Legal
Privacy Policy
Who we are
Atlas Learning ("Atlas Learning", "we", "us") is a general partnership that provides tutoring services. We match students with tutors and arrange tuition online and in person.
Atlas Learning is the data controller for the personal data that we collect and use for our own purposes.
Business address: 15 Breydon Gardens
ICO registration number: [to be added]
Data protection contact: contact@atlas-learning.co.uk
Whose data we handle
We may handle personal data relating to:
- Students — children and adults who receive tuition
- Parents and guardians — people who enquire about or arrange tuition for a child
- Adult learners — students aged 18 or over who arrange tuition themselves
- Tutor applicants and tutors — people who apply to teach with us and people we engage as independent tutors
- Website visitors — people who use this website
What we store about students
We collect information that we need to respond to enquiries and arrange tuition. Not every item below applies to every student.
| Category | Specific items | Where it comes from |
|---|---|---|
| Identity | Forename and surname | The enquiry or Find a Tutor form, completed by a parent, guardian or adult learner |
| Contact | Email address and phone number. For under-18s these will normally be a parent's or guardian's details | The enquiry or Find a Tutor form and follow-up correspondence |
| Relationship | Whether the person contacting us is the student, a parent or a guardian, and whether the student is an adult | The Find a Tutor form and follow-up correspondence |
| Address | Needed to finalise any contracts you may sign | Follow-up correspondence |
| Educational stage | Age, year group, key stage, GCSE or A-Level | The Find a Tutor form and follow-up correspondence |
| Subjects | Subjects and qualifications being studied | The Find a Tutor form and follow-up correspondence |
| Requirements | Number of lessons requested, preferred format, and availability | The Find a Tutor form and follow-up correspondence |
| Educational information | Current or target grades, exam board, areas of difficulty and other information provided about the student's studies | The Find a Tutor form and follow-up correspondence |
| Tuition arrangements | The tutor assigned, lesson arrangements and information needed to organise tuition | Created by Atlas Learning |
| Attendance | Lesson dates and attendance records where these are needed to manage tuition and tutor payment | Created by Atlas Learning or the tutor and provided to Atlas Learning |
| Progress information | Progress notes or feedback provided to Atlas Learning where needed to support the tuition service | Created by the tutor and provided to Atlas Learning |
| Correspondence | Emails, messages and relevant notes of telephone conversations with Atlas Learning | You, the tutor or us |
| Accessibility and learning needs | Information about disability, SEND, health or exam access arrangements where this is provided to us and is relevant to tuition | Provided voluntarily |
| Safeguarding records | Information about a safeguarding concern, what was recorded and any action taken | Created if a safeguarding concern arises |
Where it lives. Information submitted through our website forms is stored in our private content management system. We also keep relevant correspondence in our business email accounts and may keep business records such as payment information in our banking records.
Who can see it. Access to the CMS is limited to authorised Atlas personnel. Tutors are given the information they need to teach the students assigned to them.
What we do not normally collect
We do not need or ask for the following as part of our ordinary tutoring service:
- Payment card details. We do not take card payments.
- School or exam-board login details. We do not need passwords or access to a student's school systems.
- Lesson recordings or photographs. We do not routinely record lessons or keep photographs of students. We will ask separately for consent where we wish to collect or use these for an additional purpose.
- Advertising profiles. We do not sell personal data or use student information to build advertising profiles.
Our website forms are intended to be completed by an adult. We do not ask children to provide unnecessary personal information through the website.
What we store about adults
Parents, guardians and adult learners: name, contact details, the content of your enquiry and correspondence, details of the tuition arrangement, and records of payments made to Atlas Learning. Our payment records will normally show the name on the bank account from which a payment was received, the amount and the date.
Tutor applicants: name, email, phone number, subjects and stages offered, qualifications and information provided as part of the application. If an application progresses, we may also hold interview notes, references, evidence of qualifications and information needed for safeguarding and recruitment checks.
Tutors: we may hold contact details, qualification and safeguarding information, records relating to the tutoring arrangement, attendance and progress information supplied to us, records of payments and information needed to manage access to Atlas systems.
Our lawful bases
| Purpose | Lawful basis (UK GDPR Article 6) |
|---|---|
| Responding to an enquiry before any agreement exists | Legitimate interests, where responding is necessary and reasonably expected |
| Matching a student with a tutor and arranging tuition | Contract, where the processing is necessary to provide the agreed service |
| Managing tuition, including attendance and progress information provided to us | Contract, where the processing is necessary to provide and manage the agreed service |
| Recording payments and keeping financial records | Contract and, where applicable, legal obligation |
| Considering tutor applications | Legitimate interests and, where applicable, taking steps before entering into a contract |
| Safeguarding and responding to safeguarding concerns | Legitimate interests and, where applicable, legal obligation or another lawful basis that applies to the particular circumstances |
| Non-essential cookies and similar technologies | Consent, where consent is required |
| Website and system security | Legitimate interests and, where applicable, legal obligation |
Where we rely on legitimate interests, we consider whether the processing is necessary for our legitimate interests and whether those interests are outweighed by the individual's rights and freedoms.
Children and consent
We provide tuition to children as well as adults. We take particular care with children's personal data and aim to collect only information that we need.
A parent or guardian may provide information about a child when arranging tuition. This does not mean that the parent or guardian automatically has all of the child's data protection rights.
Children have their own data protection rights. Whether a child can exercise a particular right themselves depends on their age, maturity, understanding and the circumstances of the request.
Where a parent or another person asks us to exercise a child's rights on their behalf, we will consider the circumstances and the child's rights and best interests before deciding how to respond.
Special category data
Some information about a student may be special category data under the UK GDPR. This can include certain information about health or disability.
We do not ask families to provide this information unless it is relevant to the service. A parent, guardian or student may choose to tell us about a disability, SEND, health condition or exam access arrangement where this will help us arrange appropriate tuition.
Where we process special category data, we need both an Article 6 lawful basis and an applicable condition under Article 9 of the UK GDPR.
Where we rely on explicit consent, we will explain what we are asking to use the information for and consent can be withdrawn at any time.
Information about a student that is shared directly with a tutor and is not provided to Atlas Learning may not be held by Atlas Learning and may instead be processed by the tutor in accordance with their own professional and data protection responsibilities.
Safeguarding records
If a safeguarding concern arises, we may record information about the concern and any action taken.
Access to safeguarding information will be restricted to people who need it.
Where necessary to protect a child or another person, we may share information with an appropriate organisation, such as children's social care, the police or a school's designated safeguarding lead.
We may share information without consent where the law allows or requires us to do so. We will not normally delay a necessary safeguarding disclosure in order to obtain consent where doing so could increase the risk of harm or interfere with an investigation.
Safeguarding information may be retained for longer than ordinary tuition records where this is necessary for safeguarding, legal or other lawful purposes.
Our approach is set out on the Safeguarding page.
Whom we share data with
We do not sell personal data or share it with other organisations for their own marketing.
We may share personal data with:
- The tutor providing tuition — information they need to arrange and provide tuition
- Our CMS or website hosting provider — where a third party provides the server or other infrastructure on which our website or CMS operates
- Our email provider — through which our business correspondence is sent and received
- Our bank — where necessary to receive and reconcile payments made to Atlas Learning
- The organisation handling DBS applications — where necessary for tutor safeguarding and recruitment checks
- Authorities and regulators — where disclosure is required or permitted by law
- Other organisations — where necessary to protect someone from harm or to establish, exercise or defend legal claims
Where an organisation acts as our processor, we will have an appropriate written contract with it and require it to process personal data only for authorised purposes and in accordance with our instructions.
Some organisations may instead be independent controllers for particular processing because they have their own legal or regulatory responsibilities. Their own privacy information will apply to that processing.
Tutors and personal data
Our tutors are independent contractors rather than employees of Atlas Learning.
Where a tutor processes student personal data on behalf of Atlas Learning and in accordance with Atlas Learning's instructions, Atlas Learning is the data controller for that processing and the tutor acts as a processor.
Tutors are required to keep student information confidential and to follow Atlas Learning's data protection and safeguarding requirements.
Tutors may use their own devices and communication services, including email or WhatsApp, to communicate with students and parents as part of providing tuition. Information that a tutor receives directly from a parent or student and that Atlas Learning does not receive may be held separately from Atlas Learning's records.
Tutors may also keep their own teaching notes where necessary to provide tuition. They must keep this information secure, use it only for legitimate purposes connected with their tutoring, and delete or securely dispose of it when they no longer have a reason to keep it.
Tutors must not use information obtained through Atlas Learning to build their own marketing lists or use Atlas Learning's student information for unrelated purposes.
Our agreements with tutors set out their confidentiality, data protection and safeguarding obligations.
How long we keep it
We do not keep personal data indefinitely. We set retention periods according to why we need the information, legal and regulatory requirements, safeguarding considerations and the need to establish, exercise or defend legal claims.
| Record | Kept for |
|---|---|
| Enquiry that does not lead to tuition | Normally 12 months from the last contact |
| Student information used to arrange tuition | For the duration of the tuition arrangement and afterwards where reasonably necessary for complaints, disputes, safeguarding or legal claims |
| Attendance and progress records provided to Atlas Learning | For the duration of the tuition arrangement and afterwards where reasonably necessary for complaints, disputes, safeguarding or legal claims |
| Correspondence relating to tuition | Normally for the duration of tuition and afterwards where reasonably necessary for complaints, disputes, legal claims or another lawful purpose |
| Bank and payment records | For the period required by applicable tax and financial record-keeping requirements |
| Special category data provided to Atlas Learning | For as long as it is needed for the purpose for which it was collected and afterwards only where there is another lawful reason to keep it |
| Safeguarding records | For as long as reasonably necessary for the safeguarding, legal or other lawful purpose |
| Unsuccessful tutor applications | Normally 12 months after the application is closed, so that we can deal with any queries about the recruitment process and, where appropriate, consider the applicant for future opportunities. |
| Tutor records | For the duration of the tutoring arrangement and afterwards where reasonably necessary for legal, safeguarding, financial or other lawful purposes |
| DBS certificate information | We do not normally retain a copy of a DBS certificate. Where information from a certificate must be retained, it is kept only for as long as necessary for the relevant recruitment, safeguarding, complaint or audit purpose |
| Server-side technical logs | 90 days, where such logs are actually collected |
We review our retention periods and delete or securely dispose of personal data when we no longer have a lawful reason to keep it.
Information held in backups may remain until the relevant backup is overwritten in the normal course of our backup process.
Where your data is held
Our website, CMS and other business systems may use servers or services located in the UK or elsewhere.
Where personal data is transferred outside the UK, we will use an appropriate lawful transfer mechanism and the safeguards required by UK data protection law.
Information about the relevant transfer safeguards can be requested from us.
How we protect it
We use appropriate technical and organisational measures to protect personal data from unauthorised access, loss, alteration or disclosure.
These measures include:
- Individual accounts rather than shared logins where our systems support them
- Access limited according to a person's role
- Password and authentication controls
- Appropriate security measures for data stored and transmitted by our systems
- Regular backups where available
- Restricted administrative access
- Removal or adjustment of access when a person no longer needs it
Tutors are also required to follow our confidentiality, data protection and safeguarding requirements.
No online system can be guaranteed to be completely secure. If we become aware of a personal data breach, we will assess it and notify the ICO and affected individuals where the law requires us to do so.
Your rights
Depending on the circumstances and the lawful basis we rely on, you may have the right to:
- Be informed about how we use your personal data
- Access the personal data we hold about you and receive a copy
- Rectify inaccurate or incomplete personal data
- Erase personal data where the law requires or permits this
- Restrict how we process personal data in certain circumstances
- Object to processing where the law gives you that right
- Data portability where the right applies
- Withdraw consent at any time where we rely on consent
These rights are subject to legal exceptions. For example, we may need to retain information to comply with a legal obligation or to establish, exercise or defend a legal claim.
The right to object. Where we rely on legitimate interests as our lawful basis, you have the right to object to that processing. We will consider the objection and will stop the processing unless we have a compelling reason to continue that overrides your rights and interests, or the information is needed for legal claims.
How to exercise your rights. Email contact@atlas-learning.co.uk. Tell us what you are asking for and, where you are making a request on behalf of someone else, explain your relationship to that person. We may ask for information reasonably necessary to verify your identity or authority to make the request.
We normally respond within one calendar month. Where the law allows us to extend this period, we will tell you within the first month.
Automated decisions and profiling
We do not make decisions about students or tutors using solely automated processing that produces legal or similarly significant effects.
We do not use profiling to make decisions of this kind. Tutor matching is carried out by people.
Cookies and website analytics
Full detail is in our Cookie Policy.
Our website uses cookies and similar technologies for website operation and, where applicable, analytics. Where consent is required for a particular technology, we will ask for it.
The details of the cookies and analytics technologies we use are set out in the Cookie Policy. We will update that policy when the systems we use change.
Complaints
If you are unhappy with the way we have handled your personal data, please contact us first at contact@atlas-learning.co.uk.
We will look into the complaint and try to resolve it.
You also have the right to complain to the Information Commissioner's Office, the UK's data protection regulator:
- Website: ico.org.uk/make-a-complaint
- Helpline: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Changes to this policy
We may update this policy when our services, systems or legal obligations change.
The current version will be published on this website with the date of the latest update.
Where a change materially affects how we use personal data, we will update this policy and take reasonable steps to bring the change to the attention of people affected before the new processing starts where required.