Delegated Accountability Framework 2019 - Shaw Education ...
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Delegated Accountability Framework 2019 Shaw Education Trust Page 1 of 15 Scheme of Delegation September 2019 to August 2020
Strategy Organisational Delegated Authority Framework Is authority Strategy delegated from the CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal Board? Central Central Central Central Academy Academy Provides financial & Responsible for setting Provides educational advice in Overall strategy of SET No operational assistance in strategy, with the Board developing the strategy developing the strategy Provides due diligence advice Provides due diligence advice Responsible for making Admission of new academies to SET No in relation to potential new in relation to potential new recommendations to Board academies academies Responsible for making Admission of new sponsors to SET No recommendations to the Board Delegated authority for approval and monitoring of Responsible for development Approval of academy development and Quality assures development Yes academy improvement plans, and delivery of academy improvement plans planning across the MAT reporting exceptions to the improvement plans Board Shaw Education Trust Page 2 of 15 Scheme of Delegation September 2019 to August 2020
Governance Is authority Governance delegated from the CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal Board? Appointment of Directors No Recommendations to Board Removal of Directors No Recommendations to Board Approval of terms of reference for subcommittees and for Academy No Recommendations to Board Council Recruitment procedures for Academy No Recommendations to Board Councils Appointment of Academy Councillors No Recommendations to Board Recommendations to CEO Recommendations to RD Recommendations to AC Appoint Chair of Academy Council Yes Approves appointment Recommendations to CEO Recommends to RD Removal of Academy Councillors Yes Responsible for removal Recommendations to CEO Recommendations to RD Appoint & Remove Clerk to the Trust Yes Recommendations to Board Recommendations to CEO Recommendations to RD Board Appoint & Remove Clerk to the Academy Recommendations to Academy Yes Approves appointment Recommendations to CEO Recommends to RD Council Council Ensuring at least 2 parent governors Approves Academy Council Yes Recommendations to CEO Recommendations to RD appointed to Academy Council membership Authorised to approve/amend No Recommendations to Board organisational scheme of delegation Shaw Education Trust Page 3 of 15 Scheme of Delegation September 2019 to August 2020
Is authority Governance delegated from the CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal Board? Take out Director Indemnity Insurance Responsible for making Yes Cover adequate arrangements Provision of professional Acquisition of legal entities No Recommendations to Board advice EnsureTrustee Responsible for ensuring Ensure academy register is Maintenance of register of interests Yes register is maintained Academy register is maintained maintained Ensure Trustee Monitor transactions with Reporting all Business Business & Pecuriny parties declared as a business Ensure academy reports all Pecuniary or Related Party Reporting of Related Party Transactions Interest (Related Party & pecuniary or Related Party business and pecuniary Transactions over £20,000 to Transactions) register Transaction. Notify COO of interests (RPT) to AC the ESFA is maintained transactions over £20,000 Responsible for Responsible for ensuring the Maintain the academy risk Maintenance of Risk Register Yes ensuring SET register academy risk register is register is maintained maintained Responsible for Responsible for ensuring Maintenance of a Gifts and Hospitality Maintain the academies Gifts Yes ensuring SET register Academy Gifts and Hospitality Register and Hospitality Register is maintained register is maintained Yes but dependent on Entering into, or withdrawing from, a Provision of professional financial value and Recommendations to Board formal partnership advice level of risk No, but some policies Review and monitor Responsible for delivery of may be varied Provision of Provision of Professional Provision of Professional implementation of central and Develop policy and procedures Recommendations to Board central policy and recommends according to local Professional Advice Advice Advice local policy and recommends local policy to AC operational need local changes to ELT Ensures Companies House information Reporting on persons with significant held is up to date and Yes control on GIAS and Companies House accurate. Ensure GIAS is up to date with SET information Shaw Education Trust Page 4 of 15 Scheme of Delegation September 2019 to August 2020
Education and curriculum Is authority Education/Curriculum delegated from the CEO Academy Council Principal Board? Responsible for proposing Approval and monitoring of SET and Review of local target setting SET and local targets to the Responsible for setting local Reports to AC and Board via academy targets for student achievement No and responsible for holding Board and providing targets subcommittees and attendance Principal to account appropriate reporting Responsible for proposing SET Approval and monitoring of SET and Review of local target setting and local targets to the Board Reports to AC and Board via academy targets for quality of teaching No and responsible for holding and providing appropriate subcommittees and learning Principal to account reporting Responsible for proposing and Approval and monitoring of SET and Review of local target setting SET local targets to the Board Reports to AC and Board via academy targets around student No and responsible for holding and providing appropriate subcommittees wellbeing Principal to account reporting Makes recommendation to New and updated educational policy No Board Responsible for linking Delegated authority for Academy plans to SET Provides plans to Academy Approval of academy improvement plans Yes approval and monitoring of Strategic plan and checking Council for approval academy improvement plans quality Post-Ofsted Action Plan sign off for any Makes recommendation to No academy that has RI or SW/SM category Board Curriculum: Planning, implementation Monitors effectiveness of Monitors effectiveness of Develops and delivers Yes and review curriculum plans curriculum plans curriculum plans Sign off of SET educational policies (e.g. Makes recommendations to Makes recommendations to off site visits, RE provision, Collective No Board CEO worship etc.) Recommends to CEO for Sign off of local academy educational approval. Then is responsible policies and procedures (e.g. Approves policies and Makes recommendations to Makes recommendations and Yes for the implementation and extracurricular activities, exams, procedures CEO reports to academy council monitoring of local academy behaviour, marking policies) policies and procedures Makes recommendations to Makes recommendations to Term dates Yes Authorises term dates Consulted CEO CEO Authorises organisation and Makes recommendations to Makes recommendations to Length/ organisation of Academy day Yes Consulted Academy day CEO CEO Reports to the Standards Reports to the Standards Receives report monitors and Folllows LA procedures and Fixed term exclusions Yes Committee Committee tracks patterns reports to AC Reports to the Standards Reports to the Standards Delivers the management Permanent exclusions Yes Follows LA procedures Committee Committee process Reports to the Standards Reports to the Standards Delivers the management Exclusion appeals Yes Follows LA procedures Committee Committee process Can exercise authority to Makes recommendations to Admissions policies and criteria Yes recommend change to the Consulted Follows LA procedures CEO Board Can exercise authority to Makes recommendations to Authorised to attend admission Admission appeals Yes recommend change to the Consulted CEO appeals Board Shaw Education Trust Page 5 of 15 Scheme of Delegation September 2019 to August 2020
Finance '* Delegated authority only applies where Academies have delegated responsibility. Where responsibilities have been withdrawn all delegated responsibility sits with the CEO and COO Is authority delegated from Finance ESFA CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal the Board? Central Academy Academy STATUTORY REPORTING Completion and approval of annual Recommendation to CEO and accounts and reports to funding and No Review Board regulatory bodies Completion and submission of other Yes Authorised accounting returns Completing annual & periodic financial reports to Board and/or DFE/ESFA Yes Authorised (including income/expenditure, cash flow, projections etc.). Authorised to complete PAYE returns Yes Authorised Authorised to complete VAT returns. Yes Authorised SYSTEMS OF INTERNAL FINANCIAL CONTROL Assurance over adequacy of systems of Provides assurance to Provides assurance to CEO No internal financial control EFA as AO and Board Approval of financial regulations No Recommendation to Board Appointment of external auditors No Reports to Board Advice from COO Management of appointment Appointment of internal auditors No Reports to Board process BUDGET & MANAGEMENT REPORTING Pooling arrangements by the Multi- Recommend approval No Recommend approval to CEO Academy Trust to Board Approve a carry-forward Approve a carry-forward Approval of balances Recommend approval of threshold: Secondary 5% of threshold: Secondary 5% of GAG balances / carryforward Yes held over carryforward balances held over GAG - Primary/Special 8% of GAG - Primary/Special 8% of threshold carryforward threshold GAG GAG Yes where the value is less Approval of claims up Recommend approval of claims ESFA Grant Claims than £150,000 to £150,000 up to £150,000 Recommend approval ESFA Returns No Recommend approval to Board to Board Oversight of preparation, Oversight of preparation, Review of detailed academy Preparation of detailed Endorsement as Approval of annual budgets No review of budget plans, review of budget plans, financial plans and budget academy financial plans and Accounting Officer recommendation to Board recommendation to Board tracking budget tracking Review of academy Receipt and review of management Endorsement as management accounts and Monthly review of academy Accountable for local academy No accounts Accounting Officer preparation of summary report financial position financial position to Board Powers delegated to Principal Approval of expenditure not provided for Authority to approve Authority to approve £20,000 - Authority to approve up to Yes up to Academy Council in the annual budget up to £99,999 £39,999 £20,000 threshold Powers delegated to Principal Authority to approve Authority to approve £20,000 - Authority to approve up to Authority to make budget virements Yes up to Academy Council up to £99,999 £39,999 £20,000 threshold Shaw Education Trust Page 6 of 15 Scheme of Delegation September 2019 to August 2020
Is authority delegated from Finance ESFA CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal the Board? PURCHASING AND PROCUREMENT Yes where value is less than Authorised up to Powers delegated to Principal Placing orders for goods and services, Authorised up to £39,999 Authorised up to £20K £100k (OJEU limits to be £99,999 (formal tender up to Academy Council entering into contracts (formal tender process) (minimum of 3 quotes) observed) process) threshold Yes where value is less than Authorised up to Powers delegated to Principal Authority to accept other than the lowest Authorised up to £39,999 Authorised up to £20K £100k (OJEU limits to be £99,999 (formal tender up to Academy Council quote (formal tender process) (minimum of 3 quotes) observed) process) threshold Ensuring compliance with tendering Yes Report to Board processes Authorised to create vendors on Yes Authorised accounting system Authorised to sign off vendor payments Yes Authorised Authorised BANKING AUTHORITY AND CASH Recommend approval Approval to borrow money (bank or Recommend approval to CEO Yes No to Board for sponsor loan, overdraft) for submission to Board submission to EFA Authorised to Review and Cashflow Management, Treasury & Yes approve. Investment details to Investment be informed to Audit committee Open a bank account and approve Can be approved No Can be approved signatory signatories signatory Applications for business charge card Can be approved No Can be approved signatory accounts signatory TRANSACTION PROCESSING Payroll - Starters, leavers and Oversees systems of internal Monitors staffing and Yes Authorises changes Authorises changes amendments control; authorises changes performance Final Authorisation of Final Authorisation of SET Authorises monthly payroll Payroll - Administration Yes SET payroll payroll costs for the academy Income Yes Authorised Authorisation of expense claims (cannot Yes Authorised Authorised Authorised Authorised for Principal Authorised authorise ones own expenses) Limited authorisation of control Control account reconciliation Yes Authorised accounts (Level 5 access) Transactions >1% of annual income or Powers delegated to Principal Write-off bad debts £45k individually: or Yes - up to EFA limits Authorised up to £5k Authorised up to £5k Authorised up to £2k up to Academy Council 2.5% or 5% of annual threshold income cummulatively Shaw Education Trust Page 7 of 15 Scheme of Delegation September 2019 to August 2020
Is authority delegated from Finance ESFA CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal the Board? FIXED ASSETS Ensures management and governance arrangements are Management of capital projects Yes appropriate and reports to Board (DoEHSC ) Recommend approval Acquiring a freehold on land and ESFA approval Recommend approval to CEO Recommend approval to CEO No to Board for buildings required for submission to Board for submission to Board submission to ESFA Recommend approval Disposal of a freehold on land and ESFA approval Recommend approval to CEO Recommend approval to CEO No to Board for buildings required for submission to Board for submission to Board submission to ESFA Recommend approval ESFA approval Recommend approval to Board Recommend approval to CEO Disposing of heritage assets No to Board for required for submission to ESFA for submission to Board submission to ESFA Powers delegated to Principal Disposal of assets - not land, buildings Yes - but must approve over Authorised to Review and Authorised to Review and up to Academy Council or heritage £5k approve up to £5k approve up to £1k threshold Yes where value is less than Authorised up to Powers delegated to Principal Authorised up to £39,999 Authorised up to £20K Acquisition of assets £100k (OJEU limits to be £99,999 (formal tender up to Academy Council (formal tender process) (minimum of 3 quotes) observed) process) threshold Authorised to Review and Asset Register Yes Monitor asset register Maintain asset register approve Oversight and must report to Security Of Assets Yes Monitor security of assets Maintain security of assets Board by exception Authorised to Review and Loan of Assets Yes Monitor loan of assets Maintain loan of assets approve INSURANCES Authorised to Review and Annual Risk Review & Premium Renewal Yes approve LEASING Recommend approval ESFA approval Recommend approval to CEO Taking up a finance lease No to Board for required for submission to Board submission to ESFA Recommend approval Taking up a leasehold on land and ESFA approval for Recommend approval to Board No to Board for leases buildings lease >7 years for leases
Shaw Education Trust Page 9 of 15 Scheme of Delegation September 2019 to August 2020
Human resources Is authority Human resources delegated from the CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal Board ? Staff Structure Reviews costed staffing plans Reviews costed staffing plans Reviews costed staffing plans Approval of annual staffing plan No and makes overall budget and makes overall budget and makes overall budget Reviews annual staffing plans Prepares annual staffing plans recommendation to Board recommendation to CEO recommendation to CEO Authorised to Increase Can authorise changes within Can authorise replacement Academy/Organisational Headcount Can authorise (with COO) overall budget; reports posts within existing staffing within existing staffing budget Yes changes beyond overall budget changes in headcount to budget & where roles are not (Replacement of staff within approved Finance Committee determined as "Do not replace" budget only) Quality Assures JD in terms of Agrees JD and recommends to Job Description sign off Yes Approval of JD equal opportunities pan MAT SET HR Grade of posts (teaching & support staff) Job evaluation policy & procedures No Implements JE procedures Authorises job evaluation and Responsible for oversight and Makes grading proposals to Authorised to evaluate jobs and grades Yes recommends to the Board cross-organisational grading HR / with HR input Authorised to agree/vary basic Ensures consistent application No employment Terms & Conditions of T&Cs Recruitment Recruitment and appointment of CEO No Appoints COO jointly with Recruitment and appointment of COO No Board Recruitment and appointment of Yes- but may be Appoints Executive Team and Involved in process Involved in process Involved in process Executive Team Members and Principals involved Principals Leads process for own teams Recruitment and appointment of other Yes - but may be Authorised to appoint other Involved in process at Leads process for own teams Leads process for own teams with SET representation on the Senior Leaders involved Senior leaders Academy panel Authorised to appoint staff Authorised to appoint staff Authorised to appoint staff within own teams within Recruitment and appointment of other Authorised to appoint staff in Involved in process as Yes within own teams as agreed within own teams as agreed approved headcount & where staff line with identified strategy appropriate with CEO with CEO roles are determined as "Do not replace" Carries out recruitment Ensures legislative and best Carries out recruitment Recruitment processes Yes processes in line with SET practice compliance in Involved in recruitment process processes in line with SET procedures recruitment processes procedures Yes (but Chair must Signs contracts of COO, ELT SET HR team sign other Signing of employment contracts sign CEO contract) and Principals employment contracts Shaw Education Trust Page 10 of 15 Scheme of Delegation September 2019 to August 2020
Is authority Human resources delegated from the CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal Board ? Pay Policy Makes recommendation to Contributes to recommendation Annual approval of pay policy No Board to CEO Determines pay ranges for Responsible for oversight and Agreed by Board of Directors Determination of pay ranges Yes (except CEO) Recommends to central HR Principals and central staff cross-organisational grading 1st November 2017 Approves and reports to Audit Review Due: 31st October Appointment outside range in salary structure Yes Approves Proposal for new range to AC committee 2018 Allocation of TLR / SEN values Yes Responsible for MAT oversight Approves allocations Recommends to AC Approval of discretionary Reviews proposal and makes Reviews proposal and makes Academy council proposes to Value of other discretionary allowances Yes (except CEO) Proposals for other allowances allowances recommendation to CEO recommendation to CEO RD/COO Yes to Nominations Annual Pay Progression and Appeals Makes recommendations to N Reviews proposal and makes Reviews proposal and makes Academy council proposes to and Remunerations Recommends to AC Process and R Committee recommendation to CEO recommendation to CEO RD/COO Committee Makes recommendation to Contributes to recommendation Setting Executive Pay No Board to CEO Pension Policy & Discretions Makes appropriate pension Handling of all pension matters (teachers Responsible to ensure Yes arrangements and ensures and support staff) Academy systems are in place proper administration Makes recommendations to Makes recommendation to Approval of use of discretions No Board CEO Operation of policies Makes recommendations to Approval of employment policies No Board RDs sets Principal's targets Principal appraisal with Conducts appraisal Objective setting and performance with AC and QA pan MAT DoE/DDoE AC approves Yes (except CEO) Senior ELT arrangements for own team appraisal targets RD sets Education recommendations for pay and ensures pan Academy QA Team targets progression to DoE Leads the process with the Makes recommendations to Makes recommendations to Creates formal restructure Approval of formal restructure plans Yes Approves re-structure plan Principal; makes CEO CEO plan. Leads the process. recommendations to COO Authority to issue warnings or other May issue warnings across the May issue warnings in own May issue warnings in own Part of formal panel and May issue warnings and Yes disciplinary measures except dismissal* SET and attend panels teams and attend panels teams and attend panels monitors the level of action disciplinary measures May suspend following Yes (Principals and all other Suspension* Yes (except CEO) Informs CEO Informs CEO Informed consultation with HR and central staff) DoE/DDoE CEO or other executive team CEO or other executive team CEO or other executive team Dismissal* Yes member must be involved in member must be involved in member must be involved in Part of formal panel Part of formal panel dismissal panels dismissal panels dismissal panels Yes (except where CEO or other executive team CEO or other executive team CEO or other executive team May be part of formal panel if Appeals* (not pay progression) CEO has heard member must be involved in member must be involved in member must be involved in not involved in the first panel original case) appeal panels appeal panels appeal panels Shaw Education Trust Page 11 of 15 Scheme of Delegation September 2019 to August 2020
HR addendum The trust reserves the right to delegate varying levels authority to academies according to the performance of the academy. DISCIPLINARY CASES AND DISMISSALS delegation model DISCIPLINARY GRIEVANCE CAPABILITY (PROFESSIONAL COMPETENCE) ILL HEALTH CAPABILITY REDUNDANCY (The Board will have determined that there is a Redundancy situation) SOME OTHER SUBSTANTIAL SITUATION Post Delegated authority Appeal Post Delegated authority Appeal Chief Executive Board member 3 Board members Chief Executive Board Member Chair of Board Board member or Chief Regional Directors and Chief Operating Officer 3 Board members Director of Education, Executive Principal Chief Executive Board member Executive Director of Operations and Director of Estates, Health and Board member or Chief 3 Board members Deputy Director of Education Director of Education Chief Executive Safety and Compliance Executive Board Member or Chief Principals Board Member Director of Operations, Finance Director Chief Executive Board member Executive Board Member, Chief Chief Executive or RD or Chief Subject Directors (Inc. Director of Teaching School and SCITT) Executive or Executive Principal RD Chief Executive/Board member Operating Officer Principal Vice Principal and SLT Members Principal, RD Chief Executive Directors of Subject RD RD (other) All other Academy posts Principal RD Vice Principal/SLT member Principal RD Operations central posts COO Chief Executive or RD All other academy posts Principal RD Finance central posts COO Chief Executive or RD All central finance posts COO Chief Executive All operational posts COO Chief Executive STAFFING RESTRUCTURES SIGNATURE ON LETTER OF APPOINTMENTS PERFORMANCE MANAGEMENT Delegated authority Role Delegated authority Role Delegated authority Chief Executive Chair of Board Chief Executive Chair and 1 Board member CEO, Regional Directors, Chief Operating Officer, HR, Principal, Chair of Academy Council RD Chief Executive RD Chief Executive Principal Chief Executive, RD Director of Primary Chief Executive Director of Education/ Deputy Chief Executive COO Chief Executive Director of Education Director of Operations & Directors of Subjects Chief Executive COO Director of EHS&C Finance posts COO Principals RD Operations posts COO Finance core team COO Teachers Pay- Threshold/UPS Principal Operations core team Director of Operations ` Principal and academy line All other academy based posts Principal, or RD if unavailable All other academy posts management structure Shaw Education Trust Page 12 of 15 Scheme of Delegation September 2019 to August 2020
Health & Safety Is authority HEALTH AND SAFETY delegated from the CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal Board? Central Central Central Academy Makes recommendation to Responsible for Responsible for Health and Safety Policy Yes, but monitors Board implementation of local policy implementation of local policy Responsible for Ensuring the adequacy of health and Oversees SET arrangements Ensures Academy Yes, but monitors implementation of policy. safety practice throughout SET and reports to Board arrangements are adequate Reports to Academy Council Holds SET and Academy Responsible for Ensures critical incident plans Critical incident planning Yes, but monitors Critical incident plans and implementation of policy. are adequate and in place reviews as appropriate Reports to Academy Council. Responsible for Ensures RIDDOR reporting is Ensures Academy Health and Safety RIDDOR reporting Yes, but monitors implementation of policy. in place arrangements are adequate Reports to Academy Council. Ensures that accident reporting Responsible for the Monitoring and reporting of Health and Safety Accident reporting Yes, but monitors arrangements are in place and implementation of accident exceptions actions followed up reporting arrangements Responsible for ensuring that Monitors SET statutory training Monitors Academy statutory Statutory training Yes, but monitors there are arrangements for for H&S and reports to Board training for H&S statutory training for H&S Implements and monitors SET Checks procedures are in Monitors local statutory Statutory compliance testing Yes, but monitors statutory compliance testing place and monitors outcomes compliance testing (ABM) and reports to Board Ensures the H&S committee is Academy health and safety Receives reports of H&S Quality assures the local in place (or part of resources arrangements including committee and Yes committee (or part of resources governance sub) and reports to Academy use of risk assessments sub) Council Responsible for ensuring Ensures all academies have Fire risk assessment Yes, but monitors Supports Academy processes operational arrangements are valid risk assessments in place in place and effective Responsible for monitoring the Responsible for ensuring Ensures all academies have Asbestos risk assessment Yes, but monitors impact of operational operational arrangements are valid risk assessments in place arrangements in place and effective General monitoring and action plans in Responsible for monitoring the Responsible for ensuring relation to safety of sites including Yes, but monitors Reporting to Board impact of operational operational arrangements are buildings conditions arrangements in place and effective Shaw Education Trust Page 13 of 15 Scheme of Delegation September 2019 to August 2020
Safeguarding Is authority Safeguarding delegated from the CEO Company Secretary Regional Directors Chief Operating Officer Academy Council Principal Board? Central Central Central Academy CEO ensures single central Complete and maintain a single central Ensures a compliant SCR is in Yes register is in place for central Quality assures SCR register place for the academy team No - Board ensures a Appoint a Board member as lead trustee holds this safeguarding trustee responsibility Chair of academy council Appoint a safeguarding academy Yes ensures safeguarding councillor councillor is in post Ensures review takes place Ensure an annual safeguarding review is Yes Quality assures the review and response to any necessary Ensures review is conducted completed at each academy actions are swift Ensure appropriate members of staff and Ensures at least one member Completes training and academy councillors are trained in safer Yes of every recruitment panel has regularly updates their recruitment completed the training knowledge in this area Ensure each academy has an Ensures DSL is in post and has Ensures that a DSL is available appropriately trained designated Yes appropriate training and time to to staff and pupils safeguarding lead (DSL) carry out duties Ensure a trust wide safeguarding policy Produces and reviews is in place and complaint with statutory No CEO quality assures the policy policy annually guidance Ensure individual academy safeguarding Ensures policy is compliant policies are in place and complaint with Yes Ensures policy in enacted and reviewed annually statutory guidance Ensure academy staff receive regular Yes Quality assures training Ensures training takes place and appropriate safeguarding training Lead safeguarding Ensure SET central team receive regular ELT member ensures Yes CEO quality assures training and appropriate safeguarding training central team have completed training Ensure that files related to the protection Quality assures arrangements Ensures systems of high of children are well-organised and held Yes for the storage of records quality securely Shaw Education Trust Page 14 of 15 Scheme of Delegation September 2019 to August 2020
Data Is authority Data delegated from the CEO Company Secretary Chief Operating Officer Data Protection Officer Academy Council Principal Board? DPO Quality Assures and Ensures measures and Data audit and Mapping Yes Designates school data lead and enables monitoring of data advises on best practice processes are in place Ensuring Data Security and Privacy DPO Quality Assures and Ensures measures and Yes Designates school data lead and enables monitoring of data controls are in place and monitored advises on best practice processes are in place Information and cyber security controls DPO Quality Assures and Ensures measures and Yes Designates school data lead and enables monitoring of data including encryption advises on best practice processes are in place DPO Quality Assures and Ensures measures and Pupil, staff and visitor consent Yes Designates school data lead and enables monitoring of data advises on best practice processes are in place Ensures privacy by design is Data Processing Impact Assessments Yes Approval of DPIA's Recommends DPIA's to COO adhered to as key tenet of Data leaddevelops DPIA for apporval GDPR Ensures measures and Freedom of information requests Yes DPO will advise on request Ensures all FOIs are responded to within statutory time frames processes are in place Ensures measures and Subject Access Requests Yes DPO will advise on request Ensures all SARs are responded to within statutory time frames processes are in place DPO will advise and report to Ensures measures and Enables data lead to invetigate data breaches without Data breach investigations Yes ICO processes are in place obstruction Makes recommendations to Supports Data Lead on Data lead conducts initial investigation and reports findings to Reporting to ICO and board Yes Reports to ICO and Trustees COO investigation where necessary DPO DPO Quality Assures and Ensures measures and Document retention compliance Yes Designates school data lead and enables monitoring of data advises on best practice processes are in place DPO Quality Assures and Ensures measures and Policy Management Yes Designates school data lead and enables monitoring of data advises on best practice processes are in place Data Controller Contract, Checks and DPO Quality Assures and Ensures measures and Yes Designates school data lead and enables monitoring of data Management advises on best practice processes are in place Monitoring and evaluating the status and DPO Quality Assures and Ensures measures and Yes Designates school data lead and enables monitoring of data effectiveness of privacy controls advises on best practice processes are in place Implement any recommendations made Ensures recommendations are Yes Designates school data lead and enables monitoring of data by the DPO within the timeframes set. follow through Ensure data is disposed of in a manner DPO Quality Assures and Ensures measures and appropriate to the type of data, including Yes Designates school data lead and enables monitoring of data advises on best practice processes are in place digital data. Maintain an up-to-date and compliant DPO Quality Assures and Ensures measures and archiving system which is labelled with Yes Designates school data lead and enables monitoring of data advises on best practice processes are in place the relevant retention periods. Ensure role-appropriate training is DPO Quality Assures and Ensures measures and Yes Designates school data lead and enables monitoring of data undertaken by all staff members. advises on best practice processes are in place Ensure websites and academy council ELT Quality Assures and Ensures measures and Designates school website lead and enables monitoring of Yes information is compliant advises on best practice processes are in place website data accuracy Shaw Education Trust Page 15 of 15 Scheme of Delegation September 2019 to August 2020
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