Are you registered with the Information Commissioner's Office?

In a previous article we looked at the differences between Freedom of Information Requests and Subject Access Requests and how these should be responded to. Schools and Academy Trusts are becoming increasingly aware of their duties under data protection law. Part of these requirements is the need for all Multi Academy Trusts (MATs) to be registered with the Information Commissioner's Office (ICO). It is in fact a criminal offence if you are not registered.

Why do MATs have to register with the ICO?

Academies will inevitably process lots of personal data of both children and employees from pupils' exam results to employees' appraisals. Although the Scheme of Delegation allows for some control to be given to Local Governing Bodies or Heads of individual academies within a MAT, it is the MAT itself that is the legal entity with the ultimate control and responsibility for the activities of all the academies. As a result of this, it is the MAT which is deemed to be the data controller which processes the personal data of individuals under the Data Protection Act 1998. The MAT must therefore be registered with the ICO as all data controllers processing personal data are obliged to.

How do MATs register with the ICO?

The registration process is quick and easy using the ICO's online process. To register, details about the MAT including its name, address, Companies House number, number of staff and turnover need to be given. You will also need details about the type of data that you process.

The fees required to register with the ICO vary depending on the size and turnover of an organisation. However, as registered charities, the registration fee for MATs is fixed at £35. Registration must be renewed annually at this fixed fee of £35. You will be notified by the ICO once it is time to renew. Providing the MAT is registered with the ICO, the individual schools within the MAT do not need to be separately registered. However, for full transparency, the ICO recommends that the schools within the MAT are shown as trading names on the MAT entry.

For further information and guidance on registration or data protection law, please contact Rosie Phillips on