Carousel Privacy Policy

1. Introduction

Privacy and security are at the heart of everything we do at Carousel, and our approach incorporates data protection by design and default. This statement explains the key measures we’ve put in place to ensure that school 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.

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 General Data Protection Regulation (GDPR) as it applies in the UK, tailored by the Data Protection Act 2018.
• Only store and process the minimum data required to provide our services
• 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, password-protected identities for all end users, and variable permissions according to the user’s role.
• Comply with all Subject Access Requests made relating to the data We store.
• Ensure the data We hold about you is correct.
• Only retain data for as long as required, and delete all your data if you ask us to do so.
• Ensure that all data is held securely by taking steps so that data is not corrupted or lost.
• Always maintain adequate liability insurance.
• Audit our services against this pledge periodically and provide evidence of compliance to the other party whenever requested.
• Report any significant breaches of security to the Data Controller, the Information Commissioner’s Office (ICO) and other authorities, and, in co-operation with the Data Controller, to Data Subjects without undue delay and within 72 hours.
• Make this Privacy Policy clearly and publicly available on our website.

We DO NOT:

• Store or transport personal data outside of the EEA 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 Carousel 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 Carousel platform is developed using secure technologies, which include, but are not limited to the following:

• All personal Carousel data is stored and transported within the EEA or countries which are granted to have Adequate Levels of Protection as defined by the European Commission.
• All internal and external data transmissions to and from the Carousel Platform are encrypted using modern SSL/TLS protocols and ciphers via secure REST APIs.
• Data is encrypted at rest (i.e. when stored on a disk or laptop).
• We use encrypted passwords with variable permissions according to the user’s role for access to all sensitive information.

4. Staff access to data

Carousel 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.

All our staff and subcontractors are required to agree that they will abide by a Security and Data Protection Policy at all times.

5. Deleting and Retaining Data

We retain personal data on our platform for as long as necessary to provide the Carousel service. If a school ceases to use Carousel, we delete their data within 5 working days. We will also delete all personal and sensitive data relating to former students automatically on their 25th birthday, regardless of whether a school has asked us to do so.

6. Question banks created on our platform

By default Schools and MATs retain ownership of all question banks they create and share using our platform. In some situations, we also give you the option of sharing your question banks with other schools, and/or allowing them to be combined with other question banks. All users creating question banks on the site are responsible for ensuring that they have the necessary rights and permissions to use and share the questions they contain.

Question bank owners may withdraw their banks from the Platform at any time, in which case they will cease to be available for users to create new quizzes from that point onwards. However, any quizzes that had already been created from a question bank by a user at the point of removal will remain available to that user indefinitely. Similarly, if a question bank owner wishes to change the status of a question bank from “global” to “private”, that change will apply from that point on but not retrospectively. In other words, any legitimate use of that question bank according to the terms of this policy prior to the status change will remain valid.

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 significant breach of security or privacy did occur, Carousel will contact the Data Controller of the affected data, and inform the Information Commissioner’s Office (ICO), and other authorities without undue delay and within 72 hours.

8. Information for students and parents/guardian

Carousel, as the Data Processor, only has access to Personal Data or Sensitive Personal 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.

The categories of personal data we process and the purposes for doing so are as follows:

9. Cookies

A cookie is a string of information that a website stores on a visitor’s computer. Carousel 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.

10. Communication

If you have expressed interest in Carousel on the Carousel website or signed up as a Carousel customer, 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 You can opt out using the links on those communications, or email hello@carousel-learning.com and we will remove you from the list.

11. 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.

12. Questions and Grievances

If you have any questions or grievances in relation to security or privacy, please email us on hello@carousel-learning.com.