Privacy Policy for Schools

Sparx is committed to protecting and respecting your privacy and ensuring best practice compliance with data protection laws. Our Privacy Policy for Schools gives you information about how Sparx collects, uses and protects personal data to deliver the educational services referred to below as the “Sparx System”. It is important that you read our Privacy Policy for Schools.

Any changes we may make to our Privacy Policy for Schools in the future will be posted on this page, so you will always know what personal data we collect about you in connection with the Sparx System, the purposes we might use it for and to whom we might disclose it.

This version of our Privacy Policy for Schools was published in May 2018 in line with the General Data Protection Regulation (GDPR) and applies to the collection and use of personal data by Sparx in connection with the Sparx System from 25 May 2018. Earlier versions of our Privacy Policy for Schools can be obtained by contacting Sparx’s Data Protection Officer (whose contact details are set out in the ‘Contacting us’ section of our Privacy Policy for Schools).

Our Privacy Policy for Schools relates to personal data processed in connection with the Sparx System. If you would like more information about how Sparx collects, uses and protects any personal data that you provide directly to us, including any personal data provided through this website, please refer to the Sparx website privacy policy which can be found here.

We would like you to be able to easily find the information you need. Please click on the following links if you would like more information about the use of personal data by the Sparx System.

Why does Sparx process personal data?

Information about Student Data

Information about Parent Data

Information about Teacher Data

Other uses of Student Data, Parent Data and Teacher Data

Data security and where data is stored

Uses of non-personal data

Rights of data subjects

Cookies

Contacting us

Schools using the Sparx System are also required to provide information to students, parents/carers and teachers about Sparx’s processing activities. Please make sure you also refer to this information, which will be made available by schools.

Why does Sparx use personal data?

Schools strive to provide their students with the best possible education. Schools can choose to use the Sparx System to assist them with the delivery of engaging and creative maths teaching that is personalised to each of their students. In order to produce individually tailored questions and learning support, Sparx needs to use personal data relating to students, their parents/carers and teachers (collectively referred to in our Privacy Policy for Schools as “Data Subjects”).

Sparx has categorised the types of personal data it uses into three groups:

(i) School Data: personal data relating to Data Subjects, which is collected by the school and securely shared with Sparx. The school is the data controller of the School Data, and Sparx is the data processor acting on behalf of the school.

(ii) Usage Data: personal data generated through use of the Sparx System.

(iii) Research Data: personal data gathered by Sparx for the purposes of research.

With regards to the collection and use of the Usage Data and Research Data, the school and Sparx operate as joint data controllers. Sparx has conducted an analysis of the collection and use of the Usage Data and Research Data, and has concluded that the school and Sparx have legitimate interests in using such data and are therefore permitted to do so under GDPR. Sparx has conducted a legitimate interests assessment to ensure that the legitimate interests pursued by the school and Sparx in collecting and using the Usage Data and Research Data are not overridden by the interests or fundamental rights and freedoms of the Data Subjects (with particular consideration given to the interests or fundamental rights and freedoms of the Data Subjects who are children).

Sparx operates on the principle of data minimisation and collects the minimum amount of data in order to deliver the Sparx System and conduct its research.

Information about Student Data

1. 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, tutor group and MIS ID which is linked with other identifying Sparx codes. Teachers also share Student Data, including information on attendance and work completion.
  • Usage Data: Sparx gathers data about student activity when they use the Sparx System in order to optimise student learning. This includes data on student progress and performance in quizzes and questions, the use of features in the System, when and the time spent by the student using the Sparx System. Sparx also uses data analytics and collects information about the devices used to access the Sparx System.
  • Research Data: To improve the Sparx System, Sparx evaluates its performance by observing classes and running feedback sessions and surveys with students. Sparx runs a research programme and collects data from student assessments.

2. How is Student Data used?

Sparx combines School Data, Usage Data and Research Data relating to students and uses that Student Data to:

  • Set up and administer student accounts on the Sparx System;
  • Build a profile of each student’s performance and progress;
  • Provide bespoke maths education 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 recording their actions;
  • Update parents on homework progress and completion;
  • 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 the Sparx System, educational performance and outcomes;
  • Evaluate and improve the Sparx System; and
  • Be de-identified through aggregation and pseudonymisation.

3. How long is Student Data kept for?

Sparx does not keep personal data for longer than is necessary. Student Data is retained within the Sparx System while the student is an active user of it. When a student stops using the Sparx System, their data will be retained to fulfil reporting and other requirements. When the Student Data is no longer required, it will be stripped of the most identifying data, so as to block re-identification (a process called pseudonymisation). This pseudonymised data may be retained indefinitely by Sparx as it is not personal data.

4. Is Student Data shared?

Sparx discloses performance information and other Student Data to:

  • Teachers at the student’s school;
  • Other staff at the student’s school;
  • Parents / guardians of individual student’s (parents will only receive Student Data pertaining to their own child);
  • Sparx staff;
  • IT hosting providers (described in ‘Data security and where data is stored’); and
  • Third parties, if required by law.

Information about Parent Data

1. What Parent Data is collected by Sparx?

  • School Data: Sparx collects parent name and email addresses from the school in order to update parents on their child’s progress.
  • Usage Data: To gauge parent usage of the Sparx System, Sparx collects data generated by parents from interactions with emails sent by Sparx, including when emails were opened, links clicked and other activity in the Sparx System. Sparx uses data analytics and collects information about the devices used to access the Sparx System.
  • Research Data: From time to time in order to improve the Sparx System, Sparx seeks feedback from parents and collects data relating to use of, and parental evaluation of the Sparx System.

2. How is Parent Data used?

Sparx combines Parent Data, Usage Data and Research Data, and uses Parent Data to:

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

3. How long is Parent Data kept for?

Sparx does not keep personal data for longer than is necessary. Parent Data is retained within the Sparx System while the parent’s child is an active user of it. When a student stops using the Sparx System, the associated Parent Data will be retained to fulfil reporting and other requirements. When the Parent Data is no longer required it will be stripped of the most identifying data, so as to block re-identification (a process called pseudonymisation). This pseudonymised data may be retained indefinitely by Sparx as it is not personal data.

4. Is Parent Data shared?

Sparx discloses Parent Data to:

  • Teachers at the student’s school;
  • Other staff at the student’s school;
  • Sparx staff;
  • IT hosting providers (described in ‘Data security and where data is stored’);and
  • Third parties if required by law.

Information about Teacher Data

1. What Teacher Data is collected by Sparx?

  • School Data: In order to set up and administer user accounts, Sparx processes Teacher Data including name, title, job role, email address and teaching classes.
  • Usage Data: To gauge usage of the Sparx System, Sparx collects data about teachers when they use the Sparx System. This includes activity on the Sparx System, when and the time spent using the Sparx System 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 activity in the Sparx System. Sparx uses data analytics and collects information about the devices used to access the Sparx System.
  • Research Data: From time to time in order to improve the Sparx System, Sparx seeks feedback from teachers and collects data relating to use of, and teacher evaluation of the Sparx System.

2. How is Teacher Data used?

Sparx combines Teacher Data, Usage Data and Research Data, and uses Teacher Data to:

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

3. How long is Teacher Data kept for?

Sparx does not keep personal data for longer than is necessary. Teacher Data is retained within the Sparx System until the teacher account is deleted. After this point, Teacher Data will be retained to fulfil reporting and other requirements. When the Teacher Data is no longer required it will be stripped of the most identifying data, so as to block re-identification (a process called pseudonymisation). This pseudonymised data may be retained indefinitely by Sparx as it is not personal data.

4. Is Teacher Data shared?

Sparx discloses teacher information to:

  • Other teachers at the teacher’s school;
  • Other staff at the teacher’s school and / or managing organisation;
  • Sparx staff;
  • IT hosting providers (described in ‘Data security and where data is stored’); and
  • Third parties if required by law.

Other uses of Student Data, Parent Data and Teacher Data

Sparx may also disclose data in the event that a third party acquires Sparx or its assets. Sparx will not share personal data with other third parties without the permission  of the individuals concerned. Personal information 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 they agree not to attempt to identify individuals from that data or it is in an aggregated format.

Data security and where data is stored

Sparx is committed to protecting and respecting the privacy of Data Subjects. 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.

The data Sparx collects will be stored and processed in the UK at our offices and in our secure data centre(s). In addition Sparx uses services provided by trusted third party processors, who are based outside the UK and outside the European Economic Area (EEA). Where these processors are used, personal data will be transferred outside the EEA as described below.

Sparx uses cloud services provided by Bytemark whose servers are based in the UK. Sparx also uses cloud services provided by Google whose servers are located in Europe and also worldwide.

In order to ensure delivery of our personalised homework email to parents and teachers it is necessary for us to transfer Student Data to a US email delivery provider, PostMark.  Sparx also uses Dropbox, whose storage servers are located in the US, to securely transfer and temporarily store personal data.

Where Sparx receives sales enquiries, with the individual’s permission, data will be retained for future use. To this end, personal data will be stored by Sparx and with third parties providing customer management software.

Whenever Sparx uses a third party provider, and personal data is transferred out of the EEA, we ensure that:

  • There are no reasonable alternatives based in the EEA.
  • Personal data is only transferred to countries that have been deemed to provide an adequate level of protection by the European Commission.
  • Where we use providers based in the US, we transfer data to them if they are part of the Privacy Shield which provides robust protection for personal data.
  • We have undertaken a detailed adequacy assessment of this provider and have concluded that they have good privacy safeguards and security features in place to prevent unauthorised access of data we send them.

Uses of non-personal data

Sparx de-identifies personal data so that it can be used for purposes other than the delivery of the Sparx System. The processes of pseudonymisation and aggregation mean that individuals cannot be identified from the data. Sparx uses non-personal data for researching the results achieved through use of the Sparx System. Non-personal data is also used for marketing the Sparx System to prospective users.

Rights of data subjects

Individuals whose personal data is being processed have rights relating to that data in certain circumstances. These rights do not apply in all instances. Please contact the school if you have any requests or questions relating to data subject rights. Sparx will assist schools with upholding data subject rights in all circumstances where it is possible to do so.

Data subject rights:

  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.

You 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/

Cookies

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

Contacting us

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