FFT Education Privacy Notice
This privacy notice
Welcome to the privacy notice of FFT Education Limited (FFT).
This notice tells you what we do with personal data relating to the users of our services as well as data that is processed by us in providing those services, in particular the personal data of pupils of schools in England and Wales. It also tells you what we do with personal data collected through our websites, including cookies and applications submitted through website forms.
FFT takes your privacy very seriously. We ask that you read this privacy notice carefully as it contains important information about what to expect when we collect and process your personal data and how we will use your personal data.
These websites fft.org.uk, fftaspire.org, analytics.fftaspire.org, ffteducationdatalab.org.uk, training.fft.org.uk and fft.peoplehr.net (the websites) are operated by FFT, a not-for-profit limited liability company incorporated in England and Wales under company number 03685684, with its head office at 1st Floor, 79 Eastgate, Cowbridge, Vale of Glamorgan CF71 7AA.
These websites are not intended to be used by children.
FFT Aspire is a well-established service provided to schools and organisations that support them (Local Authorities, Multi Academy Trusts and Diocese) to help schools to improve educational outcomes through the use of data. Aspire can be accessed through the websites fftaspire.org and analytics.fftaspire.org
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing your personal information so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
Data controller and how to contact us
FFT is the data controller and responsible for your personal data (collectively referred to in this privacy notice as FFT, “we” “us” or “our”).
Some of the personal data we process is provided to us on behalf of third party data controllers including the Department for Education or our customers, which include local authorities, academy trusts, dioceses and schools. In some circumstances we will only be the processor of that data and in other circumstances we will also be a controller of that data.
We have appointed a data protection officer for overseeing questions in relation to privacy matters. If you have any questions about this privacy notice, including any requests to exercise your data protection rights, please contact them using the details set out below.
Phone: 01446 776 262
Write: Helen Robinson (DPO), FFT Education Ltd, 1st Floor, 79 Eastgate, Cowbridge, Vale of Glamorgan, CF71 7AA.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example if you are a user of the Aspire platform and you change your email address.
The information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, such as:
- Identity Data includes first name, last name, username, email address and job title.
- Contact Data includes employer, work address, country of residence, phone number, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, settings, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites and the Aspire service.
- Profile Data includes your username and password, interests, preferences, feedback, survey responses and training received.
- Usage Data includes information about how you use our websites and services, including areas of Aspire accessed, analyses viewed and updates made.
- Marketing and Communications Data includes your preferences in receiving marketing communications and your communication preferences.
- Careers Data includes information provided in applying for a role through fft.peoplehr.net, including job history and other CV data in addition to Identity Data and Contact Data.
- DfE Pupil Data provided to us by the Department for Education about current and former school pupils including name, data of birth, gender, language, ethnicity, school(s) attended and the home census output area, school exam and assessment information, any special educational needs and attendance and absence information.
- DfE teacher pseudonymised data provided to us by the Department for Education about current and former teachers including role, qualifications and subjects taught.
- Customer Pupil Data includes information obtained from schools and organisations supporting schools (such as local authorities, academy trusts, dioceses and other education providers) including, in addition to pupil data provided by the DfE, details of which pupils are on-roll, absence information, pupil estimates and targets, teacher assessments, assessment results from tests, allocation to pupil groups and data in respect of which teachers taught particular pupils.
We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us to develop our website and our services. Aggregate information may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We may also provide such aggregate information to third parties. If we do combine or connect any aggregate information with your personal data so that it can identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about users (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
The DfE Pupil Data and Customer Pupil Data we process does include Special Categories of Personal Data. This data (including language, ethnicity and information about special educational needs) is used to help customers to ensure that all of their pupils are given equality of opportunity and treatment. For example, it may be used to create “value added” models to compare the progress of pupils with similar characteristics in different schools. The legal basis of processing is covered by the Data Protection Act 2018, Schedule 1, part 2, paragraph 8 (Substantial Public Interest Conditions – Equality of opportunity or treatment).
How is your personal data collected?
We use different methods to collect data from and about you, including through:
- Direct communications. When you input your details to set up a user account or ask for support we collect your Identity Data, Contact Data and Profile Data.
- From your employer.FFT customers provide information about their users of Aspire to FFT which may include Identity Data, Contact Data and Profile Data.
- From the Department for Education. The Department for Education provides DfE Pupil Data subject to agreements with FFT.
- Customer data. Schools, local authorities, academy trusts, dioceses and other education providers provide Customer Pupil Data to be added to Aspire in their use of the service, subject to the terms of contracts between the customer and FFT.
- Automated technologies. As you interact with our websites, we automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs and other technologies. Please see section 8 below and our Cookies Policy for further details.
How we will use your data
We have set out in the table below a description of the ways we plan to use your personal data and which legal bases we rely on to do so. We have identified what our legitimate interests are where appropriate.
|Purpose/activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To allow schools and organisations who support schools (such as local authorities, academy chains and dioceses) to analyse pupil data and related analyses via the Aspire portal|
|To create and apply models to analyse past and future pupil performance|
|To produce research outputs including research papers and educational blogs|
|To register you as a user of Aspire|
|To process and deliver invoices to customers and to evidence use by customers|
|To evidence use by customers|
|To manage our relationship with you which will include:|
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
|To provide helpdesk, support and maintenance services to users of Aspire|
|To make suggestions and recommendations to you about products or services that may be of interest to you|
|To review your application for a job|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences|
|To record what training courses you have attended and offer other related services|
|To undertake research into how education systems function|
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. You can contact us for more information about this. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We will retain and process your data for as long as we require it for the purposes for which it was collected or as is otherwise required by applicable law. To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the risk of potential harm from its unauthorised use or disclosure, the purposes for which we process it, whether we can achieve our purposes through other means, and the applicable legal requirements.
In respect of Pupil Data provided by the DfE, we will:
- Remove identifying information at the end of the academic year in which the learner reaches age 21.
- Delete the data no later than the end of the academic year in which the learner reaches age 23.
- In full, within 20 working days of termination of our contract with the Department for Education.
In respect of Customer Data, we will delete the data no later than 48 months after termination of the customer’s subscription term.
In respect of the data of Aspire users, we will delete this data:
- 7 years after termination or expiry of the relevant Aspire subscription.
- 7 years after the subscribing organisation has deleted the relevant user from Aspire.
Once your personal data is no longer needed, we will securely delete or anonymise it. We may continue to use anonymised data, which cannot be associated with you, for research or statistical purposes.
When we will disclose your data to third parties
We will not sell, exchange or otherwise distribute your personal data to unaffiliated third parties without your consent, except to the extent required by applicable laws and regulations, or as set out in this privacy notice.
We may share data we collect with any related company (or other incorporated or unincorporated entity) within our corporate group and with selected third parties including:
- our UK partners (including local authorities, academy trusts and dioceses), where we enter into agreements to support the provision of services to schools;
- Other business partners, in order to provide our services (for example where we enter into agreements with third parties who provide services to us or on our behalf); and
- analytics and search engine providers that assist us in the improvement of our website and the services we provide.
We may also disclose data we collect to third parties:
- if we undergo a change of control or any of our business or assets are sold or transferred (in which case we may disclose your data to the prospective seller or buyer);
- if we or substantially all of our assets are acquired by a third party, in which case information held by us about our website users will be one of the transferred assets; or
- if we are under a duty to disclose or share your information in order to comply with any legal obligation or legal process (for example, a court order), or in order to enforce or apply our contractual rights or any other agreement; in order to protect the rights, property, or safety of our website users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Local authorities have access to school user data for administrative purposes where the school has subscribed to Aspire through that local authority.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us. We may use your Identity, Contact, Marketing and Communications, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us, are a customer or user of our services, or we have obtained your business contact details as a prospective customer from elsewhere (including your employer’s website or a directory) and, in each case, you have not opted out of receiving that marketing.
Opting out. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Cookies and other information-gathering techniques
How we protect your data
We will use all reasonable efforts to safeguard your personal data and we have put in place security procedures and technical and organisational measures to do so, including encryption. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We do not transfer, or allow the transfer by our external processors, of pupil data outside of the UK.
Some of our external third parties (for example, the provider of our customer management system) are based outside the European Economic Area (EEA) so their processing of your personal data (other than pupil data) will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
In some circumstances you have rights in relation to the personal data we hold about you. Please contact us using the contact details above if you wish to exercise any of these rights.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
You will not usually have to pay a fee to exercise these rights but if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee (or refuse to comply with your request).
We may need specific information from you to help us confirm your identity and to speed up our response; this helps keep your personal data safe and speeds up our response to your request. We try to respond to all legitimate requests within one month but this period may be longer if your request is particularly complex or you have made multiple requests; we will notify you in this case.
If we are only a data processor in respect of the data to which your request relates, we may not be able to comply with that request and will redirect you to the relevant data processor.
Links to other sites
Our websites may contain links to other sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. This privacy notice applies only to this website so when you access links to other sites you should read the privacy notice applicable to that site.
Changes to our privacy notice
We keep this privacy notice under regular review. If we change our privacy notice, we will post the changes on this page, and may place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times.
Updated: 23 October 2019