Privacy Notice for Pupils and Clients

This privacy notice describes how we collect and use personal information about pupils, in accordance with the UK General Data Protection Regulation (UK GDPR), section 537A of the Education Act 1996 and section 83 of the Children Act 1989.

Following Brexit, Regulation (EU) 2016/679, General Data Protection Regulation (GDPR) is retained EU law and known as UK GDPR. The UK GDPR sits alongside an amended version of the Data Protection Act 2018 that relate to general personal data processing, powers of the Information Commissioner and sanctions and enforcement. The GDPR as it continues to apply in the EU is known as EU GDPR.

This notice applies to all pupils and clients.

Who Collects This Information

Plus Education Group (the Company) is an education service provider which provides education services for clients and work-finding services to its work-seekers whom it places with clients to provide tutoring for students.

We are a “data controller”, which means that we are responsible for deciding how we hold and use personal information about pupils and clients (including parents as well as data provided by schools and local authorities).

This notice does not form part of any contract to provide services and we may update this notice at any time.

It is important that you read this notice with any other policies mentioned within this privacy notice, so that you are aware of how and why we are processing your information, what your rights are under data protection legislation and the procedures we take to protect your personal data.

Data Protection Principles

We will comply with the data protection principles when gathering and using personal information, as set out in our data protection policy.

The Categories Of Personal Information That We Collect, Process, Hold And Share

We may collect, store and use the following categories of personal information about you:

• Personal information such as name, pupil number, date of birth, gender and contact information;
• Emergency contact and family lifestyle information such as names, relationship, phone numbers and email addresses;

• Characteristics (such as ethnicity, language, nationality, country of birth and free school meal eligibility);
• Attendance details (such as sessions attended, number of absences and reasons for absence);
• Financial details (in order to ensure effective payment is made);
• Performance and assessment information;
• Behavioural information (including exclusions);
• Special educational needs information;
• Relevant medical information;
• Special categories of personal data (including relevant medical information and special educational needs information);
• Recordings of pupils and/or parents from the Company’s video conferencing platform;
• Information about the use of our IT, communications and other systems, and other monitoring information.

AI Use

The Company and the Group use AI tools to support tasks such as drafting, summarising, analysis, research, and workflow automation. These tools operate within our secure tenant and only access data that staff are already permitted to view, helping to improve efficiency, accuracy, and consistency across our services. All AI outputs are advisory and are subject to human review.

We have implemented a range of safeguards to ensure AI is used correctly, safely and in line with best practice. These include staff training, strict access controls, data minimisation measures, monitoring of AI use and restrictions on the use of non‑approved external AI tools. Data processed through AI tools is always within the UK or EEA. In limited circumstances where a system transfers data outside the UK or EEA, we ensure that a valid international data transfer mechanism is in place.

Collecting This Information

Whilst the majority of information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the UK General Data Protection Regulation, we will inform you whether you are required to provide certain information to us or if you have a choice in this.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

How We Use Your Personal Information

We hold personal data and use it for:

• Providing education services and extra-curricular activities to pupils, and monitoring progress and educational needs;

• To provide tutoring and educational services as agreed;

• Assessing performance and to set targets;

• Safeguarding pupils’ welfare and providing appropriate pastoral (and where necessary medical) care;

• Supporting teaching and learning;

• Giving and receiving information and references about past, current and prospective pupils and to provide references;

• Managing internal policy and procedure;

• Enabling pupils to take part in assessments and to record pupil achievements;

• Carrying out statistical analysis for diversity purposes;

• Legal and regulatory purposes (for example child protection, diversity monitoring and health and safety) and to comply with legal obligations and duties of care;

• Enabling relevant authorities to monitor performance;

• Monitoring use of the Company’s IT and communications systems in accordance with the Company’s IT security policy;

• Making use of photographic images on social media and on the website;

• Security purposes; and

• Where otherwise reasonably necessary for the Company’s purposes, including to obtain appropriate professional advice and insurance.

The Lawful Basis On Which We Use This Information

We will only use your information when the law allows us to. Most commonly, we will use your information in the following circumstances:

• Consent: the individual has given clear consent to process their personal data for a specific purpose;

• Contract: the processing is necessary for a a contract with the individual;

• Legal obligation: the processing is necessary to comply with the law (not including contractual obligations);

• Vital interests: the processing is necessary to protect someone’s life;

• Public task: the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law; and

• Legitimate Interests: the processing is necessary for the purposes of the Company’s legitimate interests (or a third party), provided those interests are not overridden by the rights and freedoms of the data subject.

We need all the categories of information in the list above primarily to allow us to comply with legal obligations. Please note that we may process information without knowledge or consent, where this is required or permitted by law.

How We Use Particularly Sensitive Personal Information

Special categories of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation, or biometrics require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit written consent.

• Where we need to carry out our legal obligations in line with our data protection policy.

• Where it is needed in the public interest, such as for equal opportunities monitoring.

• Where it is necessary to protect you or another person from harm.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Sharing Data

We may need to share your data with third parties where it is necessary. There are strict controls on who can see your information. We will not share your data if you have advised us that you do not want it shared unless it’s the only way we can make sure you stay safe and healthy, or we are legally required to do so.

Where processing requires it, we routinely share pupil and client information with:

• Schools, academies, or local authorities that the pupil is registered with;

• The Department for Education (DfE) to meet statutory obligations;

• Tutors and work-seekers engaged by the Company to deliver educational services;

• Third-party service providers who manage our IT infrastructure, video conferencing platforms, and billing systems.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.

International Data Transfers

While we prioritise processing your data within the UK and the European Economic Area (EEA), some of the third-party IT platforms, cloud storage, or software services we utilize may store or process data outside these regions.

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will transfer data to countries that have been deemed to provide an adequate level of protection for personal data.

• We will use specific Standard Contractual Clauses (SCCs) or the International Data Transfer Agreement (IDTA) approved for use in the UK, which give personal data the same protection it has in the UK and Europe.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Details of retention periods for different aspects of your personal information are available in our Data Retention Policy, which you can request from us directly. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, and the applicable legal requirements.

Your Rights Under Data Protection Law

Under data protection legislation, parents and pupils have the right to request access to information about them that we hold. To make a request for your personal information, or be given access to your child’s educational record, contact our Data Protection Officer / compliance team.

You also have the right to:

• Object to processing of personal data that is likely to cause, or is causing, damage or distress;

• Prevent processing for the purpose of direct marketing;

• Object to decisions being taken by automated means;

• In certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and

• Claim compensation for damages caused by a breach of the Data Protection regulations.

Automated Decision-Making

You will not be subject to decisions that will have a significant impact on you based solely on automated processing (i.e. decisions made by computers without human involvement), unless we have a lawful basis for doing so and have notified you.

As stated in our AI Use section, all analytical or operational AI implementations operating within the Company function strictly in an advisory capacity and are subject to mandatory human oversight.

How to Complain

If you have a concern or complaint about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance so we can investigate and resolve the matter.

Contact number: 0151 923 3147

Email: office@pluseducationrecruitment.co.uk