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Privacy Notice – Reciprocal Reading Evaluation

Introduction

The Behavioural Insights Team (BIT) is an independent research company. We are conducting an evaluation of the Reciprocal Reading programme, which is being run with pupils in schools across England. This work is important to help us understand the impact of this programme and any improvements that can be put into place to make it better, for other schools and pupils in future. This research is being funded by the Education Endowment Foundation (EEF), and conducted in collaboration with the Fisher Family Trust (FFT) who provide the Reciprocal Reading programme to schools.

This privacy notice sets out how BIT collects and uses the personal data of school staff, pupils and parents (‘participants’) for the purposes of this evaluation.

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. 

BIT will also receive participant data from FFT, the organisation delivering the Reciprocal Reading programme, who will act as a separate data controller. Please refer to their privacy notice for more information about their privacy practices.

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?

Pupil data

We will collect personal data from pupils involved in the research including: 

  • Unique Pupil Number (UPN, identifies the pupil in the National Pupil Database)
  • First name
  • Last name
  • Gender 
  • Date of birth 
  • School name
  • Year group
  • New Group Reading Test (NGRT) pre-intervention and post-intervention scores 
  • Key Stage 2 SATs Reading scores
  • Free school meal (FSM) status
  • Ethnicity* 
  • Whether the pupil speaks English as an Additional Language 
  • Special Educational Needs status and category* 
  • Type of special educational need*
  • Focus group discussion data – qualitative data gathered in focus groups on attitudes to the reciprocal reading intervention
  • Reciprocal reading session attendance data – data on the number and length of reciprocal reading interventions attended
  • Teachers’ perceptions of their home reading environment (available resources, parental attitudes to reading, exposure to reading)  – qualitative information will be gathered from teachers and used to contextualise responses from pupils (this only applies to pupils who are taking part in a focus group). 

*Some of this data – ethnicity and data about health conditions – constitutes ‘special category data’ under data protection laws, and additional protections will apply to our collection and use of this data. This information is vital for our analysis, to assess the reach and possible differential effects of the programme. Reporting on these fields for the purpose of our research will be in an aggregated format only. 

Pupils’ parent data

We will collect personal data from parents of the pupils involved in the research including: 

  • First name
  • Last name
  • Email address
  • Telephone number
  • Data on socio-economic background (FSM status) of their children 
  • Interview data – qualitative data on attitudes to reading and self-reported reading behaviours in the home

School staff data

We will collect personal data from school staff involved in the research including: 

  • First name
  • Last name
  • Work email address
  • Work telephone number
  • Survey data – quantitative and qualitative data on attitudes to the reciprocal reading intervention
  • Interview data – qualitative data on attitudes to the reciprocal reading intervention
  • Reasons for a school’s withdrawal from the trial and other specific circumstances within the school or concerning school staff that affect the school’s ability to participate in the Reciprocal Reading programme or in the evaluation activities. This includes information collected from emails sent by school staff to FFT on these topics.

What do we do with information we collect?

BIT is collecting your personal data to deliver and manage an independent evaluation of the Reciprocal Reading programme. 

As part of this evaluation, BIT will run a trial in approximately 300 primary schools in England. This trial will involve randomly selecting half of these schools to receive the programme (‘intervention schools’) and half to not receive it (‘control schools’).

Selected pupils in the intervention schools will receive twice weekly 30 minute reading sessions, led by a Teacher/Teaching Assistant (TA) – for a minimum of 12 weeks during the Spring Term of 2024. The control schools will carry on with their business as usual.

At the end of the trial, BIT will compare the reading outcomes of pupils in the intervention schools to those in the control schools to work out the impact of the Reciprocal Reading programme. BIT will also assess how the impact (if any) is achieved.

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 the personal data identified above in order to conduct an evaluation of the Reciprocal Reading programme 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.

For special category data (see above), we also rely on the following lawful basis:

SCIENTIFIC RESEARCH PURPOSES: Our processing is necessary for scientific research purposes in the public interest, subject to suitable and specific measures to safeguard the fundamental rights and the interests of the data subject, as required by applicable laws.

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:

  • 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 participants as we will share anonymised or pseudonymised data only wherever possible. We remain responsible for participants’ 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 will share participants’ data with the following organisations:

  • Qa Research – An independent provider contracted to administer the New Group Reading Test (NGRT) in partner schools.  
  • GL Assessments – An independent provider which will provide the platform to run the NGRT tests.
  • Schools participating in the research, which will receive pupil NGRT scores at the end of the study.
  • FFT, which will receive pupil NGRT scores at the end of the study.
  • The Department for Education (DfE) – National Pupil Database (NPD) team.
  • The Office for National Statistics – Secure Research Service (ONS SRS) – We will use the ONS SRS to analyse the trial data securely when it is matched to NPD data.
  • At the end of the evaluation, the data will be shared with the EEF and FFT Education (EEF’s data processor for their archive). All EEF trial data is stored in the EEF data archive, held within the ONS SRS. The archive does not contain direct identifiers like pupil name, contact details and date of birth, but does hold a Pupil Matching Reference (PMR). The PMR is used for further matching to the NPD and other administrative datasets that may be required as part of subsequent research. We will not use pupil names or school names in any report arising from the research. For information on how the EEF will use and protect participants’ data, please see their Data protection statement regarding EEF evaluations.

We may also disclose participants’ 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 

We may share your personal information with SmartSurvey, our technical service provider, for the purpose of survey administration. 

In such circumstances, your information may be transferred outside of the UK or EEA. In this case, we will ensure appropriate safeguards are implemented and participants’ are fully informed of the transfer (unless it is otherwise prohibited by law to inform you).  If you require further information about this, you can request it from the Data Protection Officer.

Security

We take reasonable steps to protect participants’ personal information and follow procedures designed to minimise unauthorised access, alteration, loss or disclosure of participants’ 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 participants’ and any applicable regulator of a breach where we are legally required to do so.

Data retention 

We will only retain participants’ 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 participants’ 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 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.

Taking the above factors into consideration, and save as set out below in relation to teacher data, our anticipated date of deletion for participants’ personal data is September 2025 (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 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 dpo@bi.team.

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. 

Withdrawing participation 

At any point until 31st July 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 FFT Literacy and schools will not share your child’s personal data. The pupil will still partake in Reciprocal Reading sessions, but their data will not be collected, and they will not be tested using the NGRT reading 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 personal data for your child and will, where possible, delete all of your child’s personal data collected up to that point  (other than interview responses that have already been analysed and anonymised, which will be handled in accordance with the remainder of this privacy notice). 

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 https://www.bi.team/research-project-privacy-notice-reciprocal-reading-evaluation or by contacting you directly.