State of Biometrics 2022 - a review of policy and practice in UK education

I co-authored a report with Jen Persson from DefendDigitalMe, 'The State of Biometrics 2022 - a review of policy and practice in UK education', which was published last week.  There is no collection, monitoring, record of biometric technology in schools held by any UK government department, regulator or commissioner so information in the report was obtained by Freedom of Information requests and research collated over the number of years I've been doing this blog.

There is definitely further research and questions to be answers and issues to be resolved following the publication.  

Biometric technology has crept from school services, canteen, library, etc, into the classroom - where 'sensors' (cameras) now scrape data from children into a group view for teachers and management to gauge real time interest in lessons, engagement, attentiveness and emotion.  This behavioural data capture is classed as biometric data under the Protection of Freedoms Act, Chapter 2 (28)(2).

From PRNewswire:

"ViewSonic Corp., a leading global provider of visual solutions, has partnered with the Smestow Academy in Wolverhampton, England, as the first school in the UK to deploy the AI-powered myViewBoard Sens analysis tool in the classroom. Through the real-time insights generated by the intelligent sensor, the school can ensure the classroom follows the wellness compliance, increase students' engagement, and facilitate a safe and active learning environment for the best possible learning outcome."

 

The Report in summary

The Protection of Freedoms Act 2012 and weak enforcement of data protection law are failing to protect millions of children from the normalisation of routine use of biometric data for everyday canteen and library transactions, and increasingly intrusive bodily surveillance in the classroom. 

Pupils in the UK are effectively guinea pigs in the use of emerging technology for companies from around the world, including facial recognition technology that has already been banned from schools in other countries.

Some companies claim that their products can measure mood and attentiveness, or use artificial intelligence to manage behaviour-based classroom planning. Some companies even claim to be able to detect autism without any child development expertise.

How this normalisation and these emerging products may affect the full and free development of the child are yet to be seen.

The fast-growing uses of intrusive technology involving bodily data in educational settings worry child rights advocates and law makers alike. 

Lord Paul Scriven said, “As parents you should be very worried and angry that private companies are seeking to make a profit from your child’s face, fingers, eyes and other personal characteristics while trying to pretend that it is all to aid their educational attainment. Where do we draw the line?”

• Data from FOI requests to schools (all UK) Our findings from enquiries to 550 schools with over a quarter of a million pupils in total, suggests that around three quarters of secondary schools are using fingerprint technology or other biometrics, and where used, uptake is routinely 85%, or more where use is restricted to only certain year groups.

• Despite the law requiring consent some schools in England are discriminating against children in receipt of Free School Meals (FSM) by obliging them to use the fingerprint systems, and others make it obligatory for all pupils. (We are yet to quantify these issues and plan to continue further research.)

• Emerging technologies, school trials and scope creep including under COVID. Schools started using facial recognition more widely in 2020. At least one school got new facial recognition technology free, “as part of a trial”. Some schools combined entry access readers with thermal and facial detection. Some are trialling “experimental” products including attentiveness and mood detection that are unevidenced in their intended outcomes or in any unintentional effects on children’s behavioural and cognitive development in UK classrooms. Voice is rarely considered under school biometrics policies whereas fingerprint technology is now routine.

• Lack of regulatory enforcement. Six months after North Ayrshire schools in Scotland put their facial recognition rollout on pause, there has been no visible ICO regulatory enforcement action. We include a latest position statement in the report.

• Large multinational companies have bought out the originally small school biometrics suppliers and many significant UK school providers are owned in the US, Canada and Israel.

• Parents’ survey findings (2018) Survation polled 1,004 parents with children in state schools on behalf of defenddigitalme about their experience of technology in schools. Over a third of parents (38%) whose children were using biometrics in school, said they had not been offered any choice despite the law that requires parental consent, the Protection of Freedoms Act 2012, and over 50% of parents had not been informed how long their child’s  fingerprints or other biometric data is retained or when the data would be destroyed.

Professor Fraser Sampson, Commissioner for the Retention and Use of Biometric Material and Surveillance Camera Commissioner and author of the report foreword, suggests there is inadequate oversight of school procurement among wide ranging comments.  “Some – including, surprisingly, the Department for Education – appear to have taken the view that bare compliance with Chapter 2 of the Act is all that is required to ensure the lawful, ethical and accountable use of biometric surveillance in schools.” He asks five key questions of practice in schools: Who's benefiting? Who's watching? Whose company are you keeping? Where's the push? And, Why the rush?

There are no UK national requirements for any quality or health and safety standards of biometric or AI technology when used by state schools, and no oversight or record of what is used where.

Current legislation is ineffective in protecting children’s and students’ rights in educational settings from age 2-25 and change is needed now. defend digital me is calling for a ban on biometric systems in educational settings.

Authors: Pippa King and Jen Persson

Artwork: Hannah Mallory

Swalecliffe Primary running out childrens biometrics for catering, registration, library and printing - caterer supplies the biometric system

After a few years of biometric vendors steering clear of selling biometrics to primary schools (it seemed that 'fingerprinting' younger children was less palatable that older children), Swalecliffe Community Primary School have decided to role out biometric technology so the children there can eat lunch and potentially print documents, log their registration and take library books out.

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
http://www.canterburytimes.co.uk/School-swaps-ditches-dinner-money-woes-hi-tech/story-20343882-detail/story.html#ixzz2o2awFg5z


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.

The bigger picture on how many children are 'experiencing' biometrics in schools 2013

Good that Big Brother Watch's 'Biometrics in Schools' report highlighted schools in the UK taking children's biometrics, though unfortunate that their figures are somewhat diluted as they are based on an alarmingly low response rate to their Freedom of Information Requests (FOIR).

Having a 39% response rate, 1255 replies from FOIRs sent  to 3,218 schools, is worrying as:
A) accurate data cannot be gleaned from it and
B) as schools are increasingly corporatised, does this suggest they see themselves as unaccountable?

But let's face it, if you were a school receiving a FOIR from Big Brother Watch about if/how your school uses children's biometrics you would be inclined not to answer, as legally every answer given under FOIR is "to the world", i.e. public.  Potentially embarrassing.

So if 40% of schools are using children's biometrics, as Big Brother Watch's FOIR response suggests, then when applied to the wider school population of 8.2 million, in England, this means that 3,280,000 children have their biometrics on school databases.  Interesting.  A figure not reported in the media.

But what about the remaining 60% of schools that did not reply to Big Brother Watch's FOIR?

In 2010 I asked 500 schools similar questions about their use of biometric systems for the then Protection of Freedoms Bill committee sitting in Parliament (now an Act of Parliament) and got replies from 47% of schools.  Because the data I had was not accurate enough to submit to the committee, not having got a near 100% replies, I rang round the schools that had not replied.

Two thirds of the secondary schools that did not reply were using biometric systems, so for example, in Liverpool's secondary schools the initial figure I got from the 47% FOIR response rate indicated that only 25% of schools used biometrics.   After ringing round the remaining schools this figure rose significantly to 72% of Liverpool's secondary schools using biometrics.

So does this mean we can apply the same criteria to the 61% of schools that declined to answer Big Brother Watch's FOIR?  In which case we would be looking at over 6.5 million children using their biometrics England's school population of 8.2 million.  A significantly larger figure than is being quoted in the media.

However, the demographic trend is that biometric systems are mostly used in secondary schools.  'Fingerprinting' primary age school children is not quite yet seen as acceptable, having had bad press in the past decade.  Whereas biometric systems in secondary schools are easier to stomach as children of secondary school age could use the technology routinely on their phone, PS and Xbox, etc.

As there are 8.2 million children in England's schools, with schools having children (from Reception, age 4/5, to Year 11, age 15/16) for 12 years, there are approximately 680,000 children per year group.  Perhaps more importantly, there is a need to look at the percentage of children having experienced biometric systems before they left school, i.e. looking at the secondary schools population where biometric technology is predominantly concentrated.  There is potentially a very high level of children passing through this age group experiencing using their biometrics in a school environment, normalising biometric use for fairly mundane transactions

It would only need two or year groups (or even one year of using a biometric system in a school) to accustom a child to the technology.  This may only mean that 1.3 million children have been using biometric systems in secondary schools but a near 100% experience of every child leaving school having experienced the technology.

So I guess the question could be better asked "How many children leaving school have experienced using biometric systems?"

Though still, the sheer numbers of children that have their biometric data on systems in schools, that possibly may be compromised in the future, is still a very valid point.

Thank you Big Brother Watch for highlighting the issue, as it is always good to have this topic in the news, but perhaps in the future more targeted research should be undertaken.

Quality of biometric normalisation does not necessarily lie in quantity of users - a nicely aimed, targeted demographic suffices.

Biometrics not so flavoursome for school catering

Over on What Do They Know, a UK website for Freedom of Information requests (FOIR), there have been some requests made to schools about biometric systems used.

Some interesting figures are emerging.  For example, Falmouth School in Cornwall has a biometric system for school meals, the take up after asking for parental consent is 34%.  Only 355 children are using the biometrics system out of a school role of 1044.

The school recently put a plea out to parents to use the biometric system: "Please could I ask as many students as possible to register to pay using the biometric system." 

Falmouth School's appeal to parents for consent to
 their children's biometrics used for cashless catering

Another school, Honiton Community College, has a biometric system where only 628 pupils and parents have consented to their biometrics being used - a 68% take up rate, with 203 not consenting, 22% .  As there are 926 students on their schools role, quite what the remaining the remaining 95 children are doing for lunch is not detailed in the Freedom of Information request reply from the college - maybe they are opting for packed lunch?

So why are schools buying identification systems for food that are only 34% - 68% effective, then having by law, in the recent Protection of Freedoms Act 2012, to provide an alternative means of identifying oneself in order to access food - surely this is a waste of taxpayers hard earnt money?

Why don't kids use use money?  Children use money out of school... oh yes, according to schools, it encourages bullying apparently.  Does it really?

Are the Headteachers and Principles so incompetent that they cannot sort out bullying issues? - if there is really an issue here at all.  If a leader of a school has to resort to buying an inefficient technology in order to eliminate bullying in a lunch line should that Principle or Headteacher be in the job, as presumably they cannot sort out bullying elsewhere too?  Also is it not the duty of a healthy society to encourage children to know how to handle money, keep it safe, not steal other's money and behave responsibly around cash?

The argument for having biometric technology in schools is weakening.  Complaints need to to be made to schools Governors, who have a responsibility to spend the public's money wisely.  On the governments Audit Commission's website (Protecting the Public's Purse)  there is an booklet entitled - Fraud risks in schools advice for school governors where it states:

"School governors share a responsibility for protecting taxpayers’ money:  As a school governor you have a special additional role. As governors you are individually and collectively responsible for proper control of your school’s finances. The buck does not stop with the financial administrator."

Maybe, in these times of austerity, we need to start holding these governors to account, spending our money on biometric systems that are clearly not fit for purpose in a school environment.

...and figures from Freedom of Information Requests

After looking at the secondary school biometric figures yesterday I thought it might be useful to take a look at the primary school market.

I sent a Freedom of Information Act Request (FOIA) out last year to over 500 schools last February/March 2010, to both primary and secondary, about the use of biometrics in schools.

4% of primary schools that responded had biometric systems.
39% of high schools that responded had biometric systems.

These figures are by no means precise as the overall response to the FOIA was poor.  The reality is that there are no collection of figures nationally and with poor response rates from schools it is impossible to gain any accurate figures.

Nevertheless, working with the results we have, this is does give a loose indication of where the UK school biometric market lies.

Figures, damned figures and statistics

Following on from the previous post we are looking at the 'joint' article published on the 15th April by the Association of School and College Leaders (ASCL) and Planet Biometrics.


"Figures come from Biostore, the main supplier of identity management systems to secondary schools. Its client base includes over 1000 secondary schools, and it estimates that well over 1 million students use its finger based biometrics daily. Biostore’s work with schools shows that 2 users per 1000 decline to use biometrics. A 99.8% uptake of a voluntary process reflects the views of most of the public on this subject"


Both articles quote the above which is by the company Biostore who sell school biometric management systems.  They understandably have a commercial interest to state that biometrics have a high take up in schools.  It is taken from their written submission to the Freedom Bill.

• Did parents specifically sign for consent?
• Was it a parental opt out scenario, 'implied consent'?
• Did the parents even know that their children were using their biometrics?
• Is the 99.8% figure an indication of the uptake of children in a compliant school environment or an indication from fully informed parents and specifically gaining written consent?

Without knowing the answers to these questions the above statement is ambiguous and figures quoted should be questioned.  For Biostore to then assume that the 99.8% uptake in schools reflects the general populations view on this is, in my opinion, rather hopeful.


I can only speak from experience, where in my sons primary school when parents were specifically asked by letter to sign to consent to the school using biometrics, approximately 20% of parents did not consent for their childrens biometrics to be processed.  The school biometric system is now not in use.


Interestingly there are 3722 secondary schools in the UK (excluding Northern Ireland) with 3,560,384 pupils.  If Biostore's "client base includes over 1000 secondary schools, and it estimates that well over 1 million students use its finger based biometrics daily" taking the figures literally at 1000 schools that means Biostore, at the very least, has 28% of the total schools biometric market.


Both articles quote that there is evidence that "30% of secondary schools have biometric systems".


Are we then to believe that one company, Biostore, has 93% of the high school market share...? 

Biometrics in Schools briefing

Over on the excellent Action on Rights for Children's (ARCH) website is a overview on the use of 'Biometrics in Schools' for the past 10 years in the UK.

A snippet from the report details the lengths biometric vendors are going to, to market biometric technologies specifically at teachers and parents:

"Some companies have engaged PR firms in order to promote their systems. Livewire PR, for example, were engaged by ‘Vericool’ to provide ‘crisis management’ for its registration system and describes its tactics as follows:

* Ensured that all news releases included implementation advice from the Department for Children Schools and Families (DCSF) – a guideline developed in association with VeriCool - [Interesting to know the DCSF was working with the commercial biometric industry to develope guidelines, presumably separate to the guidance issued by BECTA.  Was this ethical given that evidence suggests the DCSF failed to take advice from elsewhere?]

* Used ‘superfan schools’ to highlight the positive benefits of biometrics in education.

* Secured coverage on new school installations within the local media in a drive to educate parents about biometrics and dispel any myths surrounding fingertip technology.

* Commenced executive profiling programme for VeriCool spokespeople to educate teachers and parents about the benefits of biometrics."

£25,000 biometric cashless system bought - based on "commonly perceived benefits"

At the end of January Sophie McKeand's child's school told parents they were "introducing a "cashless catering system", where children will pay for their school dinners using either a fingerprint identification system or a pin number". This is in Flintshire, Wales.

Sophie rightly objected "to have such important and sensitive biometric data being taken from children for a matter as trivial as buying lunch is absolutely absurd."

Since then Sophie has been busy finding out, via the Freedom of Information Act, just how much these systems cost (using our tax money), where the funding is coming from, who made the decision to implement such systems, etc. - interesting reading indeed.

Her Freedom of Information questions and answers, for Flintshire County Council, are on the "Biometrics in Schools" forum over on the NO2ID site.

Here are a few questions and answers:

3. What is the FULL, TOTAL AND FINAL cost of this system in Alun School?

A3.The full cost of the system in the Alun School is as follows:

PCS Systems £20,905.00
Software £ 1,062.32
Installation £ 1,162.50
Server £ 283.14
Printer etc. £ 574.00
Writing/Electrics £ 1,162.50

TOTAL £25,149.46 [this is cost for one school]

1. I wish to be provided with ALL cost / benefit analysis that have been completed concerning anything whatsoever to do with implementing these cashless systems in Flintshire schools. Not just for Mold Alun but for all schools in Flintshire as stated in the quote from the first letter from Alun School, above. This includes all equipment, maintenance and IT services.

A1. The Council holds no information regarding a cost/benefit analysis. [What?]
The commonly perceived benefits however, are that..... then follows some drivel about reducing bullying and enabling children to eat before afternoon registration, up take of free meals increased, blah, blah.

So, lets get this right...

...the council spends 25K of our money on a biometric/pin cashless catering system purely based on "commonly perceived benefits" - with no cost/benefit analysis to justify such expenditure?

IMHO this sounds like jawdropping negligence.

Flintshire County Council sound like they've been sold a line. "Commonly perceived benefits" that are backed up with absolutely no academic or government literature, but I guess probably literature from sales persons.

It would seem that the implementation of the systems (that were originally proposed to be run throughout all Flintshire Schools, which would be around £250,000 of taxpayers money) has not been a completely open and transparent process, as reported today:

"Cllr Ray Dodd said he shared some of Miss McKeand's concerns. "I am surprised that this biometric system has been introduced in a school already without any consultation with elected councillors.

The education department said there has been extensive consultation, I have not been able to establish any consultation with county councillors,"

Schools dinners drop by 250,000

The number of secondary school children taking school meals has dropped by 250,000 in the past two years.

The Local Authority Caterers Association (LACA) National School Meals Survey have some interesting statistics:

In Primary Schools the number eligible for free school meals has dropped from 17.3% to 15.9% and the uptake from 14.2% to 13.1%.

In Secondary Schools the number eligible for free school meals dropped from 14.4% to 13.1% and the uptake from 10.6% to 9.6%.

The service is under immense pressure and already being seen by many private contractors as a non-viable operation.

LACA’s concern is that this may well be the case too for public sector caterers. It is not inconceivable that local authorities would consider abandoning the [food] service as budgets are unable to sustain the costs involved with the introduction of the New School Food Standards, particularly if Secondary students can continue to obtain, on the way to school and in break times, the food and drink items banned in school.

Why on earth would a school buy a biometric cashless system when clearly this is an area NOT to invest in at present, but manufacturers claims that such systems boost school meal uptake fly in the face of these recent LACA figures.

How many children?

Trying to get a figure of children with their biometric fingerprints on school databases is hard to estimate as the data on percentages varies according to statements from LEA's, manufacturers and Freedom of Information (FOI) requests.

But from this article Labour councillor Denise Headley uncovered 15 of Edmonton Green borough’s 92 schools using the "controversial biometric identification system".

In the same article Andy O'Brien, Managing Director of Micro Librarian Systems, states that 30% of schools use the fingerprint scanner. Is that Edmonton Green schools or just all schools? - because the figure from Edmonton Green is not 30%.

Working on 23%, which is just about in between the above figures and is also the percentage of schools using biometric databases in Suffolk from a recent FOI request, the following figures apply:

UK school population: Approx 9.5 million children.

England: 8,200,000
Wales: 494,181
Scotland: 743,561

23% of the total is 2,170,680 children.

So I think it it fair to say that over 2 million UK children have their biometric data on schools PC's. Maybe more.

I'd be very surprised if there are 2 million+ consenting parents to this.

Resources:
http://www.scotland.gov.uk/Resource/Doc/933/0044805.pdf
http://www.dfes.gov.uk/rsgateway/DB/SFR/s000682/SFR38-2006.pdf
http://new.wales.gov.uk/docrepos/40382/40382313/statistics/schools/1152752/key-edu-2006-e.pdf?lang=en link broken, see http://wales.gov.uk/docs/statistics/2011/110126sb72011en.pdf