SPARX PRIVACY NOTICE FOR SCHOOLS USING SPARX

Information about Sparx

Information about this Privacy Notice

Why does Sparx use personal data?

How does Sparx get personal data?

What personal data does Sparx collect?

Information about personal data relating to students (Student Data)

Information about personal data relating to parents (Parent Data)

Information about personal data relating to teachers (Teacher Data)

What other personal data does Sparx collect?

Where is your personal data stored?

How does Sparx share your data?

How long is personal data stored for and what happens to it?

How non-personal data is used

Security of personal data at Sparx

Cookies

Your rights

How to contact us

 

Information about Sparx

Sparx Limited (company number 07907042) (Sparx) is the entity responsible for the collection and use of personal data by Sparx. Sparx is registered as a data controller at the Information Commissioner’s Office (ICO) with registration number ZA006725.

Information about this Privacy Notice

This Privacy Notice is for

  • Students
  • Parents
  • Teachers
  • other School and Multi Academy Trust (MAT) staff

who use Sparx products and services. This notice gives you information about how Sparx collects, uses and protects personal data to deliver our educational technology. It is important that you read this Privacy Notice.

Schools using Sparx are required to provide information to students, parents, teachers and other school staff about Sparx’s data processing. Please make sure you refer to this information, which will be made available by your school.

This version of our Privacy Notice for Schools was published in March 2019 and applies to the collection and use of personal data by Sparx from 1 March 2019. It aligns with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

If you would like more information about how Sparx uses personal data that you provide directly to us, including through our websites or our social media channels, please refer to our website privacy information which can be found here.

 

Why does Sparx use personal data?

Sparx assists teachers in delivering engaging and creative maths teaching. In order to produce individually tailored questions and other learning support, Sparx needs to use personal data relating to students, their parents and teachers.

 

How does Sparx get personal data?

Schools share information about their students, parents and carers, and teachers with Sparx. Sparx calls this School Data. This data is provided directly from the school management information system (MIS) to ensure the data is accurate. Sparx also creates data and user profiles when Sparx is being used. Sparx calls this Usage Data. Sparx runs educational research projects with participating schools and the data generated by these projects is called Research Data.

 

What personal data does Sparx collect?

Sparx processes the personal data of students, parents and teachers on behalf of schools. In usual circumstances, schools using Sparx products and services act as data controller and Sparx is the data processor, providing a data processing service to the school. In limited circumstances, Sparx acts as joint data controller with a school. Where this applies, Sparx and the school put in place an agreement to allocate data controller responsibilities between them.

 

Information about personal data relating to students (Student Data)

What Student Data is collected by Sparx?

  • School Data: The school securely provides Sparx with Student Data to enable Sparx to set-up and administer student accounts. This includes information such as name, gender, date of birth, class, KS2 results, unique pupil number, if the student is in receipt of pupil premium, their free school meal status, if English is an additional language and MIS ID which is linked with other identifying Sparx codes. Teachers also input Student Data into their students’ user profiles within Sparx, including information on attendance, interventions and work completion.
  • Usage Data: Sparx gathers data about student activity when they use Sparx in order to optimise student learning. This includes data on student progress and performance in quizzes and questions, the use of features, when and the time spent by the student using Sparx. Sparx also uses data analytics and collects information about how and when Sparx products and services are accessed.

 

How is Student Data used?

Sparx combines Student Data in order to:

  • Set up and administer student accounts;
  • Build a profile of each student’s performance and progress;
  • Provide maths education products and services including tailored questions and support;
  • Populate algorithms which recommend individualised homework for teachers to set;
  • Provide an overview for teachers to allow them to monitor student progress and record their actions;
  • Update parents on homework progress and completion;
  • Connect Student Data and Parent Data;
  • Suggest maths set changes for students for their teachers to review and consider;
  • Provide reports to teachers on student progress;
  • Conduct research into usage of Sparx products and services, educational performance and outcomes;
  • Evaluate and improve Sparx products and services; and
  • Be de-identified through aggregation and pseudonymisation.

 

Information about personal data relating to parents (Parent Data)

What Parent Data is collected by Sparx?

  • School Data: Sparx collects parent names and email addresses from the school in order to update parents on their child’s progress.
  • Usage Data: To gauge parent usage of Sparx products and services, Sparx collects data generated by parents from interactions with emails sent by Sparx, including when emails were opened, links clicked and other related activity. Sparx also uses data analytics and collects information about how and when Sparx products and services are accessed.

 

How is Parent Data used?

Sparx combines Parent Data in order to:

  • Contact parents via email about their child’s homework progress and identify areas requiring support;
  • Connect Student Data and Parent Data;
  • Conduct research into usage of Sparx products and services, educational performance and outcomes;
  • Respond to help requests and other enquiries;
  • Evaluate and improve the Sparx products and services; and
  • Be de-identified through aggregation and pseudonymisation.

 

Information about personal data relating to teachers (Teacher Data)

What Teacher Data is collected by Sparx?

  • School Data: In order to set up and administer user accounts, Sparx processes information relating to teachers including name, title, job role, email address and teaching classes.
  • Usage Data: To gauge usage of Sparx products and services, Sparx collects data generated by teachers’ activity when using Sparx, including when and the time spent using Sparx and actions and interventions taken by the teacher. Sparx collects data generated by teachers from interactions with emails sent by Sparx, including when emails were opened, links clicked and other Sparx activity. Sparx also uses data analytics and collects information about how and when Sparx products and services are accessed.

 

How is Teacher Data used?

Sparx combines Teacher Data in order to:

  • Set up and administer teacher accounts;
  • Provide teachers with access to Student Data;
  • Provide teachers with email updates;
  • Quantify usage of Sparx products and services,
  • Respond to help requests and other enquiries;
  • Conduct research into usage of the Sparx products and services, educational performance and outcomes;
  • Evaluate and improve Sparx products and services; and
  • Be de-identified through aggregation and pseudonymisation.

 

What other personal data does Sparx collect?

Sparx researches the effectiveness of its products and services in a range of ways:

  • Research Data relating to students:
    • To improve Sparx products, Sparx conducts product research and evaluates its performance in selected schools by analysing usage data, observing classes and running feedback sessions and surveys with students.
    • To help Sparx understand how students learn better, Sparx runs an academic research programme and collects data as agreed with participating schools about student learning.
  • Research Data relating to parents: From time to time, in order to improve the Sparx services, Sparx seeks feedback from parents and collects data relating to use of, and parental evaluation of Sparx.
  • Research Data relating to teachers: From time to time, in order to improve the Sparx services, Sparx seeks feedback from teachers and collects data relating to use of, and teacher evaluation of the Sparx.

 

Sparx stores the contact details, emails and other communications from school and MAT staff in order to onboard and provide ongoing support to school staff.

Where staff have not chosen to opt out, Sparx will also use contact details to:

  • Provide newsletters and email updates;
  • Offer new services and products; and
  • Coordinate training and events as part of the Sparx Community.

 

Where is your personal data stored?

The personal data that Sparx collects will be stored and used in the EEA, primarily at our offices and in our secure data centres in the UK. We will only transfer your data outside the European Economic Area (EEA) where it is necessary for us to do so because there are no reasonable and commercially appropriate alternatives based in the EEA. Whenever we transfer your personal data out of the EEA, we ensure protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

  • We will only transfer your personal data to service providers in countries that have been deemed to provide an adequate level of protection by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use service providers based in the US, we may transfer personal data to them if they are certified under the Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.
  • We have undertaken a detailed adequacy assessment of the service provider and have concluded that it has good privacy safeguards and security features in place to prevent unauthorised access of data we send it.

A list of the third parties with whom we share personal data can be found here. This list will be updated regularly.

 

How does Sparx share your data?

Sparx discloses Student Data to:

  • Teachers at the student’s school;
  • Other staff at the student’s school and / or MAT (or other managing organisation i.e. alliances); and
  • Parents / guardians of individual student’s (parents will only receive Student Data about their own child).

Sparx discloses Parent Data to:

  • Teachers at the student’s school; and
  • Other staff at the student’s school and / or managing organisation.

Sparx discloses Teacher Data to:

  • Other teachers at the teacher’s school; and
  • Other staff at the teacher’s school and / or MAT (or other managing organisation i.e. alliances).

The personal data of students, parents and teachers will also be disclosed to:

  • Sparx staff;
  • IT hosting providers (details can be found here; and
  • Third parties, if required by law.

Sparx may also disclose personal data in the event that a third party acquires Sparx or its assets, or Sparx enters into any joint venture arrangements. Personal data will never be sold, or used to market or sell non-Sparx products or services. Sparx may share non-personal data with third parties provided that data is in an aggregated or wholly anonymised form, and that the third party agrees not to attempt to identify individuals from that data.

 

How long is personal data stored for and what happens to it?

Sparx does not keep personal data for longer than is necessary. Personal data is retained by Sparx whilst the user (student, parent or teacher) is active. When a user stops using Sparx, their personal data will be retained temporarily to fulfil reporting and other requirements. When the personal data is no longer required for these purposes, it will either be deleted or stripped of the most identifying data, so as to block re-identification (a process called pseudonymisation). As such,  because re-identification is not possible, the data may be retained indefinitely by Sparx as it is no longer personal data.

 

How non-personal data is used

Sparx uses pseudonymised, non-personal data for researching the results achieved through use of Sparx products and services. With permission, data aggregated at school level may be shared between other schools, MATs and alliances. Non-personal data is also used for marketing Sparx to prospective users.

 

Security of personal data at Sparx

Sparx is committed to protecting and respecting privacy. Sparx has appointed a Data Protection Officer who advises on, and oversees matters relating to privacy and data security. Appropriate security measures have been put in place to prevent personal data from being lost, used or accessed in an unauthorised way. Sparx conducts regular penetration testing and has obtained Cyber Essentials Plus certification. Sparx limits access to personal data to only those employees, service providers and other third parties who have a legitimate need for access.

 

Cookies

In order to provide Sparx services via a web browser, Sparx will place cookies on users’ devices. Cookies are used to collect standard internet log and user behaviour information. This information is used to arrange the content of Sparx websites, ensure security, track use of Sparx services and to compile statistical reports. These cookies are not used to target users of Sparx services with online advertising. For further information visit www.aboutcookies.org.

 

Your rights

Your rights in relation to your personal data are:

  1. The right to be informed of processing.
  2. The right to access personal data by making a subject access request.
  3. The right to rectification where personal data is inaccurate or incomplete.
  4. The right to erasure, sometimes called ‘the right to be forgotten’.
  5. The right to the restrict processing.
  6. The right to data portability.
  7. The right to object to processing.
  8. The right not to be subject to a decision based solely on automatic processing.

These rights do not apply in all instances. Please contact the school if you have any requests or questions relating to your rights. Sparx will assist schools with upholding data subject rights in circumstances where it is legally required or it is possible to do so.

You also have the right to make a complaint at any time to the ICO regarding the collection and use of personal data by Sparx. However, we would appreciate being given the chance to help you with your concerns before you approach the ICO, so please contact us using the details below in the first instance. For more information about the ICO please visit https://ico.org.uk/for-the-public/

 

How to contact us

Questions, comments and requests regarding personal information that we hold, or regarding this Privacy Notice, are welcomed and should be addressed to privacy@sparx.co.uk. Alternatively, please contact The Data Protection Officer, Sparx Limited, Oxygen House, Grenadier Road, Exeter, Devon EX1 3LH.