After sending Swalecliffe a Freedom of Information request, it turns out that surprisingly the system was not paid for by the school, instead the generous catering company GS Plus (the school caterers) are providing the system. Which begs the question - who is the data controller? Who exactly is processing the children's biometric data - the catering company or the school? Seemingly also the biometric software the caterer is providing also will be used for registration... so is the catering company branching out into registration or is another company providing that?
The school did not effectively communicate to parents that the child had the right to refuse this, instead flanneling the issue up in an "e [electronic?] safety" discussion within school. The template Department of Education letters (see page 14) do not advise this. In their template letters this is communicated unambiguously to the parents in writing.
As always biometrics are used as a solution to a problem, and indeed the technology is effective at authenticating users, but the efficiencies come with the system not the authentication process.
The school justifying the introduction of biometrics by apparently "ensuing greater" safeguarding is an emotive, and I find a slightly distasteful, use of language (unless the school really did have child safety issues?). Unfortunately "safeguarding" is a word that is overused to the point of almost dangerous dilution of the meaning of it, especially when it is used to effectively 'sell' a system to parents. Other less invasive, proportional identification processes can be used to ensure equal safety of children - especially with young children, whose biometric data had to be ubersecure, and not compromised at their early age.
See my comments in red below. Another Freedom of Information request will be sent to the school as this throws up more questions (as is often the case) to gain clarity of how who has access to the children's biometric data, i.e. who is the data controller, what companies are involved and who is ultimately actually paying for this?
I can't really imagine the caterer is paying for this altruistically... (?) I'm sure the tax payer will be propping this up. Commercial companies do not survive by 'gifting' computer hardware/software to schools. The cost will be obviously worked into the price of the contract or meals.
24 Jan 2014
Dear Swalecliffe Community Primary School,
Under the Freedom of Information Act please could you supply the following information within 20 working days.
As per the article
1) In the above article it is quoted that the biometric system would “save the school essential funds”. Please advise:
i) how this would save the school essential funds
Swalecliffe Answer: As a school we are responsible for any debt accrued by parents not paying for the meals their children have. This is part of any school’s meals contract.
In addition we require an admin assistant to manage the monies coming into school, sending the debt letters, checking the registers and then making phone calls to parents who still haven’t paid their debt. In total this amounts to approximately 15 hours per week of school admin time. This does include the time of the contractor’s cash collector which obviously impacts on the meal prices.
ii) the amount of funds estimated to be saved per year.
Swalecliffe Answer: Admin costs: £7,098 per annum
Debt costs: £1,200 per year on average each year since 2009 (although these costs have been increasing with a debt of £1,300 from September 2013 – December 2014)
33 weeks x 15 hours a week = 495 hours
£7098 divided by 495 = £14.33 per hour (incl physical expenses i.e. letters)
Will a member of staff loose 15 hours a week from their employment i.e. will someone be financially worse off?
iii) the cost benefit analysis done showing savings to the school.
Swalecliffe Answer: As above
2) Please advise the cost of the biometric system
Swalecliffe Answer: The details of this are not transparent to the school because the system is being provided by the school caterers with no costs incurred by the school
Nice. Just a thought but perhaps the school caterer could have subsidised the debt incurred by the missed payments rather that incur more debt by providing a biometric authentication system?
So then who is the data controller then and who has access to the children's biometrics?
3) Please advise any ongoing licensing or maintenance costs
Swalecliffe Answer: There are no specific costs linked to the biometric system and cashless catering for schools. However as the software is now in school we have decided to upgraded our registration system, combining the two together to make morning registration more efficient and ensure even greater health and safety and safeguarding procedures within the school. This has cost the school £480 per annum but will also save us £48 per annum as we wont be using other software we currently purchase.
How can biometric technology ensure *more* health and safety. I'd have thought the hygiene of the scanners having hundreds of fingerprints on them (not to mention the added expense of wiping them clean) would have created a health risk. Safeguarding... how many issues have the school had with 'safeguarding procedure' at registration time to justify a biometric registration system?
4) Please supply the documents sent to parents for meetings and letters sent about the biometric system, including letters sent regarding parental consent.
Swalecliffe Answer: Please find attached [documents need to be provided externally]
Another post on this topic is warranted as the Head Teacher's comments regarding the alternative identification offered is unorthodox and not a response I've seen before.
5) Please show how the school communicated to the students that they had a right to refuse to use the biometric system.
Swalecliffe Answer: The system was shared and talked about in an assembly and by the class teachers as part of our e safety and ICT day in school. The children were asked to talk about it at home and decide with their parents what was right for them. During the actual process of registering for biometrics the staff were very careful to ensure that if any child was worried or anxious that they stopped and spoke to the parents before taking the reading. This only occurred with one child who has a specific learning difficulty and Asperger’s Syndrome. The children were very excited about the process.
6) Please advise what the “right information” was given by the school to parents who had concerns about the system
Swalecliffe Answer: Please see the documents sent to parents. Following our information sessions and our drop ins we collated the most frequently asked questions and shared them with the whole parent body.
Again I will deal with this in another post, details given were inaccurate - details to follow. Suffice to say I will point this out to the school ASAP so they have the opportunity to the rectify information given to parents.
7) How many parents consented to their children’s biometrics to be processed by the school?
Swalecliffe Answer: There are 649 children on roll.
578 children are able to use the system
535 have permission for biometrics (82% of the children)
82% efficiency for a biometric system? What if other procedures in schools were only 82% efficient? - that would not be acceptable. I don't think that's a great endorsement of the system.
8) How many parents refused for their children to use the biometric system?
Swalecliffe Answer: 13 families have refused to allow their children to use the system
However 11 of these do not use the catering facility and their children do not have school meals.
Only 3 of these families attended the consultations evening, the information evening or the drop in sessions.
9) How many consent forms were not filled in by parents?
Swalecliffe Answer: 41 have not completed any forms but all of these are families who do not have school meals
10) How many children refused to participate with the biometric system?
Swalecliffe Answer: We had one child who was distressed by the process but they have a specific learning need and anything unusual is challenging for them. We also had one family who communicated that they were discussing the options with their child and would like their child’s opinions to be seriously considered in their decisions.