Privacy Policy

Last modified: 1^st September 2020

Hyperspheric Solutions Ltd ("Hyperspheric"), the company behind the GO 4 Schools product, recognises that privacy is important. This Privacy Policy applies to the data held within the GO 4 Schools system and lets you know how any personal information is processed and used by us.

There is a separate Privacy Policy that covers information that is not held within the GO 4 Schools system.

Our procedures covering the storage and disclosure of your information are designed to comply with the Data Protection Act 2018, the Applied General Data Protection Regulation 2018/EU679 (GDPR) and all other regulations applying to personal data use.

Our Privacy Principles

Hyperspheric is committed to safeguarding the privacy of your information. By 'your information' we mean any information about you that you or third parties provide to us.

• We will be transparent in our dealings with you and will tell you about how we collect and use your information.
• We will collect and use your information only as instructed by the Data Controller.
• We will continue to review and assess the quality of our information.
• We will implement and adhere to information retention policies relating to your information and will ensure that your information is securely disposed of at the end of the appropriate retention period.
• We will observe the rights granted to you under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are promptly and transparently dealt with.
• We will train our staff on their privacy obligations.
• We will ensure we have appropriate physical and technological security measures to protect your information regardless of where it's held, complying with Article 28.

The categories of data we process

Under instruction from the data controller, we process:

• Personal details.
• Family details.
• Lifestyle and social circumstances.
• Employment and education details.
• Under Article 9 of the DPA 2018 we will only collect and use special categories of data under instruction from the Data Controller who will use this information to fulfil their public duty. This processing is purely under Article 28 of the DPA.

Data we collect

As instructed by the Data Controller, to ensure the technical functioning and security of the processing as we perform for the Data Controller, and to improve the processing over time, we may collect the following types of information:

• Your communication preferences, to help us provide tailored and relevant communications.
• Cookies - When you visit GO 4 Schools, we send one or more cookies - a small file containing a string of characters - to your computer or other device that uniquely identifies your browser. We use cookies to improve the quality of our service, including for storing user preferences, and tracking user trends.
• Log information - When you access GO 4 Schools, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web requests, pages you visit, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
• User communications - When you send email or other communications related to GO 4 Schools, we may retain those communications in order to process your enquiries, respond to your requests and improve our services.
• Links - GO 4 Schools may present hyperlinks in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our product.

Use of cookies by GO 4 Schools

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

The table below explains the cookies we use and why.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout

How we process data

The GO 4 Schools system processes data provided by Data Controllers to allow them to:

• Make data about a student available to the student and their parents/guardians to support the student's education.
• Make data about students available to school/academy staff to help them support students' education and to work more efficiently.
• Make aggregated data about students (containing no user-identifiable data) available to their Governing Bodies and/or Multi-Academy Trusts to help them support students' education.

We will also use anonymised data (containing no user-identifiable information) for:

• Producing statistical analyses to help us improve our service and to support schools and academies by helping them fulfil their public duties more effectively.
• Producing information about GO 4 Schools for prospective customers and for Data Controllers who want to share information about GO 4 Schools with their staff, students, parents of students, etc.

The basis on which data is processed

• Hyperspheric acts as a Data Processor and the school/academy transferring data to us acts as a Data Controller.
• The Data Controller has a legal basis for processing your data. You should refer to the Privacy Policy of your school/academy for details.

Disclosure of your information

We will not share, sell or distribute any of the information you provide to us without instruction from the Data Controller, except where disclosure is:

• Necessary to enforce our rights, including under the GO 4 Schools Terms and Conditions.
• Necessary to enforce our rights under any other Terms and Conditions.
• Required or permitted by law.

Specifically:

• Sub-processors - Hyperspheric will not sub-contract any processing to third parties without the school/academy's written consent.
• Cross-border transfers - Hyperspheric does not transfer data outside the European Economic Area (EEA) unless the data is being accessed by a GO 4 Schools user outside the EEA.

If Hyperspheric becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

Information security

We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorised access to systems where we store personal data.

We restrict access to personal information to Hyperspheric employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data retention

If a school ends their GO 4 Schools subscription, data held within the live system will be:

• Anonymised within four weeks of cancellation.
• Deleted within sixteen weeks of cancellation.

Backups of data containing user-identifiable information will be deleted within 6 months.

Your rights

The General Data Protection Regulation (GDPR) outlines several rights. More information about these rights, including the conditions under which they apply, can be found here.

You have the right to:

• Ask for access to, or rectification or erasure of your data.
• Restrict processing (pending correction or deletion).
• Object to communications or direct marketing.
• Lodge a complaint with the Information Commissioner's Office at https://ico.org.uk/concerns/

You should address such requests to your school/academy which acts as the Data Controller.

None of the data within the GO 4 Schools system is subject to the right for data portability.

GO 4 Schools does not carry out any profiling or automated decision making with a "legal or similarly significant effect"

Questions and complaints

Hyperspheric regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or Hyperspheric's treatment of personal information by contacting us through this web site or by writing to us at:

Hyperspheric Solutions Ltd
Compass House
Vision Park
Chivers Way
Histon
Cambridge CB24 9AD

When we receive formal written complaints at this address, it is Hyperspheric's policy to contact the complainant regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Hyperspheric and an individual.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). Each version of this Privacy Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy Policy in an archive for your review.

• 2020-09-01
• 2020-01-01
• 2019-04-29
• 2019-01-15
• 2015-04-24