Updated: January 2022
By visiting www.earlyexcellence.com and www.eexat.com (the “Websites”) you are accepting and consenting to the
practices described in this policy in relation to the use of our website.
Personal information means any information which identifies you (or if you are an organisation which has purchased the EExAT Software), the information which identifies your workers or pupils), and may include information such as names, email addresses, telephone numbers, and the academic profiling of pupils supplied by the school. It may also include details such as bank account numbers and payment card details.
2. Who we are
Early Excellence Limited is a company registered in England and Wales (registration number 03421364) whose registered office is at The Old School, New Hey Road, Huddersfield, West Yorkshire, HD3 3YJ (“we” or “us”) and is registered as a data controller with the Information Commissioner’s Office (registration number ZA114933).
We respect your right to privacy and will only process personal data you provide to us in accordance with the UK General Data Protection Regulation, Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003, as updated from time to time, and other applicable legislation.
If you have any queries about your privacy whilst using our Website, please email us at firstname.lastname@example.org
3. Unsubscribe from marketing
Whilst an Early Excellence and/or EEXAT subscriber, your details will be retained.
If you no longer wish to receive marketing emails from us and want to be removed from our electronic mailing list, please email us at email@example.com with “Email Unsubscribe” in the subject heading.
If you want to change your marketing preferences please contact firstname.lastname@example.org
4. Cookies and similar technologies
A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device. Cookies do not damage your computer.
You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through our Websites may not function properly if your cookies are disabled.
We use two types of cookies on our Websites:
4.1 Strictly necessary cookies
These cookies are essential in order to enable you to move around the Websites and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser.
4.2 Performance cookies (e.g. Google Analytics)
These cookies collect information in an anonymous form about how visitors use our Websites.
They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it.
We may also use your IP address to help diagnose problems with our server, to administer our Website and to improve the service we offer to you. An IP address is a numeric code that identifies your computer on a network, or in this case, the internet. Your IP address might also be used to gather broad demographic information.
We may perform IP lookups to determine which domain you are coming from (i.e. aol.com, yourcompany.com) to more accurately gauge our users’ demographics.
Information from these types of cookies and technologies or about website usage is not combined with information about you from any other source. None of the cookies or technologies that we use will personally identify you.
Cookies are essential to the effective operation of our Website. We need to ask for your consent to set the performance cookies described above. When you arrive on our Website a banner appears asking for your consent to place performance cookies on your device. By continuing to use our Website, we assume that you consent to cookies being placed on your device.
5. Sensitive/special category personal information
We may process sensitive personal information in certain situations. This will only be used as listed in this policy for the purposes of supplying/hosting software for the performance of a contract.
Sensitive personal information includes information relating to:
- ethnic origin
- political opinions
- religious beliefs
- trade union membership
- physical or mental health or condition
We will only process sensitive personal information (in accordance with the consent given as part of the contract and relating to the information supplied by you, the client, to be stored in the system.
6. Data access and corrections
Upon receipt of your written request and enough information to permit us to identify your personal information, we will disclose to you the personal information we hold about you in accordance with applicable data protection laws.
We will also correct, amend or delete any personal information that you tell us is inaccurate. You may update any information you have given to us by emailing us at email@example.com
Requests to delete personal information are subject to any applicable legal and ethical reporting or document retention obligations imposed on us.
7. Links to other websites
8. International Transfers
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
When using the EExAT Software, we will provide to clients directly, copies of the technical and organisational measures we have in place to keep data we process on their behalf secure.
10. Children’s privacy
We recognise the need to provide further privacy protections with respect to personal information we may collect about children through the use of the EExAT Software. We limit our collection of personal information about children to no more than is reasonably necessary.
Due to the sensitivity that surrounds the data protection of minors, we recognise the need to provide elevated privacy protections with respect to any personal information we collect about children, including but not limited to, pupil academic achievements, assessment results, pictures of their work and images or videos of the children themselves, or any other information that can easily identify a pupil (”Pupil Data”).
The software will record and share Pupil Data with other staff within the clients establishment, parents and with external educational bodies (determined by the purchasing client). The software can also use Pupil Data to create aggregate national data required by the school to share with the DFE (this action would be determined by the client). Where a client purchases our software, EExAT will act as a data processor and all decisions made in relation to the processing of children’s data will be determined by the client and EExAT will only act under instruction of the controller.
Before uploading any images, you must also ensure that you have all the appropriate rights and consents to the images that you upload, whether they are images that belong to you personally, or you have been given consent to use those images by the owner. You must not include in any images you upload, images of any person for whom consent has not been provided.
If you are a school posting Pupil Data, you must comply with the provisions in the subscription agreement you have with us. You must ensure that you are able to upload the images before you do so and you must confirm that you have consent from a parent / guardian or responsible adult for each pupil whose data is being posted. You must be able to produce the parental consent upon our request and if for any reason, we ask you to remove any Pupil Data you will do so immediately.
11. EExAT Standard + and EExAT Premium
EExAT enables you to share your ‘evidence’ (photographs and video clips of your children as well as written observations) in the Moderation section as well as anonymised children’s assessment data in the Reports section. Please note that it is your responsibility as the Data Controller to ensure you have agreed a data sharing policy across your EExAT network of schools / settings, which complies with appropriate safeguarding guidelines, standards and applicable laws and regulations in relation to the Data Protection Act.
12. Retention Periods
We store your personal data on secure servers in accordance with the criteria set out in our Retention Policy. Regulations and legislation require that we keep certain information for a dedicated time. This is all outlined in full in our Retention Policy.
13. Your Rights
The GDPR provides the following rights for individuals:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object to processing
- Rights in relation to automated decision making and profiling (We do not carry out automated decision making and profiling)
- Right to access – i.e. to request a copy of your information
You can request a copy of your information which we hold (this is known as a subject access request).
If you would like a copy of some or all of it, please write to us at firstname.lastname@example.org
- let us have proof of your identity (a copy of your driving licence or passport); and
- let us know what information you want.
NB. Where we receive a request for access from a 3rd party such as a client employee or a parent of a pupil named in the EExAT Software, this will be referred directly back to the client as the data controller and we will provide any data deemed necessary under their instruction.
15. Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please email or write to us (see ‘How can you contact us?’ below)
- let us have enough information to identify you
- let us know the information that is incorrect and what it should be replaced with.
16. Right to remove your details from our records or restrict how we use your information
You can ask us to stop contacting you for particular purposes or remove your information completely from our records. There may be a legal reason why we need to keep your personal data and in that circumstance we will destroy your personal information as soon as we are legally entitled to do so. If you would like us to stop contacting you with information about our services, please email or write to us (see ‘How can you contact us?’ below).
- let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
17. Right to lodge a complaint with the Supervising Authority
If you have any concerns or complaints about how we use your personal data, we hope you will alert us to these directly (see the Contact information below). If you are still unhappy you are entitled to complain to the Information Commissioners Office (ICO) which is the supervising authority in the UK. Their contact details and the procedure can be found at www.ico.org.uk.