Overview
This agreement explains how Academy Photography Ltd processes pupil data as a processor on behalf of a school (the controller) when providing school photography services, including proof images for parents/carers to view and purchase through this shop, and digital images supplied back to the school's management information system (MIS).
Purpose of processing
We process pupil images and related data to produce proof images for parents/carers to view and order, and to supply digital photographs for the school's own records where agreed. Schools retain controller status for any administrative use of images (for example, MIS records or ID cards).
Data we process
Pupil photographs, names, class/year group, and any pupil ID numbers supplied by the school, plus parent/carer contact details needed to issue proof slips and process orders. We do not intentionally collect special category data.
Legal basis
Schools typically rely on their public task authority for administrative school photography. Academy Photography relies on legitimate interests to provide proof images and fulfil parent orders placed through this shop.
Our commitments as processor
- We process pupil data only on the school's documented instructions.
- We apply appropriate technical and organisational security measures.
- Staff who handle pupil data are trained in data protection.
- We notify the school without undue delay of any personal data breach affecting pupil data.
- We do not transfer pupil data outside the UK without appropriate safeguards.
Sub-processors
We use a small number of sub-processors for secure hosting and payment handling. Details of current sub-processors are available on request.
School obligations
- Provide accurate pupil and class information.
- Inform parents/carers of the purpose of school photography, including that proof images may be offered for purchase online.
- Flag any pupil who should be excluded from photography or online proof access.
- Ensure the school's own privacy notices cover the administrative use of images.
Retention and deletion
Images supplied to the school's MIS are retained only for as long as needed to deliver that service, then deleted. Images made available to parents for ordering follow our standard shop retention policy unless the school instructs otherwise.
On termination
When our agreement with a school ends, administrative images are deleted or returned per the school's instruction. Commercial proof images already available to parents may remain accessible to them under our legitimate interest and standard retention policy, so that parents who have already claimed photos can continue to order.
Contact
Schools with questions about this agreement, or wanting current sub-processor details, should email support@academyphotos.co.uk or call 01782 566100.