Smartgrade Ltd is a private company registered in England and Wales. Company No. 12415626. VAT Registration No. 343644011. This policy underpins the promises and contracts we make with schools relating to the education data that Smartgrade processes and was last updated on 4th September 2020. We review this policy annually.
Data Protection Legislation
Sensitive Personal Data
Smartgrade is a secure, cloud-based platform that helps schools and MATs to create, share and analyse more reliable assessments.
Privacy and security are at the heart of everything we do at Smartgrade, and our approach incorporates data protection by design and default. This statement explains the key measures we’ve put in place to ensure that a school’s data is kept secure and processed appropriately at all times. It also covers our commitments to you, and what we expect from schools in terms of privacy and data protection.
We DO NOT:
Security and Encryption
We take every reasonable measure to ensure we store data securely. The Smartgrade platform is developed using secure technologies, which include, but are not limited to the following:
Staff access to data
Smartgrade does not look "under the hood" or inspect any of the data we store. The only exceptions to this are where a school has explicitly given us permission to inspect their data; for example, to provide technical support to correct a technical problem.
All our staff and subcontractors are required to agree that they will abide by a Security and Data Protection Policy at all times.
Deleting and Retaining Data
We retain personal data on our platform for as long as necessary to provide the Smartgrade service. If a school ceases to use Smartgrade, we delete their data within 5 working days. We will also delete all personal and sensitive data relating to former students automatically on their 25th birthday, regardless of whether a school has asked us to do so.
Assessments created on our platform
Schools and MATs retain ownership of all assessments and/or assessment templates they create and share using our platform. All users creating assessments on the site are responsible for ensuring that they have the necessary rights and permissions to use and share those assessments. Assessment owners may withdraw their assessments from the Marketplace at any time, in which case they will cease to be available to users from that point onwards. However, any assessments that had already been assigned to classes by a user at the point of removal will remain available to that user indefinitely for marking and analysis.
We take all reasonable and necessary precautions to ensure that your data is secure and to recognise and then mitigate the risks to security and privacy. However, it is not possible to 100% guarantee the security of any data transmitted or stored electronically. In the event that a significant breach of security or privacy did occur, Smartgrade will contact the Data Controller of the affected data, and inform the Information Commissioner's Office (ICO), and other authorities without undue delay and within 72 hours.
Purpose of data processing and legal basis for processing
As the Data Controller, it is Your responsibility to ensure that You can engage with Smartgrade in accordance with the Data Protection Act and that Data Subjects are suitably informed about Data Processing services such as Smartgrade, that the school chooses to use. This should include an explanation of how personal and sensitive personal data is processed lawfully, fairly and in a transparent manner. You should also be clear on Your basis for collecting and sharing data, and must satisfy the relevant legal basis and permission standards in each case.
The categories of personal data we process and the purposes for doing so are as follows:
|Staff contact information|
|Student demographic information (Gender, English as an Additional Language, FSM, Pupil Premium, SEN status, Ethnicity, LAC status)|
|Student teaching group / Year Group / Subject|
|Student UPN / MIS ID|
|Student Prior Attainment|
We may share data with the following companies if such a need arises and within the terms laid out by this policy:
We access MIS information from schools via Wonde, the third party MIS integration service.
Information for students and parents/guardian
Smartgrade, as the Data Processor, only has access to Personal Data or Sensitive Personal Data as requested by the school, as Data Controller, and only for the purposes of performing services on a school's behalf.
Your child's school remains the Data Controller of any pupil data we process. If you have questions about your or your child’s data or how your school is making use of our service, please contact the school directly. Any pupil or parent/guardian enquiries we receive will be directed to the relevant school as the Data Controller for that child’s or parent's/guardian's data.
If you have expressed interest in Smartgrade on the Smartgrade website or signed up as a Smartgrade customer, and have supplied your email address, we may occasionally send you an email to tell you about new features, ask for feedback or keep you up to date with our products. If you no longer wish to be included on these communications, then You can opt out using the links on those communications, or email email@example.com and we will remove you from the list.
Third Party Websites
We cannot be responsible for the privacy policies and practices of other sites even if you access them using links on our website. We recommend that you check the policy of each site you visit and contact the owner or operator if you have any questions or concerns.
Questions and Grievances
If you have any questions or grievances in relation to security or privacy, please email us on firstname.lastname@example.org.
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