📱 WhatsApp in Schools: A Guide to Safe and Compliant Use

While this incident unfolded within the healthcare sector, its implications are far-reaching and hold significant lessons for educational institutions. The ICO’s investigation highlighted that NHS Lanarkshire lacked the necessary policies, guidance, and processes when WhatsApp was introduced. This oversight resulted in the unsafe and unauthorised dissemination of sensitive data.

Clear Guidance and Protocols

It’s paramount for schools to establish clear protocols and guidance for using communication platforms like WhatsApp. Staff must be unequivocally informed that personal WhatsApp accounts are not to be used for sharing organisational data. This encompasses student data, staff information, or any other confidential school-related details.

Risk Assessment

Before introducing new apps or communication tools, schools should undertake a comprehensive risk assessment (known as a DPIA) concerning personal data. This involves examination of the app’s privacy protocols, security measures, and data management practices. The ICO recently underscored the importance of this, stating the need to “consider the risks relating to personal data before deploying new apps.”

Training and Awareness

Continuous training is essential. Schools should ensure that all staff members are well-versed in data protection laws, school policies, and procedures. They should be acutely aware of their responsibilities, especially when it comes to reporting personal data breaches promptly.

Recommendations from the ICO

Drawing from the ICO’s own recommendations, schools should consider the following:

• Secure Data Transfer:
  If schools need to transfer images or any other form of data, they should consider implementing a secure transfer system. This ensures that sensitive data is shared in a protected environment, reducing the risk of breaches.
• App Deployment:
  Before introducing any new apps, schools should evaluate the potential risks associated with personal data. This includes understanding how the app stores, processes, and shares data.
• Clear Communication:
  Whenever a new app is introduced, schools should provide explicit communications, instructions, or guidance to staff. This ensures that everyone understands their data protection responsibilities.
• Policy Review:
  In light of any incident or new guidance, schools should periodically review and update all organisational policies and procedures related to data protection.
• Breach Reporting:
  All staff members should be trained and reminded of their responsibilities to report personal data breaches internally without delay.