The personal information you give us is important. Getting to learn about you means that we can give you products and services that best meet your needs.
Our privacy notice explains what information we collect, what we do with it, how we collect it and keep it secure.
- The data we collect
- Collecting your data
- What we do with it
- How we store and protect it
- How we share your data
- Data sharing
- Third parties
- International transfers
- Automated decision making
- Your rights
- Making a complaint
- Opting out
- Legal basis for processing data
- Contact us
Last updated: November 2023
Who we are
The legal entities that make up 腦瞳肊 (eg “腦瞳肊”, “we”, “us” or “our”), responsible for your personal information are:
- 腦瞳肊 Education (registered office: Devas Street, Manchester, M15 6EX).
- 腦瞳肊 Milton Keynes (registered office: 4 Garamonde Drive, Wymbush, Milton Keynes, Buckinghamshire, MK8 8DF).
- AC3 Solutions Ltd (registered office: Devas Street, Manchester, M15 6EX).
- AlphaPlus Consultancy Ltd (registered office: Devas Street, Manchester, M15 6EX).
- Blutick Ltd (registered office: Unit 109 Birdwood Road, Cambridge, United Kingdom, CB1 3TB).
- Doublestruck Ltd (registered office: Devas Street, Manchester, M15 6EX).
- GradeMaker Ltd (registered office: Devas Street, Manchester, M15 6EX).
- Oxford International 腦瞳肊 Examinations (registered address: Oxford University Press, Great Clarendon Street, Oxford, England, OX2 6DP).
- Training Qualifications UK Ltd (registered office: Crossgate House, Cross Street, Sale, M33 7FT).
The data we collect
The type and level of personal information we collect varies, for example:
- Identity – names, date of birth, gender, candidate number, passport, birth certificate, driving license.
- Contact – e-mail address, address, telephone number, marital status, next of kin, dependants, emergency contact details.
- Assessment – examination history, subject, grade, type of qualification and centre.
- On-screen assessment – biometric data such as audio, video of facial features, facial recognition by human or AI, identity documents, voice, images of home/working space, examination history, subject, grade, type of qualification and centre.
- Pupil – Unique Candidate Identifier (UCI), centre number, admission number, year group, registration group, teacher name, class, supervisor name, ethnicity, eligibility for free school meals, FSM6, pupil premium indicator, SEN status, LEA care status.
- Financial – bank account details.
- Transaction – details of software products and services you’ve got from us. Purchase order details, and payments made to/from us.
- Biometric data – such as your fingerprint if you visit and require access to our sites, and CCTV of your person if you attend one of our sites.
- Technical – internet protocol (IP) address, login data, operating system and platform.
- Marketing – preferences when you receive communications from us and our third parties. The technologies used, and any related correspondence.
- Usage – use of our website, performance and other communication data.
- Survey – comments and opinions provided in response to a survey.
- Recruitment – education, qualifications, occupation, work history, referees, training and skills development, nationality, experience, right to work in the UK, criminal checks (if your role requires it) ad equal opportunity monitoring.
- Employment – the terms and conditions of your employment, salary or fee payments, benefits, work patterns, National Insurance number, attendance, holidays, sickness, disciplinary or grievance issues, medical or health conditions, disabilities (for which 腦瞳肊 needs to make reasonable adjustments); and information about your vehicle, driving licence, MOT and insurance documents if you drive on company business.
- Performance – reviews and rating, development plans and related correspondence; and timesheet information.
- Activity – the websites our employees visit while using an 腦瞳肊 computer or network. The activity logs held within our systems and databases.
- Communications – emails you send or receive via our email system.
- Disclosure and Barring Service (DBS) – a DBS check reduces the risk of fraud or other unlawful acts.
- Digital data – such as audio recording of calls and webchat data to our contact centre and telephony system. Video/Audio recordings of web-conference meetings and webinars. See also online assessment data listed, as it applies. CCTV imagery both inside and outside of our buildings, including images of vehicles. Analytics/Cookie data from our 腦瞳肊 website depending on the level of interaction with our cookie banner and preference centre. Interaction on social media with 腦瞳肊 or about 腦瞳肊’s products and services.
- Behaviour – how you may interact with certain sections of an event you attend where 腦瞳肊 are present, attend or host.
- Safeguarding – information divulged to us by children, young adults and individuals at risk through use of our services, which we have a duty to investigate and act upon.
Online forms and electronic communications
All data that you provide in any of our online forms or through other electronic communications is done so at your own risk. This includes any sensitive, special category or potentially criminal data. Unless specifically requested or required, you should avoid providing these types of data to 腦瞳肊.
腦瞳肊 also collects, uses and shares aggregated data such as statistical or demographic data for any purpose. Aggregated data 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if 腦瞳肊 combines or connects aggregated data with your personal data so that it can directly or indirectly identify you, it will treat the combined data as personal data which will be used in accordance with this privacy notice.
Special category data
As an employer and provider of assessment products and services, 腦瞳肊 has to collect and process special category data of employees, associates, contractors, trustees, and importantly students. We treat this data with the extra protections required as set out in the UK General Data Protection Regulation (GDPR) and Data Protection Act (DPA) 2018 and take these requirements very seriously. We have in place, as required by legislation, an appropriate policy document for the types of special category data processing conducted by 腦瞳肊, the lawful basis, purposes, and the conditions to be able to process such data. The main purposes 腦瞳肊 process special category data are for: equality, diversity and inclusion; employment law; and the safeguarding of children and adults at risk. If you would like to know more and review this policy, please get in touch with the Data Protection Office. You can find contact details in our contact us section.
Collecting your data
We may collect personal data from you if you:
- register at an approved centre
- take part in our examinations, training, surveys or related events
- use our website, app, products or services
- interact with us through social media, email, post, text or phone, or use one of our cookies
- are a job applicant, employee, ex-employee, associate, trustee, committee/advisory group member, contractor or temporary employee.
We may capture information by telephone or CCTV when you call or visit 腦瞳肊.
There are 65 cameras at the Manchester Devas Street site, 7 cameras at Manchester Synergy House, 63 cameras at the Guildford site, 40 cameras at Milton Keynes Optima Wymbush, 5 cameras at Milton Keynes Kiln Farm Potters Lane, 9 cameras at Milton Keynes Brunleys, and 5 cameras at the London site.
You can find them in our reception areas, loading bays, entrances, blind spots and key points. The cameras are in operation 24 hours a day, 7 days a week, 365 days a year. There are signs which tell you that CCTV cameras are in operation and who to contact for further information.
Our cameras don't capture images which aren’t relevant to the purposes of the monitoring. Surveillance systems aren’t used to record sound. CCTV Recordings are kept for 3 months then overwritten.
There aren’t any cameras in areas where there’s an expectation of privacy (e.g. toilets or changing rooms).
Covert surveillance (where you’re unaware that the monitoring or surveillance is taking place), will only happen:
- in exceptional circumstances
- if we have grounds to believe that criminal activity or malpractice is taking place
- if after suitable consideration, there's no less intrusive way to tackle the issue.
Any covert monitoring or surveillance we have to do will take place for a reasonable period of time. It'll relate only to the suspected criminal activity or serious malpractice.
Cookies and similar technologies, analytics and targeted advertising
We use online tools to collect information from you. For example:
- Google Analytics improves our marketing campaigns, strategies and website content (we use )
- Third party tools help to keep our website updated and relevant to you
- Cookies and other similar technologies (such as tracking pixels) help us give you a personalised service.
We'll get in touch if you haven't completed and/or abandoned data entered on our websites and/or other online forms.
Our cookie banner and preference centre allow you to opt-in or out of the various types of cookies and similar technologies we serve in terms of Strictly necessary, Performance, Functional and Targeting. Please check out our Cookie notice for a dynamic listing of the cookies and similar technologies we serve and other information. Non-essential cookies are not loaded on our website unless you click 'Accept all'. Clicking 'Reject all' or not interacting with the banner will ensure only strictly necessary cookies are loaded in order to view our website.
You can also opt-out of the Google Display Advertising Features using , the , or .
Doing so, however, may restrict the functionality of the 腦瞳肊 website and a large proportion of other websites around the world as cookies are a common feature of most modern websites.
What we do with your data
Your personal information supports a range of different purposes and activities. The types of data we use, the legal base(s) we rely on when processing them and our legitimate interests are:
Type of Data
To set and mark tests and examination papers and maintain a permanent record of the examination results (this includes the security and integrity of the examination process, the delivery of accurate results to students; and our compliance with statutory regulations).
To develop, deliver, inform and publicise educational: products, policy, standards, qualifications, on-screen assessment, questions, resources and training (including the provision and funding of research to inform education policy and improve assessment practice, which may include the use of personal and special category data for equality, diversity and inclusion (EDI) purposes).
To promote education for the public benefit (this includes the provision of dedicated support and mentoring to young people through the 腦瞳肊 Unlocking Potential programme).
Capturing your data for events you may attend/book where 腦瞳肊 present at, attend or host by collecting data electronically or otherwise (sign up, booking, verbal, or scanners for example).
This is to provide you with relevant resources and information to support you in what you may be interested in from 腦瞳肊. You also consent to 腦瞳肊 providing your data to vetted third party suppliers to book and manage our events/venues.
To create an account, register you as a new customer and administer your account.
To manage our relationship with you, including: providing you with any information, products or services that you request from us; notifying you about changes to our products, services, events, terms and conditions or privacy notice; statistical analysis, market research, marketing, social media advertisements, and support.
Based on your marketing preferences we may use publicly available information to serve social media advertisements to you.
To process and deliver your order including: delivery of products and product features, recording your order details; keeping you informed about the order status; issuing product renewal notices, taking and processing payments and refunds, collecting money owed to us; and assisting fraud prevention and detection.
To use data analytics to: improve our website, products, services, marketing, social media advertisements, customer relationships and experiences; and for market research, statistical and survey purposes.
Based on your marketing preferences we may use publicly available information to serve social media advertisements to you.
We may track your interaction with our website (which includes cookies and tracking pixels), ad campaigns, other areas of the internet, and social media etc. This data is collected through your consent and settings whilst browsing the internet. The majority of this data is aggregated and anonymous which provides us with data on views, clicks, impressions etc.
To register you for email updates, recommend products and services, and events that may be of interest to you.
Based on your marketing preferences we may use publicly available information to serve social media advertisements to you.
To gather your opinions on our products and services, or on your experiences of education. This includes the creation of our Student Advisory Group, including EDI data collection required to ensure a complete cross section of society is represented.
To improve our customer service, monitor quality, resolve complaints and ensure compliance with regulations through contact capture, webforms and call recording.
To prevent crime and protect buildings and assets (of 腦瞳肊, occupants of the building and of their respective staff and visitors) from damage, disruption, vandalism and other crime.
For the personal safety of staff and visitors (of 腦瞳肊 and the occupants of the building) and other members of the public and to act as a deterrent against crime.
To support law enforcement bodies in the prevention, detection and prosecution of crime. This may include: social media and internet monitoring where 腦瞳肊 believe our products and services may be being illegally passed on or sold; and where we may be alerted to safeguarding issues/referrals which have been divulged to 腦瞳肊 by students through using our services.
To assist in the day-to-day management, including ensuring the health and safety of staff and visitors (of 腦瞳肊 and occupants of the building), and temporarily collecting dietary requirements if staff and visitors are provided food at any of our locations.
|To assist in the effective processing of appeals from centres or students in relation to grades received from 腦瞳肊’s assessment products and services.|
To assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings with staff (of 腦瞳肊 or occupants of or visitors to the building).
To assist in the defence of any civil litigation, including employment tribunal proceedings (involving 腦瞳肊 or occupants of or visitors to the building).
|Usage and recordings of web-conference meetings and webinars you may attend that are hosted or attended by 腦瞳肊.|
|To protect the security of commercial and personal and special category data in 腦瞳肊’s care by securing and monitoring activity within 腦瞳肊’s network, internet and email.|
For job applicants, employees, ex-employees, associates, contractors and temporary employees only:
Type of Data
To recruit the right people for our business, and manage their working relationship with us, including job role and responsibilities, salary or fee payments, progression, training, time-keeping, access control, performance management and disciplinary or grievance procedures.
Voluntary disclosures of special category data such as race/ethnicity, religion, legal gender, gender identity, sexual orientation, disability status, marital status and nationality.
This is to support our diversity and inclusion monitoring across the organisation, which is utilised anonymously, not used in recruitment decisions and only shared with colleagues on a need to know basis.
To arrange travel for you on 腦瞳肊 business and making appropriate safety arrangements for this, including monitoring your travel.
|To enable us to provide health benefits, Occupational Health, and wellbeing services to staff.|
|To enable us to test new and BAU systems using your data, where using dummy data is absolutely not viable.|
We may process your personal data using more than one lawful basis, this depends on the activity.
We’ll use your personal data for the reason we collected it. Unless we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your information for an unrelated purpose, we’ll let you know and explain the legal basis for this.
We may process personal data without your consent, in compliance with the above rules. Where it's required or permitted by law.
We'll keep your personal data:
- for as long as necessary
- for the purpose(s) its provided for
- and to meet our accounting, reporting, legal obligations and public interest responsibilities.
Disclosure and Barring Service (DBS) checks may be carried out on job applicants or employees hired for specific roles, with their consent. This is to guard against the risk of fraud or other unlawful acts being inflicted upon 腦瞳肊 customers, partners or employees. We encourage you to discuss any concerns you have regarding DBS checks with 腦瞳肊 directly.
For further details of the retention periods 腦瞳肊 applies to your data, please contact us.
How we store and protect it
We keep personal data confidential within a secure infrastructure protected by many firewalls and other technical and organisational measures. We are committed to keeping the security of our systems up to date.
Access to your personal data is only given to those who have a business need to know it. They can only access it on our instructions and they'll stay subject to a duty of confidentiality.
Any third party we work with must have security measures in place to process your personal data. 腦瞳肊 ensure their third parties protect your data under the law.
We have procedures in place to deal with any suspected personal data breach. We'd let you and the UK Information Commissioner know of a breach where we're required to do so.
We keep CCTV data on secure hard drives located within our offices. Sometimes we have to give data to law enforcement agencies, or data subjects under data protection law.
We follow a range of different governance processes. For example, we use the ISO27001 information security standard. We are currently ISO27001 certified.
How we share your information
We may share your personal information with the following, where we are the controller or joint controller of the information with other bodies and where we have a lawful basis to do so:
- The 腦瞳肊 group of companies (腦瞳肊 Education, 腦瞳肊 Milton Keynes, AC3 Solutions, AlphaPlus Consultancy, Blutick, Doublestruck, GradeMaker, Oxford International 腦瞳肊 Examinations and Training Qualifications UK).
- Government agencies, their partners and other third parties such as Ofqual, DfE, HMRC, Companies House, The Charity Commission, UCAS, Student Loan Company, Magistrates Courts, Centres/Schools/Academies, Employment Tribunals and Local Authorities.
- Affiliates, associates, business partners, suppliers (including their sub-contractors) or other third parties that we use to support the operation of our business. For example, to: carry out criminal or credit checks; support the logistics involved in the secure keying, scanning, storage and transportation of exam papers; provide IT systems and software, internet access, website or hosting solutions; organise events or provide marketing and advertising services; provide training and development services; deliver employee benefits, run payroll, perform occupational health checks and referrals, and provide employee assistance. Oxford University Press (OUP) for delivery of international products and services, other exam bodies and the Joint Council for Qualifications (JCQ) where joint working is required to process results.
- Our professional advisers including auditors, lawyers, bankers and insurers who provide professional advice, accounting, banking, legal, insurance, and pension services or to meet our audit responsibilities.
- Employers of associates, for example, the payment of teacher release vouchers.
- If you’ve given consent for us to share your data with a third party event, we may pass your data onto that third party.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 腦瞳肊 does not allow its third-party service providers to use your personal data for their own purposes and only permits them to process your personal data for specified purposes and in accordance with our instructions.
腦瞳肊 may add to your personal data any information it obtains from third parties that are allowed to share your data with 腦瞳肊. This may include data from its examination centres, schools and colleges, the Department for Education, search data providers or public sources. In each case, 腦瞳肊 will do only what is allowed by relevant laws.
腦瞳肊 may share non-personally identifiable information about the use of its websites or products publicly or with third parties; however, this will not include data that can be used to identify you.
- Authorised personnel watch our CCTV during working hours only. It's accessible remotely at other times if required.
- We can check live feeds from CCTV cameras, if for example we need to protect health and safety.
- Live feeds from cameras and recorded images are only viewed by approved members of staff.
- We can share images from our CCTV system. If for example someone's car has been broken into on our premises. We’re not responsible for the use these occupants or individuals make of those images.
- Law enforcement agencies can view or remove CCTV footage in the detection or prosecution of crime.
Data sharing with UCAS
UCAS will be provided with a copy of your candidate record for the relevant year, irrespective of whether you have made any applications to higher education institutions. This is so that there is no delay in processing your application should you decide to make a late application through the clearing system.
UCAS holds this information under strict instruction from 腦瞳肊, and the other awarding bodies, and is strictly prohibited from using the information (even consulting it) except as instructed.
UCAS is instructed to search the records to find candidates who have applied to UCAS, and to access the records of applicants. UCAS can use this information to process your application (please see the privacy notice that UCAS provides to you for more details about the information, how UCAS uses it, and how long it keeps it). If you do not apply to UCAS, however, it is instructed not to access your information.
Once clearing has finished, UCAS is instructed to permanently delete all of the records provided by 腦瞳肊 and the other awarding bodies. UCAS can only keep the information it extracted from these records if you applied to UCAS, and will let 腦瞳肊 know whether or not it accessed your records. 腦瞳肊 relies on legitimate interest in facilitating the UCAS clearing process to make sure students have a seamless integration into the admissions services.
Data sharing with the Joint Council for Qualifications (JCQ)
JCQ exam boards collectively share and process candidate-level data for the following purposes:
- To build the annual GCSE National Candidates Results Archive (NCRA), for use in research on standard-setting and to calculate prior attainment measures and prediction matrices used in GCE standard-setting.
- To create the annual candidate-level Key Stage 2 Prior Attainment data set, to match learners to collated GCSE results and to produce prediction matrices used in GCSE standard setting.
- To calculate ‘screening’ statistics after the completion of an examination series and to check that standards are aligned statistically between exam boards.
- Entries and grade data for:
- awarding endorsement grades in Ofqual-accredited GCSE English Language Spoken Language and A-level sciences
- identification of students entered for the same subject with multiple exam boards in the same examination series
- preparation of JCQ results statistics for publication
- research into standards in general, vocational and technical qualifications
- inter-board statistics and specification data
- preparation of examination timetables and key dates for publication
- preparation and use of national prediction matrices for standard setting
- preparation of JCQ advanced entries analysis
- summer results for GCSE Maths and English to feed into the November crosstabs.
We respect your data and expect all third parties to do the same.
We don’t allow our third-party service providers to use your personal data for their own purposes. They can process your personal data for specific purposes and under our instructions.
We can save any information we get about you from third parties, such as:
- examination centres
- schools and colleges
- other exam bodies
- the Department for Education (DfE)
- search data providers
- public sources.
In each case we’ll do only what’s allowed by relevant laws.
We can share information about our websites or products publicly or with third parties. This will not include data that can identify you.
Assessments impacted due to Coronavirus
The Coronavirus pandemic has severely affected the way assessments have been carried out and continues to have an impact. Awarding organisations, like 腦瞳肊, continue to find alternative contingency arrangements in some cases to ensure grades can continue to be applied. This means new ways of sharing information.
Data sharing processes for cancelled assessments
Type of Data
Sharing of personal data between awarding organisations and the JCQ for Statistical Analysis Processing, access to SharePoint facilities, Coalition Facilities and as part of Centre Virtual Visits
Processing user and usage information of each Approved Shared Data Administrator in the SharePoint Facility and Coalition Facility
Processing by the JCQ Malpractice Committee and Ofqual of any actual or alleged concerns.
Sharing and other processing of personal data by all awarding organisations for which the relevant Examination Centre is an Own Examination Centre, both as controllers and as processors.
Teacher Assessed Grades Quality Assurance Evidence supplied by each Examination Centre shall (if the Examination Centre is a Reviewed Centre) be evaluated by third party CQA Reviewers acting as processors.
Sharing of Provisional Final Outcomes to Higher Education Institutions and UCAS before Public Results Days
Data supplied to the WJEC and 腦瞳肊 from each Awarding Organisation the input data for Statistical Analysis Processing and output data from this process.
Data placed into the SharePoint facility to track status and work in progress and grades placed in the Coalition facility including final outcomes generated.
Information disclosed in connection with business transactions
Information that we collect from users, including personal data, is a business asset.
If we get a third party as a result of a transaction such as a merger or acquisition or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy,
some or all of our assets, including your personal data, will be disclosed or transferred to the third party in connection with the transition.
We'll always make you aware of such business transactions and give you the option to opt-out.
On the 28 June 2021, the UK was granted ‘adequacy’ by the European Commission in GDPR terms.
International transfers to the UK and 腦瞳肊 from the European Economic Area (EEA) and other adequate countries can continue to take place with no additional safeguards. This is alongside existing measures we have in place for international transfers outside of the EEA.
Data transfers from 腦瞳肊 to countries within the EEA
We can still send personal data to the EU/EEA, Gibraltar and other countries deemed adequate by the EU. They have adequate protection by the UK Government under the new arrangements. We’ll always do so securely in line with the GDPR principles.
Data transfers to 腦瞳肊 from countries within the EEA
Because the UK is now an ‘adequate country’ in data protection terms, the EEA do not require additional safeguards for transferring data to the UK.
Data transfers from 腦瞳肊 to countries outside the EEA (incl. USA and the rest of the world)
Our applications, services and products use service providers outside of the EEA. We may have to transfer some of your data to these providers so you can use our websites, services and products. Also, low level student personal data may be accessed from outside of the EEA for international associates (examiners) to mark 腦瞳肊 assessments or qualifications.
Appropriate measures and controls are in place to protect the transfer of your data.
Transfer of data is made in accordance with the requirements of the UK GDPR and DPA 2018 and may be based on the use of the for transfers of personal data outside the EEA. 腦瞳肊 also utilise the Information Commissioners Office’s (ICO) addendum for transfers to none adequate third countries outside of the UK and EEA. For transfers to the USA, we are able to send data to some companies without additional safeguards, as long as they are certified to the new UK-US Data Privacy Framework data bridge, which came into force in October 2023.
By using our websites, services, products or by interacting with us in the ways described in this privacy notice, you consent to the transfer of your data outside the EEA in the circumstances set out in this privacy notice.
If you don’t want your data to be transferred outside the EEA you should not use our websites or products.
Automated decision making
In certain situations 腦瞳肊 may have to make semi-automated decisions on the grading of exams/exam units, mainly when exams cannot take place or if a candidate is absent and unable to take an exam or set of exams.
Provided that students were entered for the units at the time, results will be generated based on results in the exams which students actually sat. This will be done by using statistical analysis processing for estimating missing marks, which is in line with . The calculation takes into account any differences in assessment performance that exist across different units. This is called mark estimation or back calculated mark.
This process has been documented in the legitimate interests of 腦瞳肊, and in the interests of the student and centre, to remove the possibility of the candidate receiving a grade of zero, and in some cases having to repeat a whole year of schooling. In other circumstances candidates will have the option to resit exams which are mark estimations or back calculated, if they're not happy with the grade applied.
Also, as per data protection legislation, candidates who may be affected by this process have the right to obtain human review into the grade applied, express their opinion or point of view, and to contest the decision. Visit the contact us page to find out more, or go to the contact us section at the bottom of this page.
You have several rights under the data privacy legislation. This includes, under certain circumstances, the right to:
- Access your data – you can access your data at any time by completing the subject access request form. Please be specific about what you want to know. We’ll need to confirm your identity before we release data to you.
- Correct your data – you can ask us to correct any data we hold about you that's inaccurate.
- Request erasure – you have the right to ‘be forgotten’, in certain circumstances. This doesn’t apply if it would prevent the performance of a contract with you. Or if there's another legal requirement for us to keep your data. If erasure is not possible, you may be able to ask us to restrict processing.
- Request the restriction of processing of your data – you can suspend the processing of your data under certain circumstances. For example pending a review of the accuracy of the data or after you have objected to our use of the data, and we need to establish whether we may lawfully continue processing it.
- Request the transfer of your data – in some cases, you can ask us to transfer the data you originally provided to us to yourself or to another company. This only applies to data you provided directly, or that we observed about you through automated means.
- Object to the processing of your data – you can object to our processing of your data for direct marketing purposes, based on our stated legitimate interests (defined in the table above). In some cases, we may have compelling lawful grounds to process your data which override your rights and freedoms.
- Object to automated decision-making – you can also object to the processing of your personal data where profiling is being used to make assumptions about your behaviours or preferences; for example, to target marketing communications. You have the right not to be subject to automated decision-making and can require that any such decisions are reviewed by a human.
Making a complaint
We take the handling of your personal data very seriously. But, if you feel your data is being handled in a way that breaches data protection legislation, you can make a complaint.
Please contact our Data Protection Office at GDPRenquiries@aqa.org.uk.
We may charge a reasonable fee if your request is unfounded, repetitive or excessive. We can refuse to follow your request in these circumstances.
We’ll always try to respond to any legitimate request within one month. It may take us longer if your request is complex or you've made many requests. In this case, we'll let you know and keep you updated.
As a security measure, we may ask you to confirm your identity. This ensures that:
- personal data isn't disclosed to any person who doesn't have a right to receive it
- your right to access your data or to exercise any of your other rights.
We may also contact you to ask you for further information in relation to your request to speed up our response.
You also have the right to complain to the .
腦瞳肊 Education’s Information Commissioner’s Office registration number is Z6944888.
If you don't want to receive information from us, you can ‘opt-out’ at any time. Use the “Unsubscribe” link at the footer of our emails or by contacting us at GDPRenquiries@aqa.org.uk.
We’ll process all opt-out requests as soon as possible. But please note it may take a few days for any opt-out request to be processed.
Our website may include links to and from third party websites. These websites will have their own privacy policies. We don't accept any responsibility or liability for them. Please check these policies before you submit any personal data.
The legal basis for processing your personal data
The law requires us to inform you of the legal basis for collecting and processing your personal data, where we are the Data Controller, or Joint Data Controller. These include:
- Performance of contract – ie when we have a contract to either provide a product or service to you, or to receive something from you. We're also acting under the 'performance of contract' if we collect or process your data for the purposes of entering into a contract with us.
- Legitimate interests – ie processing personal data, which doesn't relate to the performance of a contract agreed with you. We'll check the fairness of this; and will only undertake the processing if it's reasonable to do so and will not cause undue risk to you.
- Legal obligation – we're legally bound to process certain data about you. In some cases, we're obliged to share personal data with third parties, such as Ofqual, JCQ, DfE and HMRC.
- Public interest – we're obliged to maintain a permanent record of your assessment data (eg examination history, subject, grade, and type of qualification) under the 'Conditions of Recognition' defined by Ofqual, underpinned by the Apprenticeships, Skills, Children and Learning Act (2009). This is both a legal obligation and necessary for the performance of a task carried out in the public interest. We may also share data with Ofqual, JCQ and the DfE under this lawful basis.
- Consent – we don't rely on consent as a legal basis for processing your personal data. Other than in relation to sending marketing communications via email or text message.
Where we'd like to be able to contact you about our products and services, we’ll seek your consent to keep and re-use your contact details for that purpose. You have the right to withdraw consent to marketing at any time by contacting us.
We have an established Data Protection Office that oversees 腦瞳肊’s activities to ensure that your personal data is handled ethically and in line with our legal obligations. If you have any questions about the way in which we collect, hold or process your data, or wish to exercise your rights, please contact us at GDPRenquiries@aqa.org.uk. Our Data Protection Officer is Graham Dwyer.