Free Flow Info

Privacy Notice – Information for FFI Users

Who we are

Engagement in Education Ltd (EiE) is a leading education consultancy working to shape and deliver innovative yet simple methods to improve effective Parental Engagement, Parental Involvement and Stakeholder Engagement in education. This expertise has led to the development of a whole new approach and methodology to Parental Engagement in children’s learning – Free Flow Info (FFI).

EiE Ltd is a company incorporated and registered in England and Wales (registration no. 6597278). We are also registered with the Information Commissioners Office (registration reference ZA188643). You can contact us at our registered office at:

Engagement in Education Ltd

19 Saunders Croft,

Walkington,

East Riding of Yorkshire

HU17 8TG

Tel (01482) 881036

Email: alan@engagementineducation.co.uk

Why Does Engagement in Education Ltd process Personal Data

FreeFlowInfo (FFI) is a Parental Engagement methodology and approach that has been developed by EiE. It uses a bespoke web platform to provide parents and wider family members with a steady, but not overwhelming, flow of information harvested from the work that teachers and pupils are already doing as part of their daily practice; offering a catalyst for regular, positive conversations at home about what the child has been doing in school. This information can be in the form of photographs, pdf files, Office documents, video or audio and is uploaded onto the FFI web platform.

Each pupil account can be shared with up to 5 people. These can be 2 parents and 3 family members (Supporters) – all of whom can make positive comments on the upload – but importantly cannot see each other’s comments. Supporters will only be able to access and use the FFI platform with the written consent of the child’s parent. The Parent is the legal guardian of the pupil / student. Supporters are wider family members of the pupil / student as authorised by the Parent / Carer.

The Personal Data identified in the following sections of this Notice will generate login details to the platform and allow you to access the information associated with the child to which you are related for the duration of the school’s registration to the platform, your employment as a member of staff to the school, or your child’s attendance at that school.

During the period of your registration, EiE will use your Personal Data to administer your account. Schools have a legal responsibility to report the progress of children to their parents, and when asked by relevant government agencies, to demonstrate this provision. The platforms analytical tools will be able to provide evidence of the amount of information being uploaded to your child’s account and how effective the sharing of information is. A simple practical application of this could be for the school to inform you if one of your child’s Supporters is not making use of the platform to support your child, enabling you to select someone else.

FFI has been shaped through feedback from users over several years. Occasionally, EiE may perform research on relevant topics which may capture your use of the platform, your opinions and perspectives. This information is used to improve both school strategies for learning along with EiE’s ongoing development and improved functionality of the FFI approach, methodology and the web platform. The data used for these purposes will be totally anonymised so that no individual can be identified.

We will not share your Personal Data for marketing purposes with companies outside of EiE.

What Personal Data does EiE collect?

EiE is committed to being transparent about how it collects and uses Personal Data and to meet our data protection obligations. To allow school, pupil, parent and supporter access / use of the FFI web platform, EiE collects and processes a selection of Personal Data with your consent:

Pupils under the age of 13 years will require parental authorisation through written consent in their use of the FFI web platform. This should be provided to the school.

How does EiE collect this Personal Data?

Personal Data for the population and use of the FFI web platform is collected in a number of ways. Name, Title, Date of Birth (where applicable) and Email address are taken directly from the school’s management information system through the creation of a csv file that is uploaded to the FFI web platform. This process is undertaken by the school, or on occasion where technical support is required, by EiE or its third-party IT provider.

The school administrator can also input Personal Data (for example, Name and Email address) directly onto the FFI web platform. This information will generate your login details (username and password) that will allow access and use of the FFI web platform.

All Personal Data used to populate the FFI web platform such as name, title and Email address will be maintained by the school and it is your responsibility to make sure that this information is kept up to date with the school administrator.

How is your Personal Data stored and secured?

Your data is taken from the school’s Management Information System and stored on our FFI Web Platform. This is a Cloud based web application with information being securely stored with the latest firewall and storage security technologies.

In order to protect your privacy, EiE has implemented stringent Information Security and Personal Data Protection Policies. Employees and Associates who come into contact with your Personal Data have obligations to adhere to our policies and are regularly trained in security and privacy best practice.

As a user of the FFI web platform, you should regularly change your login password.

We apply appropriate technical and organisational measures in order to protect data, computing devices and the network from accidental / malicious activities or theft. Where appropriate, we encrypt our data and devices with confidential information securely destroyed when no longer required.

How long will your Personal Data be retained for?

EiE will retain your Personal Data for the duration of:

Principle 5 of the EU General Data Protection Regulation requires organisations to retain personal data “no longer than is necessary for the purpose it was obtained for. Ensuring personal data is disposed of when no longer needed will reduce the risk that it will become inaccurate, out of date or irrelevant”.

Prior to a child leaving the school, the school has the ability to download all documents that have been uploaded to the platform onto a CD or USB memory stick for the child / student / parent to keep. On leaving the school, all Personal Data and information uploaded to the FFI platform will be archived up until the statutory school leaving age of the pupil after which it will be deleted. Parents can request a copy of this information at any point in this period.

Personal Data Provided by Third Parties

The school that you are associated with, either as a member of staff, a pupil, parent or authorised family member (Supporter) of the pupil at that school, will use your Personal Data to populate the FFI web platform and enable your access to its use. The information required is collected from the school’s management information system as described previously.

Who May Have Access to Personal Data?

Your Personal Data will be uploaded to the FFI platform by the school. Where the school is part of a Multi Academy Trust arrangement, there may be occasions where information is shared with other schools in the Trust.

EiE staff and its IT Provider may also have access to this personal data on the occasion where:

What If You Do Not Supply Your Personal Data?

You are under no statutory or contractual obligation to provide your Personal Data to EiE. However, if you do not provide the necessary information through the school, we will not be able to allow your access or use of the FFI web platform.

Data Protection Laws and the Children Act 2004

In order to comply with Data Protection Laws, EiE needs a lawful basis to process your Personal Data. We use the following lawful reasons to obtain and use your Personal Data:

Consent
Use of the FFI platform by yourself as a member of school staff, as a pupil or student (with written parental consent if under the age of 13 years), or as a parent / Supporter to a child; will require your written consent to the school. Where you have provided your consent, EiE will process your Personal Data for the purposes identified below:

Contract

In becoming a registered user of the FFI web platform, you enter into an agreement with the school for the purpose of using the FFI web platform. Following the end of your membership, we will retain your personal information for a period of 3 months. Thereafter, all information will be deleted.

You can obtain a download of all information / comments relating to the pupil / student that has been uploaded to the platform by contacting the school with your request in writing.

Exemptions

Statutory Exemptions apply and relate to situations relating to the protection of children from criminal acts and related Child Safeguarding issues.

Your Rights

You have a number of legal rights to control what we do with your information. For example, you can ask us to tell you what information we have about you and get a copy of it; correct or update information that is incorrect; or, stop using your information in certain circumstances. Please note that where you request us to stop using your information, we may not be able to allow your continued access or use of the FFI web platform.

Complaints

If you are unhappy with how your Personal Data is processed by EiE, you have the right to complain through the contact details provided above. We hope that we can resolve any complaints but if you remain unhappy, you have the right to lodge a further compliant with The Information Commissioners Office (ICO). The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow Cheshire, SK9 5AF. You can also contact them by telephone on 01625 545 745 or via their website at www.ico.org.uk.

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