment (DPIA), as this processing of biometric data was high risk.
Concerned about the outcome of the DPIA, the DPO consulted the ICO.
The ICO have issued a reprimand, which doesn’t carry a fine, and set out actions they should take before undertaking something like this in the future – including talking to their DPO!
If the school had asked for his advice, it is likely none of this would have happened and the ICO would never have been involved.
So, if you have an expert in some part of your business, whether in-house or a consultant, make sure you ask them when you have an idea within their remit.
It will save a great deal of time and stress and maybe money as well.
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