Privacy Notice

Privacy Notice

The National Tutoring Programme (NTP) respects your privacy and is committed to protecting your personal data.

Published 31 July, 2020
Last updated 14 August, 2020

The National Tutoring Programme (NTP) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Purpose of this privacy notice


This privacy notice aims to give you information on how the NTP collects and processes your personal data through your use of this website, including any data you may provide through this website when apply to us for funding, sign up to our email newsletter, use our resources, or contact us online.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller


The Education Endowment Foundation (EEF) is the controller and responsible for your personal data (as EEF’ in this privacy notice).

EEF Data Protection Officer 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, please contact the Data Protection Officer:

Education Endowment Foundation (EEF), Millbank Tower, 21 – 24 Millbank, London SW1P 4QP, Data Protection Officer, 02078021676; dpo@​eefoundation.​org.​uk.

You 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.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 27 July 2020; historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier, title, job role, and the organisation you work for (if applicable).
  • Contact Data includes delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
  • Usage Data includes information about how you use our website, resources and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Users can always refuse to supply personal data, except that it may prevent you from engaging in certain website-related activities.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply to the NTP for grant-funding;
  • request to receive NTP emails or other publications;
  • request NTP resources or marketing to be sent to you;
  • enter any promotions or surveys; or
  • contact us online.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies to enhance your experience of our website. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result. We may also receive Technical Data about you if you visit other websites employing our cookies. For further details, please see our cookies policy.

How we use your personal data


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • See table below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/​ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as an applicant for NTP funding[a] Identity [b] Contact[a] To assess your application for a grant [b] Performance of a grant agreement with you
To process and deliver your requests for NTP resources[a] Identity [b] Contact [c] Marketing and Communications[a] Your consent to receiving those resources you have requested
To process and deliver our email newsletter to you[a] Identity [b] Contact [c] Marketing and Communications[a] Your consent to receiving emails from the NTP, NTP Founding Partners, the Department for Education (DfE) and NTP-approved tutoring organisations.
To respond to enquiries submitted to the NTP[a] Identity [b] Contact[a] Your consent to being contacted by the NTP, NTP Founding Partners, the Department for Education (DfE) and NTP-approved tutoring organisations.
To manage our relationship with you which may include: [a] Notifying you about changes to our terms or privacy policy [b] Asking you to leave a review or take a survey[a] Identity [b] Contact [c] Profile [d] Marketing and Communications[a] Performance of a contract with you [b] Necessary to comply with a legal obligation [c] Necessary for our legitimate interests (to keep our records updated and to study how site users use our resources/​services)
To enable you to complete a survey[a] Identity [b] Contact [c] Profile [d] Usage [e] Marketing and Communications[a] Performance of a contract with you [b] Necessary for our legitimate interests (to study how site users use our resources/​services, to develop them to advance the NTP’’s mission)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)[a] Identity [b] Contact [c] Technical[a] Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) [a] Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you[a] Identity [b] Contact [c] Profile [d] Usage [e] Marketing and Communications [e] TechnicalNecessary for our legitimate interests (to study how site users use our resources/​services, to develop them, to inform our marketing strategy, and to advance the NTP’s mission)
To use data analytics to improve our website, products/​services,[a] Technical [b] UsageNecessary for our legitimate interests (to define types of site users for our
To use data analytics to improve our website, products/​services, marketing, customer relationships and experiences[a] Technical [b] UsageNecessary for our legitimate interests (to define types of site users for our resources and services, to keep our website updated and relevant, to inform our marketing strategy, and to advance the NTP’s mission)
To make suggestions and recommendations to you about resources or services that may be of interest to you[a] Identity [b] Contact [c] Technical [d] Usage [e] ProfileNecessary for our legitimate interests (to develop our resources/​services and to advance the NTP’s mission)


Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/​product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications.

Promotional offers from us


We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which resources, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or requested resources from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted in to receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any organisation outside the NTP, NTP Founding Partners and the Department for Education (DfE) for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of applying to us for funding, using our resources, or contacting us online.

Change of purpose


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is lawful and compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We do not sell, trade, or rent your personal identification information to others.

We share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Mailchimp (for processing email communications);
  • Percipio (for processing all contacts via the NTP website);
  • Vxtream (responsible for backing up all NTP data);
  • Salesforce (for processing all grant applications);
  • Teach First (for processing email communications and grant applications)
  • Nesta (for processing email communications)
  • Impetus (for processing email communications)
  • Department for Education (DfE) (for processing email communications);
  • Microsoft (for various email and office functions).

In addition, we may share your data with approved National Tutoring Programme providers. These will be listed below once they have been appointed.

Approved National Tutoring Programme providers may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

International transfers

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • As of 16th July 2020, the European Court of Justice has invalidated Privacy Shield. As per ICO advice, we will take stock of the international transfers we make and react promptly as guidance and advice becomes available.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

How long will you use my personal data for?

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.

This may include retaining data after you have made an opt-out or similar request to ensure that you are not subsequently sent information by mistake and to protect against, for example, malicious attempts to add you to lists you do not wish to be a member of.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Your data protection

Under data protection law, you have rights including:

  • Your right of access – You have the right to ask us for copies of your personal information.
  • Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
  • Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
  • Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
  • Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at dpo@​eefoundation.​org.​uk if you wish to make a request.

No fee usually required

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.

What we may need from you

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.

Time limit to respond

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.