Post: 2 July 2013
Back in November Education Secretary Michael Gove announced a public consultation on proposals to let the Department for Education share extracts of data from the National Pupil Database “for a wider range of purposes than currently possible” in order to “maximise the value of this rich dataset”.
The National Pupil Database is a longitudinal database that holds a wide range of information on individual pupils in schools in England. There’s a detailed list of what the database contains on the DfE website.
DfE’s proposals are designed to make it easier for third-party organisations, including companies, to access and use the NPD data. However DfE assures us that access will be subject to strict security arrangements and always in accordance with the Data Protection Act.
The consultation ran until mid-December, and the outcome was published in May. The outcome included a summary of responses to the consultation, and the Government’s own response. The DfE proposals were implemented in a regulatory amendment that took force last week.
I have now obtained (following a Freedom of Information request) 89 of the 95 individual responses to the consultation. Links to all of those responses are below.
DfE has held back an additional six responses on the basis that the respondents have requested their responses remain confidential and that “disclosure would give rise to an actionable breach of confidence”.
From a comparison between the breakdown of responses in the consultation summary and the responses received, it appears that the missing responses include four or five out of the six responses submitted by commercial organisations.
There has been some apparent moderation in the NPD data sharing proposals following the consultation; DfE has added a caveat about sharing data only for the purpose of “promoting the education or well-being of children in England”, and removed a reference to allowing sharing of data to those “providing data based products and services”.
However in the context of the Government’s strong ideological commitment to marketisation of the schools sector I am skeptical whether these changes in language will place any real constraints on access to NPD data for wider commercial purposes.
My other concern is the low profile of DfE’s NPD initiative. Most of the consultation responses are from organisations with an interest in re-using the data, leavened by some cautionary advice from civil society groups. There are only a couple of responses from schools and a half-dozen or so responses from individual parents (consistently opposed to the proposals).
There appears to have been no concerted effort to bring the consultation or the NPD initiative to the attention of parents or pupils (i.e. the data subjects themselves). This is a quote from one of the parents who did respond:
“I am shocked and appalled that I wasn’t notified about this consultation through my child’s school – I read about it on Twitter of all things. A letter should have gone to every single parent explaining the proposals and how to respond to this consultation.”
(Now imagine that sentiment amplified via Mumsnet …)
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Consultation responses in eight PDF files:
Single zip file containing all of the above responses (9.2 MB).
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Additional background links:
The National Public Database (presentation by Paul Sinclair of the Department for Education, 3 June 2013)
UK.gov STILL wants to tout pupil data - don’t use the word ‘product’ (The Register, 20 May 2013)
Getting to grips with the National Pupil Database; personal data in an Open Data world (presentation by Phil Booth and Terry Dowty, 15 Feb 2013)