Privacy notice

Real Group National Tutoring Programme Privacy Notice

For the purposes of the Data Protection Legislation, the EEF, Evaluator, DfE and the Real Group are Joint Controllers.

The Evaluator will be the primary point of contact for the duration of the Project, with the EEF becoming the primary contact when the NTP Data is transferred to the data archive, provided in each case that:

Real Group shall, in connection with performing the foregoing obligations, provide to the EEF such information as the EEF may require from time to time, in connection with such performance; and (ii) the EEF may, upon notice to the Grantee, assume responsibility for all or part of the foregoing obligations and, in such case, the Grantee shall provide the EEF with all information and assistance as the EEF may require to enable the EEF to perform such obligations.

Contact details

  1. The contact details of the Real Group’s Data Protection Officer are:
    • Name: TBC (we are appointing a DPO in November 2020)
    • Email address: dataprotection@realgroup.co.uk
  2. The contact details of the EEF’s Data Protection Officer are:
    • Name: Alan Martin
    • Email address: dpo@eefoundation.org.uk
  3. The contact details of the Evaluator’ Data Protection Officer are:
    • Name: Richard Birkett
    • Email address: compliance@nfer.ac.uk

The type of personal information we collect

We currently collect and process the following information:

Subject matter Personal Data of students, tutors and school teachers participating in the National Tutoring Programme (“NTP Data”), which will be Processed by the Third Party Providers under the instruction of the Grantee.
Permitted Purpose The NTP Data shall be collected and Processed for research purposes and to allow the EEF and the Grantee to monitor the effectiveness of the National Tutoring Programme
NTP Data – categories of personal data

This is indicative of the types of data that will be collected, but is not intended as an exhaustive list:

Pupil data

  • Pupil’s name
  • Pupil’s age and date of birth
  • Pupil’s gender and ethnicity
  • Unique pupil number
  • Information on free school meals
  • Information on special educational needs
  • Pupil’s eligibility for pupil premium
  • Information on whether the pupil is in foster care

Tutor data

  • Tutor’s name, date of birth and email address
  • Tutor’s gender
  • Tutor’s highest qualification
  • Subject of tutor’s highest qualification
  • DBS / identity checks

School data

  • School head teacher’s name, email address and phone number
  • School tuition partner lead name, email address and phone number
NTP Data – categories of Data Subject
  • School students
  • Tutors
  • Parents of the school students
  • School employees
Handling data subject rights requests
  • The Evaluator shall be the primary point of contact for the Data Subjects for the duration of the Project; and
  • once the NTP Data is archived, EEF shall be the primary point of contact for the Data Subjects
Data Retention
  1. The parties shall retain the NTP Data in accordance with their respective established data retention policy / procedure, and in compliance with Data Protection Legislation.
  2. As soon as practicable after it has ceased to be appropriate to retain the NTP Data under Data Protection Legislation and its privacy policy / data retention policy, each party shall:
    • erase the NTP Data from any computers, storage devices and storage media; and
    • take all further action as may be necessary or desirable to ensure its compliance with Data Protection Legislation and its privacy policy.
  3. Within a reasonable time period following the expiry or termination of the Third Party Provider’s engagement by the Grantee, the Grantee shall require confirmation from the Third Party Provider that the Third Party Provider has securely destroyed and/or deleted any NTP Data in its possession and, upon request from the EEF, the Grantee shall provide a copy of any confirmation received from the Third Party Provider to the EEF. To avoid any doubt the foregoing shall be without prejudice to any Third Party Provider archiving NTP Data on behalf of the Grantee.
  4. For the avoidance of doubt, paragraph 3 shall not apply to NTP Data that is retained by the parties for a lawful reason under Data Protection Legislation.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • To enable us to effectively deliver the NTP to schools and pupils.
  • To fulfil our reporting requirements to EEF, Evaluator and the DfE

We also receive personal information indirectly, from the following sources in the following scenarios:

  • Pupils – pupil data is provided to Real Group by the school.

We may share this information with our NTP Tutor who is undertaking the tuition in the school.

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You are able to remove your consent at any time.
(b) We have a contractual obligation.
(c) We have a legal obligation.
(d) We have a vital interest.
(e) We need it to perform a public task.
(f) We have a legitimate interest.

How we store your personal information

Your information is securely stored in a secure Customer Relationship Management (CRM) system and Education Information Management System. All data is kept within the UK.

Your data protection rights

Under data protection law, you have rights including:

  • Your right of access – You have the right to ask us for copies of your personal information.
  • Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
  • Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
  • Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
  • Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us via the contact details at the top of this notice if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us via the contact details at the top of this notice.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Date: 30/10/2020