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Research Project Privacy Notice – Embedding Formative Assessment Scale-up Evaluation

Introduction 

The Behavioural Insights Team is conducting an evaluation of the scaling activities of the Schools, Students and Teachers Network’s (SSAT’s) Embedding Formative Assessment (EFA) programme. This privacy notice sets out how we collect and use your personal data if you are a participant in this research project. 

This research is being conducted in collaboration with SSAT and funded by the Education Endowment Foundation (EEF).

Contact details

Behavioural Insights Ltd (the legal name of Behavioural Insights Team (BIT)) is the controller and is responsible for your personal data collected in connection with this project. This notice applies to the personal data we collect directly from you and personal data which is provided to us by third parties. Where we collect personal data from you directly, please make sure that any personal details you provide are accurate and up to date, and let us know about any changes as soon as possible. 

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights in relation to your personal data, please contact the DPO: 

Post: Behavioural Insights Ltd, 58 Victoria Embankment, London, EC4Y 0DS.

Email: dpo@bi.team. 

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

What personal data will we collect?

We will collect personal data on school staff members involved in EFA, including:

  • Full name
  • School name
  • Role at school and in relation to EFA
  • Email address
  • Phone number

We will collect personal data on SSAT staff members, including: 

  • Full name
  • Role at SSAT
  • Email address
  • Phone number

We will collect personal data on existing and prospective EFA Mentors, including:

  • First name
  • Last name
  • Work email address
  • Work telephone

We will collect this data indirectly from SSAT and directly from participants. The contract signed by schools to participate in the EFA programme for the 2020/21, 2021/22, and 2022/23 school years included information about this evaluation and informed the signer that SSAT may share contact details with the evaluator (BIT) in order to arrange for participation in evaluation activities. 

Participants may also have the opportunity to participate in interviews and surveys about their experience with the programme. We will ask for consent from participants before collecting this data. Our handling of this data will be as below. 

What do we do with information we collect?

The purpose for which BIT is processing your personal data is to deliver an independent evaluation of the scale-up of the EFA programme. We will collect the personal data described above for the purpose of contacting you to take part in surveys, interviews, focus groups, and/or observations.

What is our lawful basis for processing your personal data?

Data protection laws require us to meet certain conditions before we are allowed to use your data in the manner described in this notice, including having a lawful basis  for the processing. 

For all information collected, BIT is relying on the lawful basis of: 

LEGITIMATE INTERESTS: Our lawful basis for processing the personal data listed above (e.g., SSAT and school staff names, contact details, interview and survey data) is legitimate interests (as per Article 6 (1) (f) of the GDPR) and we have considered that your interests and fundamental rights do not override those legitimate interests). It is necessary in BIT’s ‘legitimate interests’ to process the personal data identified above in order to conduct an evaluation of EFA’s scale-up that has been commissioned by the EEF. The research project fulfils BIT’s core business aims including undertaking research, evaluation and information activities in sectors that will deliver social impact.

Who has access to your information?

Your information will be accessed by a limited number of researchers and advisors in BIT’s project team working on this project. 

BIT may disclose your information to third parties in connection with the purposes of processing your personal data set out in this notice. These third parties may include:

  • regulators, law enforcement bodies and the courts, in order to comply with applicable laws and regulations, assist with regulatory enquiries, and cooperate with court mandated processes, including the conduct of litigation; 
  • suppliers, research assistants and sub-contractors who may process information on behalf of BIT e.g. cloud services to store data, transcription services, and survey platforms. These third parties are known as data processors and when we use them we have contractual terms and policies and procedures in place to ensure that your personal data is protected. This does not always mean that they will have access to information that will directly identify you as we will share anonymised or pseudonymised data only wherever possible. We remain responsible for your personal information as the controller; and
  • any third party to whom we are proposing to sell or transfer some or all of our business or assets.

BIT may share school lead names and email addresses with SSAT if leads and/or email addresses change during the evaluation. 

We may also disclose your personal information if required by law, or to protect or defend ourselves or others against illegal or harmful activities, or as part of a reorganisation or restructuring of our organisations.

International transfers 

Your personal information will not be transferred outside of the European Economic Area (“EEA”).  References in this notice to the EEA include the UK, even where the UK is no longer a member of the European Union / European Economic Area.

Security

We take reasonable steps to protect your personal information and follow procedures designed to minimise unauthorised access, alteration, loss or disclosure of your information. 

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing.

We ensure that those who have permanent or regular access to personal data, or that are involved in the processing of personal data, are trained and informed of their rights and responsibilities when processing personal data.  We provide such access on a need-to-know basis, and have measures in place which are designed to remove that access once it is no longer required.

Physical personal devices used by BIT are encrypted to protect your data, and confidential hard copy data (including special category data) is kept in locked rooms or cabinets.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention 

We will only retain your personal data 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. When it is no longer necessary to retain your personal data, it will be securely deleted. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Taking the above factors into consideration, our anticipated date of deletion for your personal data is August 2024 (within six months of the final report being published). 

We may keep consent forms which contain personal information for a number of years after the research has been completed in order to meet legal and statutory requirements and/or because this is a requirement of the research’s funder. 

In some circumstances, we will retain an anonymised dataset (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Your legal rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including rights to: 

  • Request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check we are lawfully processing it. 
  • Request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected. 
  • Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
  • Object to processing of your personal data: for example, you can object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 
  • Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data. 
  • Data portability: Where the processing takes place on the basis of your consent or contract, and is carried out by automated means, you have the right to request that we provide your personal data to you in a machine-readable format, or transmit it to a third party data controller, where technically feasible.
  • Withdraw consent to the processing of your personal data: This applies where we have relied on consent to process personal data. Please note that withdrawal of consent will not affect the lawfulness of any processing carried out before withdrawing your consent. 
  • Not be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you. Please note that BIT does not engage in automated decision making without manual intervention in its research projects.  

If you wish to exercise any of the rights set out above, please contact the Data Protection Officer with your specific request by email to: dpo@bi.team

It is important to understand that the extent to which these rights apply to research will vary and that in some circumstances your rights may be restricted.

Ordinarily, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Please also note that we can only comply with a request to exercise your rights during the period for which we hold personal information that directly identifies you. If we have only collected pseudonymised information (e.g. where we have not collected any names or contact details) or personal data has been irreversibly anonymised and has become part of the research data set, it will not be possible for us to comply. 

Changes to this Notice 

We may change this Privacy Notice from time to time.  If we make any significant changes in the way we treat your personal information we will make this clear by updating the notice on the project website [bi.team/Embedding-Formative-Assessment-evaluation] or by contacting you directly.