ThriveTrack Education is committed to protecting the personal information of children, young people, parents, carers, tutors, schools and other professionals who use or interact with our services.
This Privacy Notice explains what personal information we collect, why we use it, who we may share it with and the rights individuals have under UK data protection law.
1. Who we are
ThriveTrack Education provides tutoring, educational intervention, SEND support, assessment and related education services.
Where ThriveTrack Education determines how and why personal information is used, we act as the data controller.
For privacy enquiries, contact:
Email: hello@thrivetrackeducation.co.uk
Website: thrivetrackeducation.co.uk
Business address: Suite RA01, 195-197 Wood Street, London, E17 3NU
2. Information we may collect
Depending on the service requested or provided, we may collect:
- parent or carer names;
- child or young person's name and age;
- contact details;
- address information;
- school year group;
- subjects requiring support;
- educational needs and learning objectives;
- assessment information;
- session and progress records;
- attendance information;
- correspondence and enquiries;
- tutor and staff information;
- billing and payment information; and
- information supplied by schools, local authorities, parents, carers or other authorised professionals.
Where necessary, we may also process information relating to SEND, disability, health, communication requirements, behavioural needs or safeguarding concerns.
We aim to collect only information that is relevant and necessary for the service being provided.
3. Children's information
Many of our services involve children and young people.
We recognise that children's personal information requires particular protection.
Information about a child may be provided by a parent, carer, school, local authority or another authorised professional.
We use children's information only where there is an appropriate lawful basis and where it is relevant to the delivery, administration, safeguarding or improvement of our educational services.
4. Why we use personal information
We may use personal information to:
- respond to enquiries;
- understand a learner's educational needs;
- arrange tutoring or assessment;
- plan appropriate educational support;
- match learners with suitable tutors;
- deliver personalised teaching;
- monitor attendance, progress and outcomes;
- communicate with parents, carers, tutors, schools and local authorities;
- make appropriate reasonable adjustments;
- manage safeguarding concerns;
- manage bookings, payments and invoices;
- respond to complaints or service concerns;
- maintain appropriate business records;
- comply with legal and regulatory requirements; and
- improve our services.
5. Lawful bases
Depending on the circumstances, we may rely on one or more lawful bases under UK data protection law, including:
Contract — where information is required to provide a service or take steps before entering into a contract.
Legitimate interests — where processing is reasonably necessary to operate and improve our education services, communicate with clients, maintain records or protect our organisation and service users.
Legal obligation — where processing is required to comply with applicable law.
Consent — where we specifically ask for agreement to a particular use of information.
Vital interests — in exceptional circumstances where processing is necessary to protect someone's life or physical safety.
Where special category information is processed, such as certain health or disability information, an additional legal condition will also be required.
6. SEND and health-related information
Information about SEND, disability, health, communication needs or behavioural needs may be processed where it is relevant to providing suitable support.
This may be used to:
- plan appropriate teaching;
- make reasonable adjustments;
- identify educational or communication needs;
- understand relevant risks;
- support safeguarding;
- match learners with suitable tutors; or
- review the effectiveness of support.
Access to this information will be limited to people who reasonably require it for their role.
7. Who we may share information with
Where necessary and appropriate, information may be shared with:
- tutors and staff involved in delivering services;
- parents and carers;
- schools and colleges;
- local authorities;
- safeguarding professionals;
- statutory authorities;
- accountants, insurers and professional advisers;
- payment, IT, communications and website service providers; and
- regulatory, government or law-enforcement bodies where disclosure is legally required.
We do not sell personal information.
8. Safeguarding
If information raises a safeguarding concern, ThriveTrack Education may need to record and share relevant information with appropriate safeguarding professionals, local authorities, emergency services or statutory bodies.
In some circumstances, safeguarding or legal duties may mean that consent is not required before information is shared.
9. How long we keep information
Personal information will only be retained for as long as reasonably necessary for the purpose for which it was collected and to meet relevant safeguarding, contractual, accounting, insurance and legal requirements.
Different types of records may have different retention periods.
When information is no longer required, it will be securely deleted, anonymised or otherwise disposed of appropriately.
10. Website and enquiries
When someone contacts ThriveTrack Education through our website, email or another communication channel, we may collect:
- name;
- contact details;
- information contained in the enquiry; and
- information necessary for us to respond.
We use this information to understand the request, respond to the enquiry and, where appropriate, take steps towards providing a service. Website form submissions are saved in access-controlled ThriveTrack business enquiry records so that we can review and respond. Enquiry details are not displayed publicly on the website.
Users should avoid providing unnecessary sensitive or medical information through an initial website enquiry unless it is relevant to the support being requested.
11. Cookies and website technology
Our website may use cookies or similar technologies required for the site to operate.
If non-essential analytics, advertising or tracking technologies are introduced, we will provide appropriate information and, where required, obtain consent before those technologies are used.
12. Information security
We take reasonable organisational and technical measures to protect personal information against unauthorised access, loss, disclosure, alteration or misuse.
These measures may include:
- secure accounts and passwords;
- controlled access to information;
- secure business systems;
- appropriate confidentiality arrangements; and
- limiting access to people who reasonably need the information.
13. International transfers
Some technology providers may process or store information outside the United Kingdom.
Where personal information is transferred internationally, we will take appropriate steps to ensure that a lawful transfer mechanism or other appropriate safeguard is in place where required.
14. Your rights
Depending on the circumstances, individuals may have rights to:
- request access to their personal information;
- request correction of inaccurate information;
- request deletion of information in certain circumstances;
- request restriction of processing;
- object to certain types of processing;
- request transfer of information in certain circumstances; and
- withdraw consent where processing is based on consent.
These rights are not absolute and may depend on the circumstances and lawful basis being relied upon.
To exercise a data protection right, contact:
15. Complaints
If you have concerns about how ThriveTrack Education has handled personal information, please contact us first so that we can investigate.
You also have the right to raise a concern with the Information Commissioner's Office, the UK's data protection regulator.
Website: ico.org.uk
16. Changes to this Privacy Notice
We may update this Privacy Notice as our services, systems, suppliers or legal obligations change.
The latest version will be published on our website with the date of the most recent update.