Action Tutoring Privacy Notice for Tutors

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.

2. Purpose of this privacy notice

This notice intends to make the following points clear for our volunteer tutors about the information (data) we ask you to share with us and the information we collect independently:

why we ask you to share information with us and why we collect some additional information independently (section 3.)
what information we ask you to share with us and what information we collect independently (section 4.)
where we store the information and who can access it (section 5.)
what information we share with other parties (section 6.)
how long we keep the information (section 7.)
our legal basis for processing the information (section 8.)
security of personal information (section 9.)
transfers outside the EEA (section 10.)
how we process and use DBS checks (section 11.)
how we communicate with you using this information (section 12.)
how to control your information and your rights (section 13.)
how to contact us (section 14.)

This notice details more about the NTP and answers key questions such as why the NTP is collecting information about participating tutors, what information they are collecting, who it will be shared with, how long it will be kept, and how you can withdraw your data from their evaluation activities if you wish to. Action Tutoring will also provide an additional opportunity to withdraw, if you wish to, when you first sign up for a tutoring programme with us.

The current version of this notice is effective from 15th June, 2021.

3. Data Purpose – why we ask you to share information with us and why we collect some additional information independently

Action Tutoring asks our volunteer tutors to provide information about themselves at the point of application, 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 tailor our volunteering opportunities to your preferences and availability;
to advertise location-specific opportunities and logistical information to you;
to manage optional additional Action Tutoring-related communications to you;
to record your engagement on our tutoring programmes;
to ensure we are engaging and recruiting a diverse range of volunteers;
to enable the evaluation of our impact, improve future programme delivery and undertake quality assurance activities;

4. Data Collection – what information we ask you to share with us and what information we collect independently

At the point of application to be a volunteer tutor with us, we ask you to provide the following information: full name, occupation, postal address, gender, date of birth, contact email, mobile number, overseas address history, a-level and degree qualifications details, your tutoring preferences, relevant experience, availability, how you heard about Action Tutoring, your communication preferences, and an indication of any convictions, cautions, reprimands or final warnings that are not “protected” as defined by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended in 2013).

We also ask our volunteer tutors to optionally inform us of their ethnicity, which is deemed as Special Category Data under GDPR. Where provided, we intend to use this information to form a better understanding of the diversity in our volunteer community, of which ethnic diversity is one aspect. We can then adjust our marketing approaches as we seek to build greater diversity across our organisation. Please note that this information is in no way referenced when we review volunteer tutor applications

Please note some other information is also optional to provide, including your gender and date of birth.

If you are successful in applying to volunteer with us, we may request or collect the following additional information as you progress: ID documents to complete a DBS check, your DBS certificate number, DBS issue date, copy of DBS certificate, your volunteering history including pupils you have worked with, your attendance and engagement, surveys responses, case study content, and video/audio recordings of any sessions you deliver online.

Please see section 11. DBS checks for more details about how we process and use DBS checks.

Please note that completing surveys or providing case studies is optional.

5. Data Storage and Access – where we store the information and who can access it

Our application form for volunteer tutors is hosted on FormAssembly. The platform is password-protected and access is limited to specific Action Tutoring staff, where ‘staff’ refers to employees of Action Tutoring and not including other volunteer tutors.

We operate a central database, Salesforce, to help us securely store information. The database is password-protected and access to the database is limited to Action Tutoring staff.

For tutors who are delivering tutoring sessions online, video/audio recordings of tutoring sessions are stored on Vedamo, an online tutoring platform. Access to the platform is password-protected and only Action Tutoring staff can view session video/audio recordings. Some recordings may be temporarily transferred to an external hard drive by our Online Project Manager for storage management purposes.

Information relevant to you 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. Data sharing – what information we share or you may be asked to share with other parties

We share, or you may be asked to share information with other parties as part of your volunteering. This may include companies within our group where necessary for administrative purposes and to provide services to you, third parties that support us to provide products and services e.g. IT support, cloud-based software services, providers of telecommunications services, marketing services providers, payment service providers, recruitment service provides, professional advisors e.g. lawyers, auditors, and web analytics and search engine providers to ensure the continued improvement and optimisation of our website.

Key third parties include:

Vedamo – if delivering tutoring sessions online, your full name and email address will need to be used to set up an account on this online platform. Video/audio recordings of sessions are not shared outside the internal Action Tutoring staff team.

Looop – if delivering tutoring sessions online, or being invited to on-going learning and development opportunities, your full name and email address will need to be used to set up an account on this online platform. If you leave a comment of review in Looop, your full name may be viewable by other users.

uCheck – it is a requirement to apply for a DBS check to volunteer with Action Tutoring, unless you already have an eligible certificate. In order to complete an application for a DBS check, you will have to provide the following information to uCheck: full name (current and any previous names), address (current and previous from last five years), date of birth, gender, nationality, NI number, email address, any conviction history and a selection of identity and proof of address documents such as passport, driving licence, bank statement, birth certificate. See section 11. DBS checks.

Zoom – if attending Action Tutoring training sessions online, your full name and email address may need to be used to set up an account on this platform. You may also choose to log in via an existing Google, Facebook or Apple account.

TextLocal – in order to send you text messages, such as reminders about your training or tutoring sessions, your full name and mobile number may be processed on this platform. Any replies you make to these messages may also be stored on the platform for our reference.

MailChimp – in order to send you email communications, such as newsletters or event invites, your full name, email address, region, communications preferences and tutoring preferences may be processed on this platform.

We may also share your full name and DBS details, including your DBS certificate number, issue date and a copy of your DBS certificate with our partner schools where you volunteer to support pupils from that school.

If your DBS certificate has a caution or conviction, we will request further details from you in order to complete a risk assessment, which we will then ask you to approve and consent for us to share this information and a copy of your certificate with our partner schools – see section 11. DBS checks.

For details about information shared with the National Tutoring Programme as part of their evaluation activities, please see the link provided in section 2. Purpose of this privacy notice.

Unless consent is sought, or an agreement of confidentiality is in place, additional information will not be intentionally shared with other third parties, unless we are legally obligated to do so.

Anonymous and aggregated data may be published on the Action Tutoring website and used in published materials, such as Action Tutoring’s annual report for funders.

7. Retention – how long we keep the information

FormAssembly – a copy of your original application to volunteer with Action Tutoring may be stored by us on our FormAssembly account for a period up to eight years.

Salesforce – records stored on our central database containing information provided at the point of application, alongside additional information we may have captured independently, are placed under limited access at any point where you indicate you are no longer interested in volunteering with us, or after approximately two academic years of inactivity from you.

Vedamo – Your account on Vedamo will remain active while you are signed up with us as an active tutor. If you are not actively tutoring or expected to be tutoring in the near future, we will suspend your account. Video/audio recordings of online tutoring sessions are kept for up to one full academic term after a programme of tutoring has finished. Further information about how long Vedamo retains records can be found in their privacy policy linked in the previous section.

MailChimp – we annually archive mailing lists which are no longer in use. Further information about how long MailChimp retains records can be found in their privacy policy linked in the previous section.

Looop – we annually review and archive users where appropriate. Further information about how long Looop retains records can be found in their privacy policy linked in the previous section.

uCheck – Incomplete DBS applications are deleted by uCheck automatically after three months, while documents uploaded in support of ID/address history checks are deleted automatically by uCheck 12 months from the result date of the check.

For completed DBS applications, Action Tutoring is able to view the information an applicant provided as part of the application on uCheck for up to two years, however we can no longer view the police records or barred list information on DBS certificates six months after an application was complete.

You can email uCheck for a complete copy of their Data Retention Policy: [email protected]

TextLocal – we annually review and remove any ‘contact groups’ no longer in use on our TextLocal accounts which would include your full name and mobile number. Further information about how long TextLocal retains records can be found in their privacy policy linked in the previous section.

Our best practice for any 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.

However, please note that some key information may be retained in some of these platforms over on a longer-term basis in order to:

meet our responsibilities in relation to child protection and safeguarding;
maintain a record of unsuccessful applications;
maintain a record of individual requests to restrict further use or ‘processing’ of their personal information, or requests for Action Tutoring to cease contacting them, in order to respect these requests in future;
to ensure we don’t accidentally duplicate information;
to provide references for volunteers after they have volunteered with us.

8. Legal basis – our legal basis for processing the information

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

Legitimate interests: where information we request or collect independently is used to effectively coordinate the delivery of our programme both in-school and online, to tailor our volunteering opportunities to your preferences and availability, to advertise location-specific opportunities and logistical information to you, to manage optional additional Action Tutoring-related communications to you, to record your engagement on our tutoring programmes, to ensure we are engaging and recruiting a diverse range of volunteers, and to enable the evaluation of our impact and improve future programme delivery
Examples: full name, occupation, contact email, tutoring preferences

Legal obligation: where we may need to use or share information in order to comply with a legal obligation, such as to meet our safeguarding responsibilities by facilitating the investigation of a safeguarding concern with a local authority.
Examples: DBS certificate number, DBS issue date, copy of DBS certificate, volunteering history

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.

We also ask our volunteer tutors to optionally inform us of their ethnicity, which is deemed as Special Category Data under GDPR. This is collected under an Article 6 Legitimate interests basis, and a ‘Reasons of substantial public interest’ basis under Article 9, with a public interest condition of ‘Equality of opportunity or treatment’ under DPA 2018.

Please note that a majority of schools which Action Tutoring works with are partnering with us as part of the National Tutoring Programme (NTP). We therefore recommend reviewing the NTP Privacy Notice for tutors separately which outlines the legal basis identified by the National Tutoring Programme and evaluators for collecting and processing some of your information.

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 policies and 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.

10. Transfers outside 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 14.

11. DBS checks – how we process and use DBS checks

To meet our responsibilities in relation to safeguarding, it is necessary for all our volunteer tutors to complete a full enhanced DBS check, of which Action Tutoring will cover the cost (if they are based in England, Scotland or Wales, but we don’t cover the cost for NI tutors).

You will need to complete an initial online DBS application form, providing the following information to uCheck: full name (current and any previous names), address (current and previous from last five years), date of birth, gender, nationality, NI number, email address, any conviction history and a selection of identity and proof of address documents such as passport, driving licence, bank statement, birth certificate.

You will then need to present or share your identification and proof of address documents, such as a passport, driving licence or bank statement, to a member of the Action Tutoring team for them to cross-check and complete your DBS application. However, it is not standard practice for us to screen-shot or record the point at which you present an ID document on screen.

If your DBS certificate is clear, we will share your DBS details, including your DBS certificate number, issue date and a copy of your DBS certificate with partner schools where you are signed up to tutor pupils from those schools.

Please note that once you have given consent for us to share details of a DBS certificate to a partner school, we cannot guarantee a school’s policy to securely store the information, or only retain the details for a limited time.

12. Communication – how we communicate with you using this information

Action Tutoring may contact you via email, phone, text or post. to:

Advertise volunteer opportunities.
Communicate logistical or safeguarding information to you.
Invite you to complete compulsory and optional training sessions during your volunteer activities.

With your explicit consent, Action Tutoring may periodically contact you via email or text with additional information, to enhance your volunteering experience. You are able to specify which topics you would like to receive communications about, including:

Charity news and campaigns. Termly newsletters with news and updates on the charity and its work, as well as information about other ways to support us, including charity campaigns and fundraising activities.

Additional tutor learning and development. Occasional emails with: News and research about education, inequality and volunteering; tips, resources and articles to help you improve as a tutor; information about events, surveys and focus groups, to aid our work and enrich your volunteering experience.

Job and training opportunities. Occasional email alerts about job opportunities at Action Tutoring and our charity partners, including Teach First and Now Teach training opportunities or PGCE-related events (where interest is indicated in your application).

You are presented with a clear choice to opt into receiving any or all of these additional communications in your application form. If you decide at a later date that you no longer wish to receive them, our emails include clear and easy opportunities to opt-out of these mailing lists, or you can also contact us at any time via email: [email protected]

You can also email us at this address if you would like no further contact from Action Tutoring entirely, including core information about volunteering. Please allow five working days for us to process these requests.

After two years of inactivity, we will cease any further communication with you.

13. 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 7. 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).

Where 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.

14. How to contact us

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

To contact us in relation to any of the information contained in this policy notice, to make a complaint, or to pursue any of your 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

To download this policy: Action Tutoring Privacy Notice for Tutors 2021