Virtual school heads: sharing vulnerable children's data

Balancing privacy and protection

Sharing student data is an essential responsibility for schools, especially for vulnerable children who face challenges requiring additional support. Whether it’s for safeguarding, accessing services, or maintaining well-being, responsibly handling this sensitive data is paramount to protecting the child.

For too long, poor information sharing has been identified as a contributory factor to serious child safeguarding incidents, and the barriers to improving this are well documented, including in reviews following the death of, or serious injury to, a child.

Department for Education, Keeping Children Safe, Helping Families Thrive, November 2024

The DfE’s Keeping Children Safe, Helping Families Thrive proposal brings about some major safeguarding changes in schools during 2025. The responsibility of Virtual School Heads (VSHs) has been expanded to ensure they fully support vulnerable children, beyond just those in care. This includes children living with kinship carers, as well as those under child protection plans or child-in-need plans.

To facilitate this, there is a strong emphasis on data sharing with Virtual School Heads. Schools and other safeguarding agencies are mandated to share specific information with VSHs to ensure these vulnerable children receive the educational assistance they require. This improved flow of data supports tracking attendance, attainment, and progress, and allows for timely interventions when necessary. The proposed implementation of a Single Unique Identifier (SUI) further simplifies accurate data sharing, ensuring VSHs and other professionals receive cohesive and comprehensive information about each child’s needs.

The proposals also introduce clearer guidance on the legal framework for data sharing, reducing the hesitation caused by perceived regulatory boundaries under the GDPR. Schools and agencies are now obligated to share safeguarding data for the benefit of the child, ensuring all parties are equipped to provide necessary interventions and support.

In summary, the expanded role of Virtual School Heads, coupled with enhanced data-sharing measures, aims to create a more integrated safeguarding network. This ensures vulnerable children consistently receive critical educational and welfare support.

When might sharing data be necessary?

• Financial & practical support services
  Assisting with free school meals, transport, or housing support.
• Health & special educational needs
  Providing medical, therapeutic, or educational interventions.
• Social care & safeguarding
  Addressing risks like neglect or abuse, in cooperation with social services and others.
• Education & attendance support
  Ensuring full participation in education and overcoming barriers.
• Justice & law enforcement
  Supporting vulnerable students while preventing harm or criminal activity.

Key data protection considerations when sharing data

1. Lawfulness, fairness and transparency – only share data after establishing lawfulness, ensuring it’s necessary, proportionate, and secure to do so.
2. Due diligence on data recipients – verify the recipients’ adherence to data protection, use legal agreements, and document every step.
3. Balancing interests and lawful basis – prioritise students’ safety while respecting their privacy. Choose the appropriate lawful basis for sharing data.

Data sharing when there’s an emergency

In emergencies (e.g., safeguarding risks, public health crises), schools may share data if necessary to prevent harm. Robust policies, procedures, and training will help staff act quickly and responsibly during such situations.