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.
The current version of this notice is effective from 18th February, 2021.
2. Purpose of this privacy notice
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 with us and why we collect some additional information independently
- what information we ask partner schools to share with us and what information we collect independently
- where we store the information and who can access it
- how long we keep the information
- what information we share with other parties
- our legal basis for processing the information
- how to contact us
Please note that if a school partners with Action Tutoring as part of the National Tutoring Programme, then additional documentation, including privacy notices produced by the NTP, will be provided to the school separately, as well as withdrawal forms and guidance for pupils and parents/ guardians regarding the additional collection and processing of data for the NTP beyond that covered in this privacy notice.
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 7. 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 ask our partner schools to share information with us and why we collect some additional information independently
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 enable us to successfully fundraise, to keep costs to schools low.
4. Data Collection – what information we ask partner schools to share with us and what information we collect independently
Before a pupil officially joins our programme, we ask our partner schools to provide us with the following information about all pupils selected to take part, via a password-protected spreadsheet or email encryption software: full name, school, school year, gender, date of birth, unique pupil number, subject ability, pupil premium status and other circumstances of disadvantage.
Optionally, the school may also choose to provide additional engagement-related guidance for our consideration. If partnering with Action Tutoring as part of the National Tutoring Programme, then the SEND status of participating pupils will also be requested at this stage.
During the programme, we will independently record: pupil attendance and engagement, pupil assessment results, pupil survey responses.
After a pupil has completed the programme, we may ask our partner schools to provide, via a password-protected spreadsheet or email encryption software: pupils’ final GCSE results in English Language and maths, or final SAT results in reading, writing and maths.
For pupils who are accessing the tutoring sessions online, video recordings of tutoring sessions are made. For those pupils accessing the tutoring session online from an at-home setting, rather than in school, we will ask the school to indicate if the pupil has access to the necessary IT at home to participate in the sessions, and provide the following information for a responsible adult such as a parent or guardian: full name, mobile number, email address, relation to pupil.
5. Data Storage and Access – where we store the information and who can access it
We operate a central database, Salesforce, to help us securely store pupil and parent/guardian information. The database is password-protected and access to the database is limited to Action Tutoring staff, with ‘staff’ referring to employees of Action Tutoring and not including our volunteer tutors.
For pupils who are accessing the tutoring sessions online, video recordings of tutoring sessions are stored on the online tutoring platform, Vedamo. Access to the platform is password-protected and only Action Tutoring staff can view session video recordings. Some video recordings may be temporarily transferred to an external hard drive by our Online Project Manager.
For pupils who complete assessments or surveys online, their names, results and responses may be stored on the webform platform, FormAssembly. The platform is password-protected and access is limited to specific Action Tutoring staff.
Information about pupils and their parents/guardian may also be recorded in other formats, such as in emails, word processing and spreadsheet applications. Information in these formats may be stored on Action Tutoring devices or in Google Workspace applications such as our Google Drive cloud storage. Access to these devices and cloud applications is password-protected and restricted to Action Tutoring staff.
6. Retention – how long we keep the information
Pupil and parent/guardian records on our central database, Salesforce, containing information provided by our partner schools, alongside additional information we have captured independently, are pseudonymised approximately two academic years after a pupil graduates from the Action Tutoring programme. This involves removal of all information from a record which could be used to identify an individual pupil or their parent/guardian. This process can only be reversed by specific members of the Action Tutoring team and only under reasonable circumstances, such as to facilitate a safeguarding enquiry.
Video recordings of online tutoring sessions completed on Vedamo are kept for approximately one full academic term after the term in which the session took place.
The names, results and responses of pupils who completed assessments or surveys using the webform platform, FormAssembly, will be archived approximately two academic years after a pupil graduates from the Action Tutoring programme.
Our policy for any pupil and parent/guardian information temporarily stored in other formats, such as word processing or spreadsheet applications, is to delete this information as soon as the purpose for processing the information in the alternative format is complete.
7. Data sharing – what information we share with other parties
The following information about pupils may be shared with specific tutors before and during the programme to help them tailor their tutoring sessions: full name, school, school year, gender, subject ability, SEND status, assessment results, attendance and engagement notes, and any other information the pupil’s school has voluntarily provided to us which is deemed relevant for the tutor to be made aware of.
After a pupil has completed the programme, the following information may be shared with tutors, but only in relation to those pupils they directly supported: pupils’ final GCSE results in English Language and maths, or final SAT results in reading, writing and maths.
Unless consent if sought, or an agreement of confidentiality is in place, information about pupils or their parents/guardians will not be intentionally shared with other third parties.
Anonymous and aggregated data relating to pupils may be published on the Action Tutoring website and used in published materials, such as Action Tutoring’s annual report for funders.
8. Legal basis – our legal basis for processing the information
To lawfully process the information outlined in this notice, we may rely on:
Contract: where information we request or collect independently about pupils or their parents/guardians is necessary for us to effectively coordinate the delivery of our programme in partnership and agreement with schools.
Examples: pupil full name, subject ability
Legitimate interests: where information we request or collect independently about pupils or their parents/guardians is used to enable the evaluation of our impact, improve the future delivery of our programme, demonstrate that our programme reaches the pupils who need it as defined by our charity’s mission, and to enable us to successfully fundraise.
Examples: pupil premium status, unique pupil number, exam results, survey responses
Legal obligation: where we may need to use or share information we hold about pupils or their parents/guardians in order to comply with a legal obligation, such as to facilitate the investigation of a safeguarding concern with a local authority.
Consent: in order to facilitate any additional processing of information beyond which is outlined in this privacy notice, we will seek consent from the relevant individuals in order to do so.
Please note that if a school partners with Action Tutoring as part of the National Tutoring Programme, then additional documentation will be provided to the school separately, outlining the legal basis identified by the National Tutoring Programme and evaluators for collecting and processing certain data, including the SEND status for participating pupils.
9. How to contact us
To contact us in relation to any of the information contained in this policy notice, to make a complaint, or to pursue any rights under the General Data Protection Regulation, please email: [email protected]
Or write to us at: Action Tutoring, The Dock, Tobacco Quay, Wapping Lane, London E1W 2SF
Telephone: 0203 872 5894
You can download this full policy here: Action Tutoring Privacy Notice for Schools, Pupils, Parents and Guardians
