National Tutoring Programme & Privacy

Pearson Education Limited (Pearson) has been appointed as a Tuition Partner on the National Tutoring Programme (NTP) by the Education Endowment Foundation.

As a Tuition Partner, Pearson is responsible for the personal information it handles in order to deliver the NTP. That information, which is only used for delivering the NTP and for safeguarding purposes includes:

• Data for matching to National Pupil Database (NPD), including: name, date of birth, Unique Pupil Number (UPN)
• Background characteristics such as gender, ethnicity, socio-economic status and household proximity to school
• Information on pupil performance / attainment
• Special educational needs
• School attendance / exclusion
• Interactions with social services
• Reasons for programme eligibility
• Information about participation in the TP programme including attendance at tutoring sessions.
  

Pearson shares this responsibility with the Education Endowment Foundation (EEF), who are responsible for the overall delivery of the NTP, with the Department for Education, which commissioned it, with their chosen Evaluator for the NTP service and with schools, as they are responsible for commissioning the service on behalf of pupils.

Full details of Pearson’s approach to protecting your personal information are available below, but the short version of what we do with personal information in connection with the National Tutoring Programme (NTP) is:

• We only use the information we are entrusted with and which is developed in the course of someone accessing the NTP for the purpose of delivering the NTP service to schools and pupils, for improving that service and for safeguarding purposes;
• We do not share your information with anyone unless it is necessary to provide the NTP service or for safeguarding reasons and permitted by law (and will never sell it to anyone for any reason);
  We do not use any of the personal information collected in connection with the NTP for marketing purposes;
• We do not use the personal information we hold in connection with the NTP to profile pupils or tutors or permit anyone else to do so;
• We do not use the personal information we hold in connection with the NTP to profile pupils or tutors or permit anyone else to do so;
• All online tutoring sessions are recorded for safeguarding purpose for at least 6 months or until the end of the NTP (whichever is longer) and after that time has passed schools have the ability to delete those recordings and other information held in connection with their pupils; and
• We do not rely on machine learning or artificial intelligence to make significant decisions about pupils or their interaction with the NTP, but we do use it to provide you with a service which you can get the most out of by transcribing and indexing your tutoring sessions so that you can easily search them afterwards for specific sections or information.
  

Please note that we may use anonymised data which cannot be linked to you for research purposes and to improve our services, but will not be able to link that information to anyone who participates in the NPT.

You have the right to withdraw from the NTP at any time, to request access to information that we hold about, to correct any inaccurate or incomplete information, to request that information is deleted if it is no longer needed, to object to that processing or to ask that we restrict our processing of your personal information.

If you (or any parents) have questions about the way in which the NTP uses personal information or wish to ensure that your personal information is excluded from the government’s evaluation of the NTP, you can contact the NTP evaluator directly at: TuitionPartners@nfer.ac.uk

If you have any questions about the tuition service that is supplied by Pearson please contact us directly at ntpdata@pearson.com

Privacy Notice

This Privacy Notice explains how personal information will be used by Pearson in relation to the digital learning products and services that link to this Privacy Notice. In this Privacy Notice we call these our "Services”.

The nature of our business means that, from time to time, we’ll require some personal details from our customers and website users. The data we collect could just be a name and an email address, but depending on your level of engagement with Pearson, it could be much more than that.

The personal information you’ve shared with us, along with data on how you use our websites – what you search for and what preferences you select, for example – help us to better understand our customers as a group and as individuals. This in turn helps us to provide a range of products and services that meet your needs.

Please note that by using our Services you acknowledge that we will (and, to the extent it is required, you authorise Pearson to) transfer your personal information across national borders to the countries where Pearson and its partners operate, including the European Union, the United Kingdom and the United States. We will only carry out these transfers where permitted by law and will take appropriate steps intended to protect your personal information.

If any content or information you store or upload to Pearson websites or apps contains the personal information of other individuals, you must be legally permitted to share that information with Pearson.

Summary

• Where your consent is required we will obtain your permission before sending you promotional material about Pearson or accessing information on your device relating to your use of our websites and apps. You can withdraw that consent at any time.
• We use your personal information to enable you to register with Pearson and to provide you with the Services that you request, or which are requested on your behalf by educational institutions, parents or guardians.
• Some of our Services provide interactive features that engage with third party sites such as social media sites or those of educational institutions. If you use those features those sites will send us information about you.
• Our Services may use artificial intelligence and machine learning to provide you with a personalised experience and educational tools and material that are likely to be most useful to you. Where that is the case such uses will be clearly signposted and additional information will be provided to you.
• We use cookies and other technologies to track the use of our websites and apps and to improve and personalise our services. This varies by site and app and details are available on product specific website and app cookie policies and preference centres.
• We transfer personal information to the United States and to other countries which may be outside the country in which you live. Where that is necessary, we do so in accordance with applicable law and rely on established mechanisms (such as the European Commission’s Model Contract Clauses) to protect personal information.

This Privacy Notice is designed to help you understand how we and other companies in our group collect and use your personal information. We want you to make informed decisions when using our websites and any features on them, including any registration and ecommerce services.

This Privacy Notice applies to all Services linking to this Privacy Notice and any features of them and any ecommerce, purchasing or other areas which require registration on our sites. However, it won’t apply to any third-party sites which are linked to our sites. We recommend that you read the privacy notice of any such sites that you visit as we are not responsible for them.

We have included full details of who we and our group companies are at the end of this Privacy Notice.

What information does Pearson collect about me?

Limited personal information is collected during the registration process for Services. As a guide, we normally request the following data fields for users who are learners: First Name, Last Name and email address. In addition, where relevant, we may also collect: Year Group, date of birth, gender, a learner's institution and course identifier. The limited personal information we collect during the registration process for teachers typically is: First Name, Last Name and Email address, and where relevant, the teacher's institution and course identifier. Institutional customers are responsible for ensuring that any information they upload to the Services is accurate.

For some Services, a user may register using an alias name (pseudonym) and email address that is not otherwise associated with personal information provided to Pearson. This alias registration may not be available if the user account is established through integration with a third party service or if the institutional customer establishes the account for a user or otherwise prohibits the use of this option. If a user establishes a user account through alias registration in an institutional customer setting, the user must notify the institutional customer and the teacher for each educational course or learning program in which the Services are used so that the teacher and educational institution can recognise the user account as belonging to that user.

As users of the Services, learners and teachers may also generate personal information when using the Services. For example, the Services may record assignments, student coursework, responses to interactive exercises, scores, grades and instructor comments, details of the books the learner has read or activities the learner has completed. If the Services involve online tuition the tutor sessions will be recorded for safeguarding purposes for at least 6 months. Users may also generate personal information if they post in a community or forum, or use a communication tool provided through the Services. Pearson is not responsible for use or disclosure of these postings or communications by community or forum members, or by anyone else who receives your communications.

Other personal information that we collect may include your credit card or billing information, shopping selections and data about the pages you visit and your other activity on our site, as well as any other personal information relating to you that you supply to us or which is provided to us with your knowledge and permission.

How does Pearson collect my personal information?

We collect your information in two ways:

1. When you, your parent/carer or your institution (including your teacher) disclose your information through using the Services, registering you to use the Services (including when an institutional customer instructs us to register you to use the Services), contacting us (online or offline), ordering Services from us.
2. When you interact with the Services, our website, our mobile applications or when you open our email communications. We use cookies to collect this information. To find out more, please visit our Cookie Policy.

In a separate automatic operation we may collect application and system logs data which could include data such as your IP address, internet service provider and browser type, type of computer/device, and details of the website, application or email communication you came from before entering the Services. This information is used to:

• work out how many times the Services are visited;
• record which parts of the Services have been visited so we can improve the content and layout of the Services;
• understand the effectiveness of our email communications;
• monitor the health of the Services, detect unauthorised access and fraudulent activity, prevent and respond to security incidents and appropriately scale the computing resources for the Services.

We may from time to time supply third parties with an anonymised form of this data for uses in connection with our Services.

What will Pearson do with my personal information?

The personal information that is collected will be used by Pearson to provide the Services (including to communicate with users regarding service updates) and in accordance with this Privacy Notice. In addition, where an institutional customer has purchased access to the Services, personal information will also be used by Pearson in accordance with our contract with that institutional customer.

This may include analysis of users' use and progress across a variety of Services so that we can help learners make progress with their learning - for instance to evaluate the educational efficacy and effectiveness of the Services and to make appropriate recommendations to users and institutional customers based on this evaluation.

Email addresses for learners are collected in order to be able to issue passwords securely through our systems and to send out service messages where necessary. Please also refer to the section headed Marketing communications and opting out to see how else email addresses may be used.

Some Services may have the capability to connect to your Google Drive so that you can upload or download documents directly from or into your Google Drive. Before they do so, you will receive a prompt asking you to click "Allow" to enable the Services to connect to your Google Drive. You may remove this connection in the My Account settings for your Google account at any time. Pearson will use this connection to access your Google Drive only for the purpose of uploading or downloading documents that you specifically select with limited metadata to allow identification and retrieval, so that you can access and use the documents within the Services or download them to Google Drive. Pearson will use, process and store these documents and associated personal data in accordance with this Privacy Notice.

What is the legal basis for Pearson to use my personal information?

We and our group companies use your personal information for a variety of business purposes which are in our legitimate interests ("Business Purposes"), and/or in order to enter into or perform a contract with you ("Contractual"), and/or with your consent ("Consent"), and/or compliance with our legal obligations ("Legal Reasons"). For example, we may use your personal information:

• to provide you with the relevant services through our applicable site, for Contractual Reasons
• to process your online purchases, for Contractual Reasons
• to inform you about and provide more information on products and services offered by us and our group companies, for our Business Purposes or with your Consent
• to invite you to participate in surveys, discussions and prize draws and ask for your views on our services via online surveys and discussion forums, for our Business Purposes and/or with your Consent
• to improve the products and services offered to you for our Business Purposes
• for marketing for our Business Purposes and/or with your Consent
• for statistical or analytical purposes for our Business Purposes
• to detect, prevent or investigate security breaches or fraud for our Business Purposes and/or Legal Reasons
• to otherwise to better meet the needs and preferences of our customers for our Business Purposes
• for safeguarding purposes to protect the vital interests of learners and where there is substantial public interest in providing a safe space for the education of young and vulnerable learners.

We will not allow unrelated third parties to use your personal information for marketing without your consent. Where we rely on your consent, you have the right to withdraw it at any time.

We also use personal information to identify types of user, audit how our sites are used, and to help with the strategic development of our sites. When doing so, we remove any direct identifiers.

Participation in surveys and discussion forums is entirely voluntary. You may unsubscribe from being contacted for these purposes at any time. Survey information will be used for market research with the aim of improving our services.

We will show your username on any content you submit or post on our sites (including discussions, bulletin boards and forums).

For how long will Pearson keep my personal information?

We will keep your personal information only for as long as necessary to fulfil the purposes for which we are processing your personal information unless the law permits or requires longer. For example, we might need to keep your personal data for quality assurance of the service we have provided, or we might need to keep it to defend future legal claims.

Email marketing and opt-out

Marketing will not be sent to any learners aged under 16 registered to use the Services unless consent has been provided on behalf of the learners, in which case such consent may be withdrawn at any time.

Contact details for teachers, learners who are 16 or over, and adult subscribers to the Services may be used for these purposes:

1. to contact the user with more information about our products and services and those of our group companies, except where the user has told us not to;
2. to invite the user to participate in surveys, discussions and prize draws and ask for the user's views on our Services via online surveys and discussion forums.

Participation in surveys and discussion forums is entirely voluntary. Users may unsubscribe from being contacted for these purposes at any time. Survey information will be used for market research with the aim of improving our Services.

We will not send marketing emails to a user who has opted out of receiving them. Any marketing communications we send will include an unsubscribe link at the end of the email.

How does Pearson keep my personal information safe?

We seek to protect the safety of all your personal information by implementing appropriate technical and organisational measures. For example, provided your browser accepts HTTPS (Hyper Text Transfer Protocol) Secure encryption, we seek to protect your payment information against unauthorised access through a secure server. Where we use third parties to process personal information, we require them to ensure the safety of your information.

Any personal information that you voluntarily post on a public area of our site, such as a bulletin board or discussion forum, or an interactive area requiring registration and/or subscription, may be collected and used by others. Please be careful what personal information you disclose in this way. You understand that we cannot control the actions of other users.

Will Pearson share my personal information with anyone else?

We will never sell users' personal information. We may disclose and share personal information:

• with our service providers (for example, suppliers who develop or host our Services) in which case we will require them to implement appropriate technical and organisational measures to meet the requirements of applicable law; and/or
• if required or permitted by law; and/or
• with relevant third parties (law enforcement agencies, your employer or educational institution) if we reasonably believe a user may be in breach of the law (e.g. if a user has posted defamatory content on our Services) or may have engaged in any academic dishonesty or misconduct, or may be in breach of any terms of use or end user licence agreement which apply to the Services, or in breach of any other contract with the user or the user's educational institution or employer; and/or
• with an institutional customer (on a limited basis and only with your knowledge and where it is necessary to provide the Services) or parent/carer where the institutional customer or parent/carer has purchased access to the Services on the user's behalf; and/or
  with schools, regulators and government bodies in connection with services that are delivered to learners in partnership with those bodies and as set out in notices which we will provide to you which outline the nature and purposes of that data sharing;
• with our group companies who may use the information in accordance with the Marketing communications and opting out section below. Please note information on learners aged under 16 will not be shared with group companies for marketing purposes; and/or
• in connection with a sale, joint venture or other transfer of some or all of our company or assets, subject to the commitment of the acquiring entity to comply with this Privacy Notice; and/or
• to protect the security and safety of the user and other persons, data, assets and systems, consistent with applicable law; and/or
• in other situations with the user's consent.

We also use personal information in aggregate form (so that no individual user is identified by name) to identify types of user, audit and analyse how our Services are used, to help with the strategic development of our Services, to conduct educational research, and to develop new products and services. When doing so we remove any direct identifiers so that the data is no longer considered personal data for the purposes of data privacy laws and regulations.

Will Pearson send my personal information to another country?

We may transfer your personal information to other countries around the world, including countries outside of the European Economic Area ("EEA"), which may not have the same data protection laws as those of the country where you access our sites. Where we transfer your personal information to countries outside of the EEA we will take appropriate steps to ensure your personal information is afforded the same level of protection as described in this Privacy Notice.

We have entered into an intercompany data processing agreement using the European Commission standard contractual clauses (in the absence of an adequacy decision) for data transfers to our group companies located outside of the EEA. We rely on adequacy decisions or any adequate data transfer mechanisms adopted by the European Commission or a supervisory authority from time to time for transfers to third parties located in countries outside of the UK or the EEA.

What rights do I have?

In some regions such as the EEA (European Economic Area) you may have certain rights in relation to your personal information including the right to:

• request access to and obtain a copy of your personal information
• rectification of your personal information if it is no longer accurate or erasure of your personal information if our retention is no longer necessary for the purposes for which it was collected
• restrict or object to the processing of your personal information in certain circumstances
• data portability (if applicable)

If you or your parents or guardians wish to exercise any of your rights in relation to your personal information please send your request to us using the details set out in the "Contacting Pearson" section below. We will consider and act upon any request in accordance with applicable data protection laws.

You may also have the right to complain to the Information Commissioner (if you are in the UK) or to your local data protection supervisory authority if you are unhappy with our privacy practices notified under this Privacy Notice.

What if I am under 16 years old?

If you are under 16, please be sure to read this Privacy Notice with your parent or guardian and ask them questions about anything you don’t understand.

Misuse of personal information

Any improper collection or misuse of personal information is in violation of this Privacy Notice and of our Legal Notice or terms of use. Please report it by emailing dataprivacy@pearson.com.

You agree not to misuse any personal information available on our sites or to gather it or use robots or other automated scripts, codes or functionalities to do so.

You agree not to misuse any personal information available on our sites or to gather it or use robots or other automated scripts, codes or functionalities to do so.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time. We will always include the date of a new version so that you know when there has been a change.

Contacting Pearson

If you have any questions about our Privacy Notice, please do not hesitate to contact us at:

Data Protection Officer
Pearson
80 Strand
London
WC2R 0RL
United Kingdom

You may also email us at dataprivacy@pearson.com.

This Privacy Notice is provided on behalf of Pearson plc and its group companies. This means all companies owned or controlled by Pearson plc (registered office 80 Strand, London, WC2R 0RL, United Kingdom, registered number 53723).