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Privacy Statement

This statement underpins the policies, promises and contracts we make with schools relating to the education data that Assembly processes.

In conjunction with this document, you should read the Glossary of Terms used within this statement, and also elsewhere on our site.

What is Assembly?

Assembly is a secure, cloud-based platform that connects to your school’s Management Information System (MIS) and extracts key elements of your school’s data and stores it in a way that allows you to connect other applications to your data. These applications allow you to extend, analyse and aggregate data you collect and store in school.

Privacy and Data Protection Statement

1. Introduction

Privacy and security are at the heart of everything we do at Assembly. This statement explains the key measures we’ve put in place to ensure that a school’s data is kept secure and processed appropriately at all times. It also covers our commitments to you, and what we expect from schools in terms of privacy and data protection.

For further detail, please refer to our full Platform Terms of Service, which provide a full explanation of how we process and protect data as well as what we require from schools to agree to before deciding to use our service.

2. Our Principles

We:

  • Process the data received from schools for the purposes of education and school improvement only, and only for those purposes necessary to provide the service explicitly offered to schools
  • Adhere strictly to the terms of the Data Protection Act 1998 and any future amendments or applicable legislation
  • Only store and process the minimum data required to provide our services, and to inform you in advance of using any of our services what data that service requires.
  • Transport and store all personal data originating from schools using modern and best practice encryption technologies. This includes Secure Socket Layers (SSL/TLS) for encrypted data transfer over the internet, encryption of all data at rest, field-level encryption for personally identifiable data and password-protected identities for all end users
  • Comply with all Subject Access Requests made relating to the data We store
  • Only retain data for as long as required, and delete all your data if you ask us to do so, if you delete the connector or if your account becomes inactive.
  • Ensure that all data is held securely by taking steps so that data is not corrupted or lost
  • Ensure that all staff having access to personal data hold a valid Disclosure and Barring Service certificate
  • Always maintain adequate liability insurance
  • Audit our services against this pledge every 12 months and provide evidence of compliance to the other party whenever requested
  • Report any breaches of security to the tata controller, the Information Commissioner’s Office (ICO) and other authorities if required by law, and, in co-operation with the data controller, to data subjects
  • Always notify schools prior to connecting an Assembly application which data that Assembly application needs access to, and allow you to accept or reject that request
  • Make the Terms of Service and this Privacy Policy clearly and publicly available on our website

We DO NOT:

  • Store or transport personal or sensitive data outside of the EU or outside of countries which are granted to have Adequate Levels of Protection as defined by the European Commission
  • Share your data with any third parties except where explicitly requested by you or required by law.
  • Use Your data, made available via the Assembly platform, for the purposes of advertising or marketing, or for any purpose other than the service explicitly provided to You
  • Transport personal data originating from schools in an unencrypted format
  • Claim ownership or exclusive rights over any of the data processed or created as part of services provided to You
  • Share information with other third parties except where specifically agreed by the Data Controller or where required by law
  • Change any applicable terms of service without giving You the opportunity to opt-out of such changes

3. Security and Encryption

We take every reasonable measure to ensure we store data securely. The Assembly platform is developed using secure technologies, which include, but are not limited to the following:

  • All personal and sensitive Assembly data is stored and transported within EU or countries which are granted to have Adequate Levels of Protection as defined by the European Commission
  • All external data transmissions to and from the Assembly Platform are encrypted using modern SSL/TLS protocols and ciphers
  • Encryption at rest i.e. when stored on a disk or laptop
  • Field level encryption in our database, where we feel it necessary to do so
  • We use encrypted passwords with variable permissions according to the user’s role are used for access to all sensitive information
  • All servers are situated in secure locations that comply with the Data Protection Act 1998

4. Staff access to data

Assembly does not look ‘under the hood’ or inspect any of the data we store. The only exceptions to this are where a school has explicitly given us permission to inspect their data; for example, to provide technical support to correct a technical problem. This permission is given on an ‘as needed’ basis and the ability to access the data is revoked once the technical problem is resolved.

All our staff are required to agree that they will abide by the Security and Data Protection Policy at all times and sign a Confidentiality and Non-Disclosure Agreement. All staff and contractors are required to undergo an enhanced Disclosure and Barring Service (DBS) check. From time to time we do use contractors who are not in the EU. Where we do this we ensure that no data is stored or transported outside of the EU using appropriate and secure technologies.

5. Deleting and Retaining Data

We retain personal data on our platform for as long as necessary to provide the Assembly service. If a school deletes our connector, we will delete their personal data within 5 working days. We will also delete personal data if we detect that an account has been inactive for a significant amount of time.

6. Assembly and Third Party applications

We ask all Third Party Application Developers to sign up to our Third Party Developer Agreement.

Schools are responsible for accepting the terms and conditions of third party applications. We make these clearly available through the Assembly platform.

Before we allow Assembly and Third Party Applications to access school data, schools must authorise the requests to connect to their data and review the scopes and groups of data that an application is requesting. These permissions can be revoked at any time by the school. Where an application is requesting sensitive pupil data, this will be specifically highlighted and will require specific authorisation from the school.

7. Privacy or Security Breaches

We take all reasonable and necessary precautions to ensure that your data is secure and to recognise and then mitigate the risks to security and privacy. However, it is not possible to 100% guarantee the security of any data transmitted or stored electronically. In the event that a breach of security or privacy did occur, Assembly will contact Data Controller of the affected data, and inform the Information Commissioner’s Office (ICO), and other authorities, if required by law.

Information for students and parents

Assembly, as the Data Processor, only has access to pupil data as requested by the school, as Data Controller, and only for the purposes of performing services on a school’s behalf.

Your child’s school remains the Data Controller of any pupil data we process. If you have questions about your or your child’s data or how your school is making use of our service, please contact the school directly. Any pupil or parent/guardian enquiries we receive will be directed to the relevant school as the Data Controller for that child’s or parent’s/guardian’s data.

General Website Privacy

8. Cookies

A cookie is a string of information that a website stores on a visitor’s computer. Assembly uses cookies for purposes such as helping us to identify and track visitors’ usage and preferences. You can disable cookies in your browser if you wish to, although this may mean that some features of our website do not work as they should.

9. Communication

If you are a registered user of the Assembly website, or have expressed interest in Assembly on the Assembly website, and have supplied your email address, we may occasionally send you an email to tell you about new features, ask for feedback or keep you up to date with our products. If you no longer wish to be included on these communications, then please either use the unsubscribe link at the bottom of our emails, or email help@assembly.education and we will remove you from the list.

10. Third Party Websites

We cannot be responsible for the privacy policies and practices of other sites even if you access them using links on our website. We recommend that you check the policy of each site you visit and contact the owner or operator if you have any questions or concerns.

If you access our Website from a third party site, we cannot be responsible for the privacy policy and practice of that third party site and recommend that you check the policy of that third party site and contact the owner or operator if you have any questions or concerns.

Questions

If you have any questions or grievances in relation to security or privacy, please email us on hello@assembly.education