biuro@lozinska-adwokat.pl

RODO chroni informacje o uczniach

RODO chroni informacje o uczniach

Prawo oświatowe tajemnica nauczycielska RODO dobry adwokat wrocław kancelaria prawna

RODO chroni informacje o uczniach

Przepisy wprowadzające RODO do Prawa oświatowego

W dniu 4 maja 2019 r. weszła w życie ustawa z dnia 21 lutego 2019 r. o zmianie niektórych ustaw w związku z zapewnieniem stosowania rozporządzenia Parlamentu Europejskiego i Rady (UE) 2016/679 z dnia 27 kwietnia 2016 r. w sprawie ochrony osób fizycznych w związku z przetwarzaniem danych osobowych i w sprawie swobodnego przepływu takich danych oraz uchylenia dyrektywy 95/46/WE (ogólne rozporządzenie o ochronie danych). 

Powyższa ustawa dostosowuje polskie przepisy prawne do RODO. Nowelizacja przewiduje wiele zmian w dotychczasowych uregulowaniach. Zmiany wprowadzono między innymi w ustawie z dnia 14 grudnia 2016 r. – Prawo oświatowe.

Obowiązek zachowania w poufności według RODO

Dostosowanie przepisów Prawa oświatowego do standardów przewidzianych przez RODO skutkowało wprowadzeniem ustawowej  ochrony informacji o uczniach.

Do ustawy – Prawo oświatowe dodano art. 30a, który ukonstytuował obowiązek zachowania w poufności informacji uzyskanych w związku z pełnioną funkcją lub wykonywaną pracą. Tajemnicą objęte są informacje dotyczące zdrowia, potrzeb rozwojowych i edukacyjnych, możliwości psychofizycznych, seksualności, orientacji seksualnej, pochodzenia rasowego lub etnicznego, poglądów politycznych, przekonań religijnych, jak również światopoglądowych uczniów.

Do przestrzegania obowiązku zachowania w poufności ww. informacji zostali zobowiązani nie tylko nauczyciele. Ustawa wskazuje bowiem także inne osoby pełniące funkcje lub wykonujące pracę w:

  • innych formach wychowania przedszkolnego,
  • szkołach,
  • placówkach,
  • organach prowadzących szkoły lub placówki,
  • organach sprawujących nadzór pedagogiczny oraz
  • innych podmiotach realizujących zadania i obowiązki określone w ustawie.

Ustawowe odstępstwa od obowiązku zachowania poufności

Niemniej jednak nowy przepis przewiduje trzy sytuacje, w których nie stosuje się zasady zachowania w poufności informacji dotyczących uczniów:

  • w przypadku zagrożenia zdrowia ucznia,
  • jeżeli uczeń, a w przypadku ucznia niepełnoletniego jego rodzic, wyrazi zgodę na ujawnienie określonych informacji,
  • jeśli przewidują to przepisy szczególne.

Co oznacza w praktyce obowiązek zachowania poufności?

Trudno stwierdzić jak w praktyce będzie funkcjonował omawiany obowiązek zachowania poufności. Dodany przepis jest bowiem bardzo ogólny i jednocześnie nie reguluje wielu istotnych kwestii. Z jednej strony umożliwia to więc dostosowywanie wewnętrznych procedur do konkretnych przypadków, z drugiej jednakże stwarza okazję do nadużyć lub zaniedbań. Czas też pokaże czy nie będzie to wyłącznie martwy przepis, czyniący zadość  jedynie formalnie wymogom RODO. 

 

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