GDPR - Use of UPN for Integrators

Introduction

SIMS has been asked about the use of UPN by partner companies by a number of customers and hence there is a need to clarify our guidance to partners and educational establishments. This document offers current guidance for SIMS Partners and educational establishments using or considering the use of their products. DfE published updated guidance in December 2017 which is the basis for this update.

Audience for this document

• ESS Staff – Please distribute this document to customers who enquire about the use of UPN by partner systems.
• ESS Partners / Technical Integrators
• Customers – LAs/MATS/Schools/Academies/Colleges/…

References

Updated Guidance

The following section has been taken from the DFE Guidance and fundamentally changes the September 2013 guidance.

Please read the full DFE Guidance because there are caveats and additional constraints.

Conclusion for Schools and Partners

There are some anomalies such as the use of UPN within CTF to transfer students including those over the age of 16.  However, the guidance in general would appear to be straight forward to interpret in most cases.

If partners choose to use UPN then it is recommend that:

1. Partners review their use against the updated DFE Guidance.
2. If unsure then partners should seek clarification from their legal advisors.

GDPR offers further protection to personal data and partners should review any decisions against the current guidance.