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Privacy Policy

1. SCOPE

All data subjects whose personal data is collected, in line with the requirements of the GDPR and the Data Protection Act 2018 by Schools Attain Ltd (trading as Schools Attain) through the use of Schools Attain products (including Analytics) and Schools Attain marketing activities.

2. RESPONSIBILITIES

2.1 The Operations Manager is responsible for ensuring that this notice is made available to data subjects prior to Schools Attain collecting or processing their personal data.

2.2 All Employees and Staff of Schools Attain who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured or the legal basis for processing their data has been communicated clearly.

3. PRIVACY NOTICE

3.1 Who are we?

We are Schools Attain. Our product, Analytics, was launched in 2020 by two secondary school curriculum leaders, Dave Webb and Mark Wolff, who had a vision to transform the way analytics was approached in schools. Our software makes a difference to schools throughout the UK.

The website www.schoolsattain.com, is run by Schools Attain.

When we refer to ’we’, ’our’ or ’Schools Attain’ we are referring to Schools Attain Ltd and Schools Attain Analytics.

Our Data Protection Officer and data protection representatives can be contacted directly here:

By email:

dpo@schoolsattain.com

The personal data we may collect or process on you is:

Registered Data Subjects

Non-Registered Data Subjects

The personal data we collect falls into different categories (sometimes more than one). Your data will be used for the following purposes:

Product - Information in this category is needed in order to be able to provide Schools Attain software to data subjects. In addition it is required to address or deal with any requests or enquiries.

Login - Information in this category is used to ensure we have a unique login method for each data subject in particular to improve website security.

Notifications - Information in this category allows us to provide data subjects with key product usage information to their preferred communication method.

Profiling - Information in this category allows the school to segment reports on usage of our products into key area to help and support specific students.

Marketing - Information in this category is used to send out Schools Attain product information to parties who have requested or are highly likely to have an interest.

Company - Information in this category is used to send out company information on Schools Attain and its products and services.

Payments - Information in this category is used to facilitate purchasing of software licenses or digital content online via Schools Attain.

Our legal basis for processing for the personal data:

Parents - Our legal basis for collecting and processing your data is your explicit consent which is obtained on the user completing registration of a new user account.

Students - Our legal basis for processing your data is Contract. We have this in place with your school. They may have a different legal basis for collecting your information originally which they will be able to provide.

Teachers / Staff Members - Our legal basis for processing your data is Contract. We have this in place with your school. They may have a different legal basis for collecting your information originally which they will be able to provide.

Schools Attain does not collect or process data defined as ‘special categories’ by the ICO such as: Racial; Ethnic origin; Political opinions; Religious beliefs; Philosophical beliefs; Trade union membership; Genetic data; Biometric data; Health data; Data concerning a natural person’s sex life or Sexual orientation.

3.2 Consent of Parent Data Subjects

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Schools Attain to process personal data. If in the future we may require sensitive personal data then we will always advise you on the reasons and how the information will be used.

Where we have obtained your explicit consent it may be withdrawn at any time by contacting us.

Once you have withdrawn your consent your account will be deleted and all of your personal data will be deleted and/or anonymised within 28 days of your consent being removed.

3.3 Legal basis for processing Student, Teacher and School Staff Member data

We are processing your personal data based on our Contract with your school. You may object to this processing by contacting your school directly. Your school will then work with us to block any future data coming through to our system. We will then remove / anonymise all your personal data on our system within 28 days of the request being made.

3.4 Legal basis for processing Non-Registered Data Subjects data

We are processing your personal data based on Explicit Consent. You may opt out of this processing at any time by contacting us.

Once you have opted out, we will no longer contact you with information about Schools Attain products and all of your personal data will be deleted and/or anonymised within 28 days.

3.5 Disclosure

In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Further information is available on request about the factors we shall consider when deciding whether information should be disclosed.

You can also get further information on:

• agreements we have with other organisations for sharing information;
• circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics;
• our instructions to staff on how to collect, use and delete personal data; and
• how we check that the information we hold is accurate and up to date.

Except as set out above, Schools Attain will not pass on your personal data to new third parties without first obtaining your consent. All third parties will have in place agreements consistent with GDPR requirements. We will never sell your data to third parties. The following third partu will receive your personal data for the following purpose(s) as part of the processing activities:

Scroll horizontally to see full table

In addition to the above exceptions, you provide your general consent to Schools Attain, with appropriate safeguards and procedures, to utilise media channels such as Facebook, Twitter and Google to provide company updates and product information.

3.6 Retention period

Schools Attain will process and store personal data for students, parents, teachers and school staff members for the duration of the schools license with Schools Attain. If you leave the school during an active license with your school we will delete/anonymise your personal data within 28 days of your account being deleted by your school.

For non-Schools Attain users we will process and store personal data while we are in contact with you with relevant information on our services. If we have not contacted you for a period of 1 year your data will then be removed from our system automatically.

If you have opted out to your data being processed we will delete your data within 28 days of your opt out being received.

3.7 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review – in the event that Schools Attain refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.7 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.5 above) in the processing of your personal data.

3.8 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Schools Attain (or third parties as described in 3.5 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Schools Attain’s Data Protection Officer.

The details for each of these contacts are:

Supervisory authority contact details

Contact Name:	Information Commissioner’s Office (ICO)
Contact Details:	https://ico.org.uk/concerns/

Data Protection Officer (DPO) contact details

Contact Name:	Schools Attain DPO
Contact Details:	dpo@schoolsattain.com

4. Online privacy statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information

This privacy notice tells you how we, Schools Attain, will collect and use your personal data for (i) supporting in the use of our software, (ii) contacting you about key notifications about our software and (iii) in certain cases sending marketing information about our products.

Why does Schools Attain need to collect and store personal data?

For students, parents, teachers and school staff members, in order for Schools Attain to provide those users with our online services, we need to collect and process their personal data for delivering the features within our software to the right person and with the right information.

For marketing purposes we focus on main contacts, network managers or bursars with Schools Attain that have consented to receiving relevant material. In respect to other individuals we will confirm their consent to receive marketing information or contact these users for additional consent.

For non-registered users we need to collect and process personal information on users who have expressed an interest in our educational software so we can contact them with the relevant information. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

Will Schools Attain share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Schools Attain in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to support in delivering our product functionality to our users. When they no longer need your data to fulfil this service, they will dispose of the details in line with Schools Attain’s procedures. We do not currently process any sensitive personal data, however in the future if this changes and we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Schools Attain use the personal data it collects about me?

Schools Attain will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR) and the Data Protection Act 2018. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Schools Attain is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Schools Attain contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

If you are a parent or non-registered user Schools Attain at your request, can confirm what information we hold about you and how it is processed.

If you are a student, teacher or school staff member Schools Attain will need to receive a request from your school (the data controller) to activate a subject access request.

If Schools Attain does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Schools Attain or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

A small charge may be applicable to organise some information in a form that is in a non-database format and easily understanbdable.

What forms of ID will I need to provide in order to access this?

Schools Attain accepts the following forms of certified ID when information on your personal data is requested:

• Passport
• Driving Licence
• Birth certificate

Once ID has been approved these records will not be retained.

How does Schools Attain protect my personal data?

Schools Attain are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Does Schools Attain collect any other information about me?

When using our products we collect navigational / usage data. This data is anonymised to is not considered personal data. This information can consist of information such as geographical location, browser type, referral source, length of visit, pages viewed and phone make and model.

We use navigational / usage information to operate and improve our products on an aggregated basis.

We also collect IP address information on users via Amazon Web Services product Cloudwatch. This information is not stored alongside any personal information so is not considered personal information itself. This information is used for preventative and detective controls. In particular the controls can include a host-based intrusion detection system (HIDS) that monitors and analyses network traffic, log files and file access on our system which enables us to create automated alerts to detect and address attacks, unauthorised or suspicious activities and general errors in on the platform.

Contact details of the Data Protection Officer / Operations Manager

Contact Name:	Schools Attain DPO
Contact Details:	dpo@schoolsattain.com