Privacy and data protection

All personal data we handle is processed and stored within the UK or European Economic Area or under equivalent adequacy arrangements approved by the European Commission, unless you have consented otherwise.

Wonde is a secure service that enables you to control access to your data and revoke it at any time. Use of Wonde allows us to avoid the need for unsecure file sharing mechanisms such as email, and means that you are in control of the data you share, with the ability to remove access at any point. Although Wonde processes personal data, ImpactEd staff will only be able to view data in an anonymised format unless you grant us access to view personal data (for example, to solve a technical issue). More details on Wonde’s security procedures are available here.

If you are using Wonde to share data with ImpactEd, you can accept or withdraw our access to your school’s data as a whole at any time through the Wonde portal.

In addition, Wonde provides you with options to control access to specific datapoints. Some data permissions (such as pupil year group) we require for the ImpactEd platform to function. These are marked as required. Other permissions which are required for some projects but not others are marked as optional, and your school can choose whether these are shared or not. We will advise the data contact within your school if these optional permissions are required.

Finally, if there is a particular pupil that you are not able to share data for, they can be marked within Wonde and data will not be processed for that pupil.

Whether we are a data controller or processor can depend on the specific project orpartnership. In the vast majority of our partnerships, we are the data processor withthe data controller being the school or education organisation that we are workingwith. This means that our use of personal data is restricted to the purposes the data controller instructs us to fulfil. If you are unsure of the data processing relationship for your partnership with ImpactEd, please contact us at support@impacted.org.uk.

We do not share personal data for commercial purposes. We have a small number of authorised subprocessors that we use to assist us in delivering projects (for example, our email service providers). Typically no sensitive data is shared with any of these providers. These subprocessors are held to the same data protection standards that we hold ourselves to. Further details are provided in our example Platform Data Sharing Agreement.

Where we are the data processor and you are the data controller, it is your responsibility to decide on the grounds you will use for processing. The most common grounds used by our partners are ‘Public Task’ (in the case of schools and other public bodies), legitimate interests or contractual obligation. If you use these reasons for processing, collecting parental or pupil consent is not necessarily required.

ImpactEd takes privacy and security very seriously. We are Cyber Essentials Plus certified and registered with the ICO (number: ZB373629). All data we process is transferred through encrypted mechanisms and we anonymise data by default where personal data access is not required. If personal data access is required, this is on an ‘as needed’ basis and for a fixed time period only until data can be anonymised.

Further details are provided on our privacy page and in our example platform Data Sharing Agreement.

This can vary by the type of partnership and details will be provided in any data sharing or contractual agreements. Typically for school subscriptions we retain personal data only for the course of a subscription; following the end of a subscription all data is fully anonymised and retained for research purposes. For partnerships with education organisations, personal data is typically retained for six months following the end of a project and then fully anonymised.

We have automated and encrypted backups on the ImpactEd platform, keeping at least a month of retrospective data (by day and week), guarding against unintentional data destruction. We also keep a rolling internal audit log which allows for inspection of data flows and actions. Our cloud service providers also have multiple redundancies and failsafes to guard against any outage periods. In the event of any service outage, we will contact any affected parties directly with any mitigations and solutions. We also have a business continuity plan which covers arrangements in the event of systems failure.

This is managed through your Wonde portal, through which you can approve or remove access to data at any time. All data sharing which is required for the platform to work is marked as a core permission in Wonde, so is accepted when you accept the Wonde request. Any data sharing which varies by project are marked as "optional" permissions in Wonde so you can accept or reject these on a field by field basis. When we set you up we will provide guidance on which of those to accept/reject. As with all our data access, this access can be removed at any time through the Wonde portal.

All data comes directly from your school Management Information System and is updated every 24 hours. So provided the records in your MIS are accurate this data should always present the most up to date and accurate record of any information.

We have access controls in place on the ImpactEd platform to limit access to personal data. School users will typically have access to unanonymised data for all pupils in the school as they would in their MIS. This is to enable schools to analyse data at a whole-school level, look at results for individual pupils, or to select the pupils who are participating in a particular intervention.

Unless we have specified otherwise, ImpactEd will not access this personal data. We have technical access controls in place such that potentially identifying information is suppressed and not available to ImpactEd users. The exception to this is where ImpactEd access to personal data is required for purposes of evaluation delivery or to solve a technical issue, in which case the relevant subscriber is asked to grant access and our usage of personal data ceases once the issue is resolved.
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Where you are using the ImpactEd platform to share data with a third party (e.g. a charity who supports some of your students), this data will be shared on the basis you have agreed with them (which could be in identifiable or anonymous format).

Yes. In the event of a parent or pupil requesting their data is not shared with Wonde or ImpactEd, you can use your Wonde dashboard to control access. To do this, the Wonde admin at your school should select ImpactEd on their Wonde dashboard and go to “Access Controls”. From there, they can select the filter method they require and then choose the pupils, teachers or contacts they wish to exclude/include.