Last Updated: 21/05/2018
Collection and Use of Personal Information
1. The Data we Collect:
Get My Grades will collect the following pieces of data:
- When you create your profile Get My Grades will collect data to personalize your profile, including your title, name, mailing address, email address, contact preferences and payment method/ status.
- Get My Grades allows individuals the option to further personalize their profiles by offering them the option to add pictures to their profiles.
- Get My Grades will collect sensitive personal information on individuals including race, gender and ethnic background. Individuals have the option to opt in or out of sharing this information with us.
- When you use the Get My Grades platform, we will collect data on your academic attainment and performance.
- When you create additional profiles that link to your account, we may collect information on those people such as the title, name, mailing address, email address, phone number, contact preferences.
- In certain situations, Get My Grades may ask for and collect details on your SEND (Special Educational Needs and Disabilities), EAL (English as an Additional Language) and FSM (Free School Meals) status.
- We collect information on how you use the site such as your IP Address, location and which version of web browser you use by using cookies and page tagging techniques.
2. How We Use Data:
The personal data that we collect is used for a host of reasons, in line with our legitimate interest and the interests of the individual, including their rights and freedoms. The data is used in the following ways:
- The personal information we collect is used to identify and personalise the individual’s user account so that the individuals can use the platform effectively.
- The personal information allows us to keep the individual posted on Get My Grades’ latest announcements, updates and upcoming events. If you do not want to be part of this mailing list you can unsubscribe via emails or update your preferences.
- We may use personal and or sensitive information to conduct internal research, used to maintain, improve and develop our system, including how it decides what content to present to users, which assignments it recommends or any other feature.
- We will collect data on your academic attainment, history and performance. This will be used with our algorithms and software to provide the best service possible to the individual. This includes setting the skill level of questions, suggesting concept pages to learn or other assignments to complete at the appropriate times.
- We will use the data from your linked accounts to provide information on the progress of the user’s account.
- We will use the personal information to communicate about purchases and changes to subscriptions, terms and conditions, contracts, and policies. This is vital to the effective operation of the platform, to provide evidence of purchases and to maintain clarity on the basis upon which services are being provided.
- We may use your personal information for internal purposes such as auditing, data analysis, the design or delivery of services and customer communications.
- Your personal information may be used for external research with our research partners (that we work with from time to time). If your data is used, it will be anonymised and we will ensure that it is not possible for it to be traced back to the individual or used to identify any user individually (unless you otherwise give your consent for us to provide data that is personally identifiable).
- We may collect information regarding customer activities, IP address, location and which version of the browser you’re using. This information is collected to help us provide more useful information to our customers and to understand which parts of our website or platform are of most interest. This will help us to improve the user experience of our website and platform (or any other service we may provide, whether paid for or not).
- We may collect details of queries you have about our products. This will allow us to easily and effectively answer future questions or make improvements to our platform, following consumer feedback on our product and services. We may use your questions or queries for marketing, customer support, employee training or research but we will ensure that they are anonymised and cannot be used to identify any person individually if they are going to be made publicly available or released to a third party other than those that would already have access under a different provision of this agreement.
3. The Collection of Data:
Get My Grades will collect data in a variety of ways. We collect the majority of data through user entry, that is data that users enter onto our platform themselves. This refers to any personal information that is needed to generate a profile for the user or other information that the user elects to provide to us. Any sensitive personal information will need to be entered by the user and they will have the choice to indicate a preference not to provide such information where an entry is required. We will also collect data autonomously through the aggregate of attainment outcomes from answered questions and previously covered concepts.
We may also gain personal information through other data controllers such as institutions, academies, schools, tuition agencies, research organisations and other third-party organisations. This sharing of data will be permitted through our own legitimate interest and the data controllers lawful basis for processing data. If we are provided data for which we believe we have no legitimate interest to process, or where we suspect, with good cause, that it has been obtained by non-compliant means, we will delete this data from our systems or anonymise it effectively so that it can no longer be used to identify any individual person.
We will also collect data through cookies, these provide us with information that will inform us of details on how individuals use our website and where they are located.
4. How We Disclose Data:
Get My Grades will only disclose your personal data with other parties for whom users have given us permission (or we reasonably believe that they have given permission) or to those users who are legitimately linked with the individual directly or indirectly via our platform. This could be a tutor/ tuition agency (or other provider) and/ or a school, academy or similar organisation. In the course of our business, we may use sub-processors to process personal data on our behalf in accordance with our instructions and this policy. Data will be protected by industry standard data security measures and staff with access to such data will be provided with relevant and appropriate training. We will not sell or rent personal data to marketers or unaffiliated third parties without good cause.
We may disclose any personal data to any public body (such as the police or local authorities) where we believe there is a legitimate public interest to do so, such as the prevention, detection or prosecution of criminal offences, to safeguard children or young people or for any other reason where there is deemed to be an overriding public interest.
We may disclose your data to any research partners (such as universities or other organisations that provide relevant services) that we may work with from time to time. Unless you specifically give your consent, this data will be anonymised, which means that individuals will not be able to be identified by the data. The data will be protected by our security measures, as described in Section 7, and we will provide training to our own members of staff that have access to such data.
5. Where Data is Stored:
We store your data on secure servers in the Europeans Economic Area (EEA), however, in the course of providing our services we may send data outside the EEA, with appropriate checks and security measures, to ensure the resilience of our platform and to improve the reliability of the service we offer. This data will be stored here for up to two years after the deactivation of your account (or until you exercise your right to erasure). This is to enable individuals to open their account after they close it and to restore their personal and academic data on our system. After the two year period ends after the deactivation of your account, we will erase all personal and supplementary data from your account and our servers. If you would like this data to be erased before this time period, follow the instructions in Section (6), subsection (D), or if you would like to obtain and re-use this data please follow the instructions in Section (6), subsection (F).
6. Access and Choice (including rights of data subjects):
Get My Grades takes your privacy and security very seriously, for this reason we have outlined your individual rights to your data that we store and process. The following eight sub-sections are set to show you exactly what rights and freedoms you have to your data in accordance with the General Data Protection Regulation. If at any point you would like to receive further details on your access to your data, or just to access the data, feel free to follow the details outlined in Section 12.
If you seek to exercise any of the rights included below, we will require that you notify us in writing and may require verification of your identity to prevent the unauthorised disclosure or deletion of data. This is important as data can be valuable and difficult to restore and we need to be sure of the identity of the individual making the request in order to prevent its unlawful disclosure or deletion against the best interests of the data subject.
At any point, we may provide features or tools to enable you to exercise any or all of the rights outlined below. If this is the case, we may ask that you use these tools in order to exercise your rights rather than contacting us directly, although we will still be happy to confirm whether or not you have successfully exercised your right if you require clarification which is not otherwise available to you.
A. Right to be informed
B. Right of access
Individuals have the right to access their personal data and supplementary information stored and processed by Get My Grades. This includes the right to know and confirm the data that we are processing on individuals, access to this personal data and any other additional supplementary information. Get My Grades will provide a copy of the data it processes and stores on individuals, which will be free of charge for the first (1st) copy. However, we may charge a reasonable fee when the request is:
- Manifestly unfounded,
This information will be provided as soon as possible from Get My Grades, however, depending on circumstances this may take up to 20 working days. Get My Grades reserves the right to ask the individual to specify the information that they have requested, depending on the size of the quantity of information we have on a individual. If you would like to access the personal or supplementary data Get My Grades holds on you, please email email@example.com.
C. Right to rectification
Individuals have the rights to have their personal data rectified if it is inaccurate or incomplete. If the personal data we hold on an individual is inaccurate or incomplete, Get My Grades will rectify the information as soon as possible after we become aware of such an inaccuracy. In some cases where it is not possible, Get My Grades will rectify the information within 20 working days of a request. You can contact us by emailing: firstname.lastname@example.org.
In many cases, individuals will have the ability to rectify incorrect information themselves via the appropriate tools or functions made available by our platform. If we have provided a feature for you to edit the data we hold on you, we may ask you to rectify any inaccuracies or omissions yourself using these features.
D. Right to erasure
The right to erasure or right to be forgotten allows an individual to request for their data to be permanently deleted from our system, if there is no compelling reason for its continued processing. Get My Grades will permanently delete the personal and supplementary data held on consumers within two (2) years after they have stopped their subscription. This is for internal research and development and also for the ease of consumers who return to our platform and would like their accounts restored.
Individuals can request to erase their personal and supplementary data and to prevent the processing of the data before the expiry of the two year period, however, this will rely on one of the specific circumstances below:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- When the individual withdraws consent.
- When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
- The personal data was unlawfully processed (i.e., otherwise in breach of the GDPR).
- The personal data has to be erased in order to comply with a legal obligation.
- The personal data is processed in relation to the offer of information society services to a child.
If at any point we have disclosed the personal or supplementary data to other organisations, we will contact and inform them of the erasure of the personal data, and inform the individual of these recipients if asked to do so. We will also inform the organisations that they also erase links to, copies or replications of any personal data.
Get My Grades takes the storage and processing of your data very seriously, if at any point an individual feels that they want us to delete the personal and supplementary data on an individual and the reasoning behind this corresponds to one or more of the reasons above, we will permanently delete your data within 7 working days. If you would like to erase the personal or supplementary data Get My Grades holds on you, please email email@example.com
E. Right to restrict processing
Individuals have the right to suppress the processing of personal data, this means that Get My Grades can store the information but can no longer process the information until the restrictions have been lifted. Individuals can request to restrict the processing when, one of the following circumstances apply:
- Where an individual contests the accuracy of the personal data, data controllers/ processors should restrict the processing until they have verified the accuracy of the personal data.
- Where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our legitimate grounds override those of the individual.
- When processing is unlawful and the individual opposes erasure and requests restriction instead.
- If we no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim.
If one of these circumstances apply, Get My Grades will stop processing this data as soon as possible or within 5 working days. We will also inform any party or organisation, of the restrictions to the individual’s personal data and if asked to we will inform the individuals about these recipients. We will also inform the individuals when we decide to lift the restrictions and as to why we have lifted the restriction.
F. Right to data portability
Individuals have the right to obtain and re-use their personal data for their own purposes. Get My Grades will provide this data if requested, in a structured, commonly used and machine readable form. We will provide this information without undue delay but it may take up to 20 working days. Users should be mindful of this and make requests in good time and inform us if they require the data in advance of an important deadline.
G. Right to object
Get My Grades processes data on the lawful basis of a legitimate interest, this means that if you think that our legitimate interest in processing data, as found in Section 9, violates your own individual rights or freedoms of the individual you can object to this data being processed. Individual must have “grounds relating to his or her particular situation” in order to exercise their right to object to processing.
If an individual has an objection to Get My Grades processing your data, you must email us the objection at firstname.lastname@example.org, we will stop processing your data with undue delay and respond to your objection explicitly and present our legitimate interest in a clear manner.
H. Rights related to automated decision making including profiling
Get My Grades will only carry out automated decision making to automatically set questions or recommend subjects to an individual. This automated decision making will be based on the history of your academic progress or attainment, not the personal or sensitive personal data you enter into our platform. This automated decision making is designed to help the individual to learn more effectively or make more progress in an academic subject or discipline that we offer services for. If we ever use your data in the sense of profiling, the data will be completely anonymised to reduce the personal impact this could have on the individual. We have created the appropriate safeguard and protections to protect the individuals rights, freedoms and interests. In almost all cases, automated decision making is used to suggest a course of action rather than to actually make and implement a decision without any human input.
If you would like to know more about are automated decision process or speak a member of our staff about the automated decision making, please email email@example.com.
I. Rights to lodge a complaint
Individuals have the right to lodge a complaint with a supervisory authority. Get My Grades takes the protection of your data very seriously, if you feel we have not protected your data efficiently, you have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office. You can lodge your complaint on there website through the following URL, https://ico.org.uk/concerns/.
7. Security and Protection of Data:
Get My Grades takes data security extremely seriously and we have a number of strategies, policies and measures to keep the data we hold secure. These include:
- Encryption of personal data at rest and in transit;
- Industry-standard technical measures to prevent unauthorised access (the full details of which are not public knowledge in order to increase the level of security afforded);
- Ensuring that only employees, contractors or third parties that have a lawful basis to access and process such data are provided with access;
- Appropriate requirements in all contracts with third parties to ensure the security of data where it is, or may become, accessible to such third parties for any reason whatsoever;
- Relevant training for employees that do (or may) have access to personal data;
- Comprehensive insurance (including cyber security cover) provided by a reputable and competent insurer;
- Internal processing policies to prevent the unauthorised transmission of data to third parties. This includes a bar on sending details via email without the explicit consent, in person from a senior manager, which will not be granted until we have positively verified the identity of the person making the request. Therefore, individuals should bear in mind that we will seek to verify their identity before meeting any request that they make and we may decline any request if we have good cause to doubt the identity of the person making such a request.
Data subjects (such as users of the platform that we provide) have a responsibility to act prudently at all times to keep their own data, and that of other users they are linked to, safe. Our Terms and Conditions state very clearly that users must keep their passwords confidential and secure and should not allow any other person to access their account for any reason. Get My Grades cannot accept any liability for the loss or theft of data arising due to the unauthorised access to a user’s account where the password has been obtained or guessed by an unauthorised third party.
You should ensure that you keep your account, and the password you use to access it, secure. If the personal data of other users is stolen or deleted by unauthorised access of your account that you could have prevented, then this may be treated as though the data was stolen or deleted by you and you may be held personally liable. You should contact us immediately by emailing: firstname.lastname@example.org if you believe that there has been a security breach, making this fact clear in the subject of your email. We may block activity on your account in such cases if we believe there is good cause to do so.
Get My Grades understands the importance taking extra precautions to protect the privacy and safety of children (those under the age of 13) using the Get My Grades platform. Children under the age of 13 are legally required to have parental consent given before they can set up an account; Get My Grades requires all students under the age of 18 to have parental consent in order to use our platform. The only details we will process before receiving parental consent are a child’s first name and the email address of their parent or guardian. This will be used to send an email to the parent or guardian on behalf of the child with instructions on how to provide the necessary consent and to set up the child’s user account. If an account is not set up by a parent or guardian within 14 days, then we will delete the email address and the child’s first name.
9. Legitimate Interest:
Get My Grades relies on a legitimate interest for it’s lawful basis of processing data. The legitimate interest being that for the Get My Grades product to function and benefit the consumer, it needs to process the personal data of individuals. Get My Grades processes personal data to create and track the consumers who use the product and the individuals linked to their account.
The tracking and processing of data allows the Get My Grades product to function and is in the best interests of the individual, their rights and their freedoms. This is in line with our lawful objective, outlined in the Get My Grades Terms and Conditions and any relevant contract, which is to provide an online educational platform that is adaptive to a students educational needs and has the facility to share data with other individuals or organisations as specified by the fee payer, in accordance with the instructions they supply through the use of our platform. This data will also be used to improve, maintain and develop the platform to give all customers the best experience when using the product.
10. Get My Grades as a Data Processor:
Get My Grades will act as a data processor when in contract with an institution. We will only process data inline with this contract and in no other way unless individual users request us to do so and there is a legal basis or obligation for us to act in such a manner. The data controllers are responsible for making sure that the customer’s privacy rights are respected and protected, including how data is disclosed to third parties not affiliated with Get My Grades. We will process data according to our own security and privacy policies, our Terms and Conditions and the users’ lawful instructions.