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Research Project Privacy Notice for school staff and parents

One Step Ahead: A Teacher Choices project

Introduction

Your school or your child’s school is participating in a research project testing the impact of an early learning Teacher Choices project called One Step Ahead. A common question teachers ask about their practice is how to best support pupils to access lesson content in mathematics. One Step Ahead explores how regular targeted pre-teaching sessions for Key Stage 1 pupils can improve their confidence and mathematical reasoning skills, compared with other usual approaches to targeted support that do not involve pre-teaching. 

The project is a collaboration between the Behavioural Insights Team (BIT) and the Education Endowment Foundation (EEF). BIT has designed the project, and will be delivering and evaluating the project. The EEF are the funders of the project, including its evaluation. In each participating school, 24 pupils will take part in the initiative (12 in Year 1 and 12 in Year 2). In each year-group, 6 of the 12 pupils will receive regular pre-teaching maths sessions over one term, and the other 6 will continue to benefit from the in-class and out-of-class support they would usually receive, but not receive any pre-teaching. 

This privacy notice sets out how BIT, as a data controller, will collect and use the personal data of the pupils and school staff that participate in the research.

Contact details

Behavioural Insights Ltd (the legal name of BIT is the controller and is responsible for any personal data collected in connection with this evaluation. 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 a school staff member or a pupil’s  legal rights in relation to staff or a pupil’s  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 and what will we do with it?

Most personal data will be collected directly from participating schools. Data will be shared and stored securely, in accordance with the Data Protection Act (2018) and UK GDPR (General Data Protection Regulation).

For participating Year 1 and Year 2 pupils, the following data will be collected:

  • Full name
  • Date of birth
  • Gender
  • Free School Meals eligibility status
  • English as an Additional Language (EAL) status
  • SEN status
  • Type of SEN (if applicable)
  • Unique Pupil Number (UPN)
  • Year group
  • Attendance to pre-teaching maths sessions
  • Results from a short mathematical assessment at the start and end of the trial
  • Results from a short questionnaire about maths anxiety at the end of the trial
  • Focus group discussion data – qualitative data gathered in focus groups on experiences of the pre-teaching sessions*
  • Observation fieldwork notes*
  • School name and URN

* This data will only be collected for pupils in schools selected for case studies and observations and will therefore not be collected for every pupil involved in the One Step Ahead project. You will be informed if your school or your child is selected for focus groups and observations, which are voluntary opt-in activities for schools.

BIT will use the data collected to conduct an evaluation of the One Step Ahead trial. As part of this evaluation, we are running a trial in approximately 95 primary schools in England. This trial will involve Year 1 and Year 2 teachers in all participating schools to identify 12 pupils in their class who may be eligible for pre-teaching sessions in maths. BIT will randomly allocate half of the identified pupils to receive pre-teaching sessions (‘pre-teaching’ group). The other half of the identified pupils will not receive pre-teaching sessions in KS1 Maths, but can receive any other type of additional support typically provided (forming a ‘comparison’ group).

At the end of the project, BIT will use the pupil data that it has collected (as listed above) to measure the effect of One Step Ahead pre-teaching on pupils’ skills and confidence in maths. BIT will also assess how the impact (if any) is achieved.

For school staff (including the key contact person, Year 1 and Year 2 teachers, and Maths lead where relevant), the following data will be collected:

  • Name
  • Email address
  • Job title
  • Number of years’ teaching experience
  • Specialism (if any)
  • Usual practice of providing targeted or additional out-of-class support for KS1 Maths
  • Lesson topics covered in the term
  • Class size 
  • Attitudes and views about the pre-teaching approach and the trial
  • Attitudes and views about the guidance materials for the trial

 

This data will be used to deliver the initiative. Specifically, BIT will use school staff data to:

  • Communicate directly with the school staff to facilitate delivery of the One Step Ahead initiative.
  • Share this information with the project funders, EEF, who will use it to monitor the recruitment of schools to the project.
  • Enable BIT to recontact school staff to invite them to take part in future research projects.

We will not use any identifiable staff, pupil, or school data and information in any report that we publish about the One Step Ahead project.

Withdrawing pupil participation

At any point until July 15, 2024, you can withdraw your child’s participation from the trial. If you withdraw your child from the trial before any of their personal data is shared with BIT, then schools will not share your child’s personal data, your child will not participate in the pre-teaching sessions, and they will not take the baseline and endline tests. Should we be informed that you would like to withdraw your child from the trial after some personal data has been collected, we will not collect any additional data for your child. Wherever possible, we will delete all of your child’s personal data collected up to that point (other than interview responses that have already been anonymised and analysed, which will be handled in accordance with the remainder of this privacy notice). 

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 staff and pupil data in the manner described in this notice, including having a lawful basis for the processing. 

For all information collected as part of the One Step Ahead project, 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 staff and pupil 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 learn more about the teaching of mathematics in the classroom to help us assess the feasibility of different teacher choice approaches that aim at improving maths attainment and reducing attainment gaps between pupils. The research project fulfils BIT’s core business aims including undertaking research, evaluation and information activities in sectors that will deliver social impact. This determination is based on an assessment undertaken by BIT’s Legal team, which is performed in advance of each new research project.

Who has access to your information?

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

BIT may disclose the information to third parties in connection with the purposes of processing the 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 personal data is protected. This does not always mean that they will have access to information that will directly identify school staff or pupils as we will share anonymised or pseudonymised data only wherever possible. We remain responsible for staff and pupil personal information as the controller.

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

We may also disclose staff or pupil 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.

For the purpose of research and archiving, pupil-level impact data (e.g. maths learning and anxiety assessment results) and some pupil personal data (e.g. name, date of birth, UPN) that BIT has collected will be securely shared with the EEF’s Data Archive manager (FFT). FFT will match each pupil’s personal data with a unique Pupil Matching Reference number in the Department for Education’s (DfE) National Pupil Database. Once matched, all pupil personal data that could directly identify a pupil will be deleted and the remaining pseudonymised pupil data will be added to the EEF Archive. At this point, EEF will become the controller of the data transferred to the EEF Data Archive. The EEF Data Archive is held in the Office for National Statistics (ONS)’ Secure Research Service and includes information that is only identifiable to the DfE. The data is kept indefinitely for the purposes of future research, which may entail matching the data with other administrative data. For more information about the EEF Data Archive and EEF’s privacy notice, please see here.

International transfers 

Staff and pupil 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 personal information and follow procedures designed to minimise unauthorised access, alteration, loss or disclosure of personal 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 personal 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 staff and parents and any applicable regulator of a breach where we are legally required to do so.

Data retention 

We will only retain staff and pupil 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 the staff and pupil 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 the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Taking the above factors into consideration, the approximate date of deletion for staff and pupil personal data is 31st December 2025 (within three months of the final report for the One Step Ahead project being published). 

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

School staff and pupil legal rights 

Under certain circumstances, staff and pupils have rights under data protection laws in relation to their 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 a staff member or a pupil wishes 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. Please note that this does preclude you exercising your right to complaint via the Information Commissioner’s Office (www.ico.org.uk).

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 staff and pupil personal information we will make this clear by updating the notice on the project website or by contacting staff and parents directly.