Privacy notice – Oxford Analytics 2020-21

What is the purpose of this notice?

This policy should be read in conjunction with our GDPR statement and terms and conditions.

Oxford Analytics provides research, training and consultancy services for schools, colleges academies and policy makers. To provide our products and/or services we need to use personal data. We take your privacy and data security seriously. This privacy notice summarises our data collection, processing and usage practices. It also describes your choices regarding use, access, and correction of your personal information.

By using our website, www.oxfordanalytics.org, you consent to the data practices described in this notice and you consent to our use of cookies. If you do not agree with the data practices or the use of cookies described in this notice, you should not use our website.

We may update this notice from time to time by publishing a new version on our website in line with legislative updates and/or changes. We may notify you of changes to this policy by email or, if you are a registered user, through our e-newsletter.

  1. How we use your personal data

In this Section 1 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data;

(c) the legal bases of the processing.

1.1 Usage data – www.oxfordanalytics.org

Oxford Analytics is the data controller and responsible for this website. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and WordPress. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

We do not collect Special Categories of Personal Data. Special Categories of Personal Data can include details about your race or ethnicity, sex life, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, information about your health and genetic and biometric data).

1.2 Service data

We may process your personal data that is provided in the course of the use of our services (“service

1.2.1 Reporting data – level 3 performance

For the purposes of the Data Protection Act 2018 and the General Data Protection Regulation ((EU) 2016/679) (“GDPR”)) we are a “data processor” on your behalf when providing reporting and/or services such as the preparation of Level 3 reports (August results report, Mocks & Monitoring reports) and L3 comparative analysis on behalf of your school/college/academy, when you request us to do so. In our capacity as a data processor for Level 3 reporting and research, we collect and process information. We collect data only for the purposes that we have clearly explained to you and limited only to those purposes. We process the data received from partner school/colleges/academies for the purposes of education and school improvement only, and only for those purposes necessary to provide the service offered to schools or colleges – as described on this website. When using our services, your school, college, academy or MAT (partner centres) will be the “data controller” You decide which information to send to Oxford Analytics, when and what we can do with it. As data controller, you should only process personal data if you can do so for one of the reasons allowed in the GDPR. Schools (maintained), colleges and academies are considered public bodies and you can seek to rely on the “public interest” reason for processing this data, utilising Oxford Analytics for the purpose of providing educational research and school improvement in the public interest. The processing we conduct is required to support the legitimate interests of partner centres; and to fulfil our contractual obligations to that school, academy, college or MAT.

1.2.2 Research Data- NPD Level 3 outcomes.

For the purposes of the Data Protection Act 2018 and the General Data Protection Regulation ((EU2016/679) (“GDPR”)) we are considered a “data controller and data processor” when producing level 3 Grade Outcomes information, derived from NPD data. The processing is proportionate and necessary for our legitimate interests and that of the schools, academies, colleges and multi-academy trusts we provide educational support to.  The processing we conduct is also required to fulfill our contractual obligations to partner school, academies, colleges and multi-academy trusts.

We do not hold the original data. The data we request, and which the data provider supplies, de-identifies individual learner data which then cannot be linked to any data outside that of the dataset provided. All published outputs are totally anonymous and approved by the data provider and ONS supervisors.  All processing takes place in the ONS secure environment and no data is used for any other purpose than that agreed and explained in the NPD agreement.  We process the data in order to provide resources that support student progress and the management of this in post-16 centres. Our request is detailed in the Approved Data Request list published by DfE as part of the Government efficiency, transparency and accountability programme.

The processing of the data is for the wider purpose of promoting education in England through conducting research or analysis, producing statistics to support student progress, in line with the Education (Individual Pupil Information) (Prescribed persons) (England) Regulations 2009.

1.3 Enquiry data

We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering and selling relevant services to you. We may also process information relating to how you have interacted with our website and any marketing we have sent you in order that we may send you relevant communications. The legal basis for this processing is consent.

1.4 Transaction data

We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

1.5 Notification data

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

1.6 Correspondence data

We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and communications with users.

1.7 The establishment, exercise, or defence of legal claims

We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise, or defence, of legal claims, whether in court proceedings or in an administrative, or out-of-court, procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

1.8 Compliance with a legal obligation

In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

1.9 Other People’s Personal Data

Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

In this Section 2, we provide you with information about which third parties we may pass your data to.

2.1 Group companies

We do not disclose your personal data to any other companies.

2.2 Our professional advisors

We may disclose your personal data to our insurers and/or professional advisers insofar as is reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice, and managing legal disputes.

2.3 Our technical providers

We may disclose your personal data to our data centre, telephony, and server administration providers insofar as is reasonably necessary for the safe and efficient storage of your data.

2.4 Our payment providers

Financial transactions relating to our website and services may be handled by our payment services providers, PayPal and Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds. You can find our payment provider’s privacy policies in the following places:

Paypal: https://www.paypal.com/ee/webapps/mpp/ua/privacy-full

Stripe: https://stripe.com/gb/privacy

2.5 For compliance with a legal obligation

In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. International transfers of your personal data

We do not transfer data outside the UK.

  1. Retaining and deleting personal data

This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.1 Length of retention

The periods for which we keep your information depend on the purpose for which your information was collected and the use to which it is put. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. See section 10 for level 3 data retention.

4.2 Retention relating to a legal obligation

Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests, or the vital interests of another natural person.

  1. Security of personal data

5.1 Appropriate measures

We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, or alteration of your personal data.

5.2 Secure storage

We will store all your personal data on secure servers, personal computers, and mobile devices, and in secure manual record-keeping systems.

5.3 Password storage

Any passwords you provide us will be stored by us in encrypted form.

5.4 Financial transactions

Data relating to financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

5.5 L3 Passwords.

Designated staff at the centre is/are provided with a single access password for L3 services.  If you are an L3 user you should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing L3 services confidential and we will not ask you for your password (except when you log in to L3 reporting or request support with your use of the service).  You are responsible for managing the distribution of that password.  In addition, you have the right to request a change of password at any time and this should be undertaken when you have change of staff able to access the service.

  1. Your rights

In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.1 Principal rights

Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority;

(h) the right to withdraw consent.

6.2 Right to access

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.

6.3 Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

6.4 Right to rectification

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

6.5 Right to erasure

In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

6.6 Right to restrict processing

In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

6.7 Right to object to processing

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

6.8 Right to object to direct marketing

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

6.9 Right to object to processing for scientific or historical research

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

6.10 Right to data portability

To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

6.11 Right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In the UK the supervisory authority is the Information Commissioner’s Office – https://ico.org.uk.

6.12 Right to withdraw consent

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

6.13 Providing us with written notice

You may exercise any of your rights in relation to your personal data by written notice to us at helpdesk@oxfordanalytics.org or to the postal address as published in this privacy statement.

  1. Third party websites

7.1 We do not link to third party websites

  1. Personal data of children

8.1 Age range

Our website, reporting services and resources are targeted at teachers and managers in educational provision.  Some resources may be used by staff at these providers with students over the age of 15.  We do not hold the personal data of a person under the age of 18 in our databases.  If we discovered so, we will delete that personal data.

  1. Updating information

9.1 What to do if you want your data updated

Please let us know by email at helpdesk@oxfordanalytics.org or by post to the postal address as published in this privacy notice if the personal information that we hold about you needs to be corrected or updated.

  1. Acting as a data processor

10.1 level 3 reporting and research – data processing

In respect of our L3 users’ data, we act as a data processor for the express purposes of the Data Protection Act 2018 and the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) when producing level 3 reports or analysis. The processing is required to support the legitimate interests of partner centres; and to fulfill our contractual obligations to that school, academy, college or MAT.

We adhere to the terms of the Data Protection Act 2018 and GDPR, and any successor amendments and/or legislation.

We collect data only for purposes that we have agreed with you to support school improvement objectives.

Our processing is necessary, proportional, secure and designed to have minimal privacy impact. We process the data required by partner centres to achieve their school improvement objectives only as explicitly agreed with you.

  1. We offer the opportunity to delete uploaded data immediately.
  2. If not deleted, your data will be erased automatically from our servers within 80 hours.
  3. We do not retain any institution’s learner data for any purpose.
  4. Our storage and processing uses encrypted servers only located in the UK and process the minimum data required to provide our contract to you.

Oxford Analytics is aware that schools/colleges/academies have an obligation to ensure that they are following Data Protection and/or Local Authority guidelines and therefore recommend that schools/colleges include Oxford Analytics within their ‘fair processing notice’ for ongoing processing.

Data security

We deploy a range of appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  We ensure that all data is held securely and take a range of steps to ensure data is not corrupted or lost. We also ensure the data is accurate and kept up to date at all times.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business requirement to access it.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.

We audit and review our services against this policy every 12 months and provide evidence of compliance to the other party whenever requested

Data Protection Act /Information Commissioner’s Office 

We are registered with the Information Commissioner’s Office. The ICO is the UK’s independent public body set up to protect personal information and to promote good practice in relation to data collation and use.  Our data protection registration number is ZA146504.

We have an established policy to report any breaches of security to the data controller, the Information Commissioner’s Office (ICO) and other authorities if required by law, and, in co-operation with the data controller, to data subjects

  1. Processing of external datasets.

We access national datasets for the purpose of providing summary analysis of subject performance.  No identifiable personal data is included in the outcomes of the analysis and the nature of any publication is notified in advance through a data request and/or via the approval process for the data release. Any data used is either in the public domain or through an approved data release from the data holder.

  1. About cookies

12.1 What a cookie is

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.2 Types of cookie

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3 Cookies and personal data

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

12.4 Cookies that we use

We use cookies for the following purposes:

(a) necessary cookies – we use these cookies help make our website usable by enabling basic functions like page navigation and access to pages which require visitors to create an account and login. The website cannot function properly without these cookies;

  1. Managing cookies

13.1 Per browser

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari);

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and- privacy (Edge).

13.2 Blocking cookies

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on our website.

  1. Email marketing tracking

Tracking email opens

When we send marketing emails promoting Oxford Analytics’s products and services we employ a common software technology called beacons. Beacons are tiny 1px x 1px graphics with a unique identifier, similar in function to cookies, and are used to track if you have opened a marketing email. We use these in our HTML-based emails to let us know which emails have been opened by recipients. They allow us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered by beacons in emails to our customers’ personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each email we send you.

Tracking email clicks

When we send marketing emails promoting Oxford Analytics’s products and services we personalise each link in each email with unique code to enable us to track whether the recipient has clicked on the link in the email. This allows us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns. We also combine the information gathered by beacons in emails to our customers’ personal data. If you would like to opt-out of these emails you can do so by clicking on the unsubscribe link in the footer of each email we send you.

  1. Our details

15.1 This website

This website is owned and operated by Oxford Analytics.

15.2 Our company registration

We are registered in England and Wales under registration number 08647112.

15.3 Our place of business

Our principal place of business is the University of Oxford’s Centre for Innovation and Enterprise, Begbroke Science Park, Woodstock Road, Begbroke, Oxford, OX5 1PF.

15.4 Contact methods

You can contact us:

(a) by post, using the postal address given above;

(b) by telephone, on 01865 309617

(c) by email, on helpdesk@oxfordanalytics.orgor the contact form published on our website;

15.5 Data protection officer

Our data protection officer’s contact details are: Data Protection Officer, University of Oxford’s Centre for Innovation and Enterprise, Begbroke Science Park, Woodstock Road, Begbroke, Oxford, OX5 1PF.