Thanks for clarifying the actual sub-section of GDPR. We haven’t said that a data breach has occurred, simply that it is a distinct possibility. I agree that a lawyer would need to look at the documentation, to be sure either way. In terms of how OAA rank pupils if the data is anonymised - yes I’d be interested in finding out the answer to that too - it appears that it is happening is some LAs local to ours, however, and Heads from those other LAs said that it works successfully. In LAs where the LA has retained overall responsibility - yes I agree that must have happened because all schools have reached an agreement for that to happen, perhaps because they all wanted to remove the potential for unfairness and malpractice - an admirable aim in my view. You seem to think that the words ‘marketing’ and ‘poaching’ are interchangeable - not so - in fact they are completely different. Marketing is acceptable, and all schools do it, but actually using names, addressses and telephone numbers, provided to nomnaintained schools by the LA, goes way beyond marketing and, yes, adds up to poaching.