Action Tutoring privacy notice for schools

See previous privacy notice version here (in effect from 1st May 2025 – 30th April 2026)

This version of this notice is effective from 1st May 2026.

1. About Action Tutoring

Action Tutoring (we, us, our) is a registered education charity, supporting pupils from disadvantaged backgrounds to achieve a meaningful level of academic attainment, with a view to helping them progress to further education, employment or training. We provide high-quality volunteer tutors to work with pupils, increasing their subject knowledge, confidence and study skills.

In secondary schools, Action Tutoring particularly focuses on supporting pupils on the grade 3-4-5 borderline in English and maths. We aim to help them achieve a grade 4 and above in maths and English GCSEs. In primary schools, we aim to help pupils work towards expected standards in maths and reading.

Please separately see our Privacy Notice for our Website and School Marketing Activity for how we handle personal data relating to school marketing activity. Please also see our Privacy Notice for Pupils, Parents and Guardians for the additional data we gather as part of running our programmes.

2. Purpose of this privacy notice

The current version of this notice is effective from 1st May 2026.

This notice intends to make the following points clear to schools, pupils, parents and guardians about the information (data) we ask partner schools to share with us about pupils taking part in our programme and the information we collect independently:

• why we ask our partner schools to share information about our pupils with us and why we collect some additional information independently (section 3.)
• what information we ask partner schools to share with us and what information we collect independently (section 4.)
• where we store the information and who can access it (section 5.)
• how long we keep the information (section 6.)
• what information we share with other parties (section 7.)
• our legal basis for processing the information (section 8.)
• security of personal information (section 9.)
• transfers outside of the EEA (section 10.)
• how to control your information and rights (section 11.)
• how to contact us (section 12.)

We have also produced an Action Tutoring Parent/Guardian Letter for schools who may wish to distribute this to the parents/guardians of participating pupils, introducing what the Action Tutoring sessions involve, and directing them to this privacy notice. Although pupil participation in the Action Tutoring programme is not reliant on written opt-in consent from a parent or guardian (see section 8. Legal basis), this letter nevertheless provides parents an opportunity to inform their child’s school if they do not wish for them to take part in the Action Tutoring sessions, or to inform us if they do not wish for their child’s information to be used for evaluation purposes.

3. Data purpose (why we gather data)

Action Tutoring asks our partner schools to provide information about the pupils they put forward for participation in our tutoring programme, and we collect some additional information independently for the following reasons:

• to effectively coordinate the delivery of our programme both in-school and online;
• to meet safeguarding responsibilities;
• to enable the evaluation of our impact and improve future programme delivery;
• to demonstrate our programme reaches the pupils who need it as defined by our charity’s mission;
• to grow the delivery capability of our charitable activity.
  

4. Data collection (what data we gather)

Personal data on staff in schools which will be collected in a programme as described below:

The names and contact details (school name and address, contact email address, telephone number and job role/title) of Action Tutoring’s key contact and other potential contacts: Headteacher; Senior Leadership Contact, Safeguarding contact, Head of Subject, Business and/or Manager; and link teacher for individual programmes where relevant. Contact details include school name and address, contact email address, telephone number and job role/title.

Staff perceptions of the implementation and outcomes of the tutoring evaluation.

Information relating to contact points of a school with Action Tutoring and sentiment and tracking of future programme partnerships.

We set out separately the data we gather from schools on pupils and directly from our tutoring sessions in our Privacy Notice for Pupils, Parents and Guardians.

5. Data storage and access (where we store the information and who can access it)

We operate a central database, Salesforce, to help us secure school data. The database is password-protected, and access is limited to Action Tutoring staff, with ‘staff’ referring to Action Tutoring employees and not our volunteer tutors.

Information may additionally be stored in e-mail and on our business systems including Google Workspace.

6. Retention (how long we keep the information)

Action Tutoring seeks to ensure personal data is only retained for the period that it needs it for, or in accordance with laws, regulations and professional obligations that we are subject to. This means that:

• Teacher data relating to schools are retained up to ten years after a school stops being a delivery partner for Action Tutoring. This is to preserve the safeguarding record-keeping within Action Tutoring.

7. Data sharing (what information we share with other parties)

We share data with trusted suppliers, such as our IT and support contractors, who support us with our data systems. We will only share under a data sharing or data processing agreement. Where appropriate and a school is part of a MAT data may be shared with the central MAT.

8. Legal basis (our basis for processing the information)

To lawfully process the information outlined in this notice, we may rely on:

Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. 

Action Tutoring has undertaken legitimate interest assessments, which demonstrate that it is within its scope to deliver and manage its programmes efficiently.

9. Security of personal information

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

We have procedures to handle any potential data security breaches. Data subjects, third parties and any applicable regulators will be notified where we are legally required to do so. If you become aware of a potential data breach involving your personal data, please contact us immediately using the details provided at the end of this notice.

10. Transfers outside of the EEA

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the European Economic Area (EEA).

We may share personal information to third parties outside of the European Economic Area (EEA). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.

Where personal data is transferred outside of the EEA to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include Standard Contractual Clauses.

For more information about transfers and safeguarding measures, please contact us using the information in section 12.

11. How to control your information and your rights

Action Tutoring is committed to accommodating your rights under the General Data Protection Regulation, which include:

• Your right to be fully informed on how the information we ask you to share with us and the information we collect independently is processed by Action Tutoring. If you have any questions about the guidance provided in this policy notice, or would like further detail on specific sections, then please address your query to the contact details provided below.
  
• Your right to access the information we have asked you to share with us and the information we collected independently. If you require a copy of this information, please make this request using the contact details provided in this notice and the information will be provided to you in an electronic format as soon as possible, within one month at the latest. We will need to confirm your identity to provide this information.
  
• Your right to rectify the information we have asked you to share with us and the information we collected independently if it is inaccurate or incomplete. If you believe that any of the information is inaccurate or incomplete, please contact us as soon as possible using the contact details provided below. We will promptly correct any information found to be incorrect.
  
• Your right to erase the information we have asked you to share with us and the information we collected independently. You may request that this information be placed under restricted access, pseudonymised or deleted where there is no compelling reason for it to be kept. However, we may need to retain some information as stated in section 6. Retention – how long we keep the information.
  
• Your right to restrict or object to the further processing of the information we have asked you to share with us and the information we collected independently. Please use the contact details provided to inform us of any wish to restrict or object to the further processing of this information. Note that we may need to retain some key information in order to respect your restriction or objection in future.

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

When we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.

12. How to contact us

To contact us in relation to any of the information contained in this policy notice, to make a complaint, to pursue any rights under the General Data Protection Regulation and to contact our DPO, please email: hello@actiontutoring.org.uk

Or write to us at: Action Tutoring, Fivefields, 8-10 Grosvenor Gardens, Victoria, SW1W 0DH

Telephone: 0300 102 0094

If you are unhappy with the way that we have handled your Personal Information, you can make a complaint to the Information Commissioner’s Office (ICO) which is the UK authority responsible for data protection.