Introduction

The Behavioural Insights Team (BIT) is an independent research company. We are being funded by the Education Endowment Foundation (EEF) to evaluate the impact of workload reduction committees on teacher workload and retention. This work is important to help us improve our understanding of the effects of workload reduction strategies and how these can be implemented by schools. 

BIT plans on testing the impact of workload reduction committees on teacher workload and retention outcomes. The first stage of the project is a scoping phase to assess the relevance of this proposed ‘school choice’ and the feasibility of conducting a robust impact evaluation.

This privacy notice sets out how BIT collects and uses the personal data of school, multi-academy trust (MAT) and local education authority (LEA) staff (‘participants’) for the purposes of the scoping research (June 2024 – January 2025).

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 evaluation. This notice applies to the personal data we collect directly from participants and personal data which is provided to us by third parties. Where we collect personal data from participants 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: [email protected]. 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?

Scoping phase (June 2024 – January 2025)

We will collect the following personal data from school staff and representatives from MATs/LEAs:

• First and last name 
• Professional email address 
• For school staff: school name and job title 
• For Multi-Academy Trust/Local Education Authority staff: organisation name and job title
• Qualitative data (responses given during interviews/focus groups)

We may also contact you using details already held by BIT and/or EEF where you have participated in a BIT/EEF project in the past.

What do we do with information we collect?

For scoping research participants: The purpose for which BIT is processing your personal data is to assess the relevance and feasibility of implementing workload reduction committees in schools as a strategy to reduce teacher workload and increase teacher retention. 

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 is legitimate interests (as per Article 6 (1) (f) of the GDPR) and we have considered that participants’ interests and fundamental rights do not override those legitimate interests). It is necessary in BIT’s ‘legitimate interests’ to process this personal data in order to complete the scoping activities outlined above. The scoping phase is an essential part of the wider project which aims to test the impact of a proposed school choice on teacher retention. The processing of personal data is necessary to resolve uncertainties around the proposed school choice/research question and the feasibility of testing the impact of this. 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 participants’ information to third parties in connection with the purposes of processing your personal data set out in this notice. These third parties may include:

• other companies in BIT’s group (that are based in the United Kingdom)
• 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 

Anonymised data may be made available to other researchers and organisations.

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. 

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 personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Our anticipated date of deletion for participants’ personal data is March 2028 (3 months after project completion, defined as the date that the final report is signed off by the EEF). 

We may retain the names and work contact details of school staff and MAT/LEA representatives beyond this date for the purposes of inviting schools or their staff to participate in future similar projects at BIT. If you do not wish to be contacted for this reason, please email [email protected].

We may keep research 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 participants) for research or statistical purposes, in which case we may use this information indefinitely without further notice to participants. 

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. 

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: [email protected].

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.

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 identifies you. If 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 this notice on our website or by contacting you directly.