Welcome to the privacy notice of Education Analytics and Training Ltd.
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.
Education Analytics and Training 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.
The websites https://ealstar.co.uk and https://app.ealstar.co.uk/ (the websites) are operated by Education Analytics and Training, a limited company incorporated in England and Wales under company number 13328562 with its head office at 10 Bolton Road West, Ramsbottom, Bury, England, BL0 9ND.
The website is not intended to be used by children.
Education Analytics and Training provides schools and organisations that support them (Local Authorities, Multi Academy Trusts and Diocese) with assessment services that can assist with improving the outcome and data management of students learning English as an additional language.
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
Education Analytics and Training is the data controller and responsible for your personal data (collectively referred to in this privacy notice as Education Analytics and Training, “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 most circumstances we will only be the processor of that data and in other circumstances we will also be a controller of that data.
If you have any questions about this privacy notice, including any requests to exercise your data protection rights, please contact us using the details set out below.
Email: privacy@ealstar.co.uk
Phone: 00 44 161 3273735
Write: Education Analytics and Training Limited. c/o 10 Bolton Road West, Ramsbottom, Bury, England, BL0 9ND
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 EAL STAR platform and you change your email address.
THE DATA WE COLLECT
This personal data is required to enable us to provide the services you require to you. If you do not provide personal data we ask for, it may delay or prevent us from providing those services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific service or website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
HOW WE WILL COLLECT YOUR DATA
We use different methods to collect data from and about you, including through:
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 register you as a new customer | (a) Identity (b) Contact |
(a) Performance of a contract with you. (b) Used as a unique identifier. (c) Prevents duplicate records being created. |
To process and deliver your service including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To provide the necessary deliverables for a Service to you. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Special Category Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests such as: (i) Reporting purposes (i) for communication purposes (iii) to help measure the impact of key services (iv) in relation to any incidents involving the data subject |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We will only use your personal data if we have a proper reason for doing so for example:
A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by your own rights and interests.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
How and why we use special category personal data
Under data protection law, we can only use special category personal data where:
There are ten potential grounds for using special category personal data under data protection law. Generally, where we use special category personal data, we will do so on the ground that this is necessary for providing services relating to children and establishing, exercising or defending claims. This includes using special category personal data, where necessary, for:
Where this does not apply, we will seek explicit consent to process special category personal data.
MARKETING
We may use your Identity, Contact, Technical, 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 (we call this marketing).
If you have agreed to receive marketing, you may always opt out at a later date.
You have the right at any time to stop Our Company from contacting you for marketing purposes or giving your data to other members of the Our Company Group.
We may share your personal data with the parties set out below for the purposes set out in the table above:
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.
We store your data securely within the European Economic Area (EEA). On rare occasions we, or our external third parties, may need to transfer your data outside the European Economic Area (United Kingdom UK). If we transfer your personal data to any country outside of the European Economic Area or the United Kingdom, we only do so if that data is protected by appropriate safeguards, including the use of standard data protection clauses adopted or approved by the European Commission or the UK government.
In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those 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.
Our Company securely stores your data on Cloudways - Cloudways is a managed cloud hosting solution that is fully protected with end-to-end encryption that ensures that all data in transit is protected and encrypted with HTTPS protocol, preventing access to data during transfer from one system to another. Their privacy policy can be viewed here Terms of Service | Cloudways
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 will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. After an account has expired, we will safely retain data for a period of 6 months to allow for opportunity to re-subscribe and reinstate access to your school assessment and tracking data. You will be notified by email 2 weeks before the 6-month period, to let you know a full deletion is about to occur. After this it will not be possible to reinstate any historic data, even if your school re-subscribes at a later date.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see “your legal rights” below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Access | 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. |
Withdraw consent | 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. |
Rectification | The right to require us to correct any mistakes in your personal data. 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. |
To be forgotten | The right to require us to delete your personal data—in certain situations. 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. |
Restriction of processing | 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:
• If you want us to establish the data’s accuracy. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. |
Data portability | 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. |
To object | 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 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. |
Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the EAL HUB Limited group of companies and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
External Third Parties