Privacy notice: Tips by Text evaluation
Your child’s school is participating in a research project testing the impact of an early learning programme called ‘Tips by Text’.
The Tips by Text project is a collaboration between the Education Endowment Foundation (EEF), the Behavioural Insights Team (BIT), the National Institute of Economic and Social Research (NIESR), the Institute for Employment Studies (IES), and the University of Oxford. Together, these parties (with the exception of the EEF) are referred to as the ‘Research Team’ in this Privacy Notice. The roles of each party named above are as follows:
- The EEF are the funders of the project.
- BIT will be responsible for designing the programme (in collaboration with trusted academics) and for sending text messages to parents/guardians randomly selected to receive them.
- NIESR/IES will evaluate the impact of the programme on pupil outcomes. They will also explore parents/guardians’ perceived impact on pupil outcomes, explore their experiences of the programme and assess whether the programme could be implemented at a larger scale.
- The University of Oxford will have access to the data after the project has been completed to conduct secondary analyses.
This privacy notice sets out how the Research Team will collect and use your personal data.
After your child’s school has shared personal data of pupils and parents/guardians taking part in the project with the Research Team, each member of the Research Team will become a separate data controller of this personal data in order to perform the roles set out above.
If you have any questions about this privacy notice, including any requests to exercise your legal rights in relation to your personal data, please contact NIESR/IES in the first instance.
NIESR, 2 Dean Trench Street, Smith Square, London, SW1P 3HE
Institute for Employment Studies, City Gate, 185 Dyke Road, Brighton, BN3 1TL
You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact NIESR/IES in the first instance.
We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it and let you know of any material changes to this notice.
The Research Team deals with and shares your personal data following a data sharing agreement between the Research Team members. The agreement sets out the purposes for which we may process and share your personal data and our agreement to cooperate to protect your personal data and deal with any requests you may have.
What kind of information do we collect?
Your child’s school will share the following information with NIESR/IES (who will then share it with other members of the Research team as necessary for them to fulfill their roles):
- Pupil name
- Date of birth
- Unique Pupil Number (UPN)
- Class name
- School name
NIESR/IES will access and link this pupil data to background and school data held on the National Pupil Database (NPD). The NPD data to be requested will include whether or not the pupil is eligible for Free School Meals (FSM) as well as their gender.
NIESR/IES will match the above pupil data to data on pupil outcomes. This will include data from questionnaires and assessments administered as part of the project including a standard assessment of literacy skills and a measure of social development as well as data on outcomes available through the NPD.
- Email address
- Mobile telephone number
- Responses to text messages
- Responses to interviews and surveys
NIESR will match responses from parent surveys to data from the NPD on their child's FSM status
What do we do with information we collect?
Each organisation will use the data for different purposes:
- To deliver the programme to parents/guardians (i.e., to send the text messages)
- To manage communications with parents/guardians
- To act as the main point of contact for schools and parents/guardians for anything to do with the text messages
- To conduct the randomisation (i.e., to randomly allocate parents/guardians to receive or not receive the messages)
- To match data received from schools and parents to NPD data and outcome data
- To contact parents/guardians about participating in interviews and surveys
- To instruct and liaise with independent test administrators
- To evaluate the impact and effectiveness of the programme and prepare a report about the project
The University of Oxford
- To build on existing work by the Department of Experimental Psychology on what works to foster an effective home learning environment for early years pupils
- At the end of the project, data will be submitted to the EEF’s data archive which is managed by the Fischer Family Trust (FFT). At this point, EEF will become a data controller and FFT will be a data processor
What is the lawful basis for processing your personal data?
We will only use your personal data where we have a lawful basis for doing so.
- BIT’s legal basis for processing personal data is ‘legitimate interests.’ BIT considers that processing of personal data is necessary to conduct the delivery of the Tips by Text programme. This project fulfils BIT’s core business aims, including undertaking research and delivering low-cost interventions that will deliver social impact.
- NIESR and IES’ legal basis for processing personal data is also ‘legitimate interests.’ The evaluation of Tips by Text fulfils one of NIESR and IES’ core business purposes (undertaking research, evaluation, and information activities) and is therefore in our legitimate interest, that processing personal information is necessary for the conduct of the evaluation.
- The University of Oxford’s lawful basis for processing data is ‘public interest task.’ This research will build on existing work by the Department of Experimental Psychology on what works to foster an effective home learning environment.
- When the EEF becomes data controller at the end of the project as the data is submitted to the data archive, the legal basis for processing personal data is ‘legitimate interests.’ These legitimate interests include gathering data about what educational interventions work best, under what conditions, for which pupils, with a view to increasing attainment and reducing educational disadvantage.
Who else has access to your information?
The Research Team may disclose your information to third parties in connection with the purposes of processing your personal data set out in this notice. These third parties may include suppliers, research assistants, trusted academic partners and subcontractors who may process information on behalf of the Research Team to carry out such work as sending text messages, administering tests, undertaking interviews, transcribing interviews, and archiving data. In all cases, the Research Team will ensure that these third parties enter into appropriate data processing agreements with us and that they keep your personal data secure and confidential.
We may also disclose your personal information if required by law, or to protect or defend ourselves or others against illegal or harmful activities, or as part of a reorganisation or restructuring of our organisations.
Your personal information will not be transferred outside of the EEA.
We take all reasonable steps to protect your personal information and follow procedures designed to minimise unauthorised access, alteration, loss, or disclosure of your information.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When it is no longer necessary to retain your personal data, it will be securely deleted.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- BIT, NIESR and IES will delete any personal data six months after the completion of the project.
- The University of Oxford will retain the personal data up to three years after it is received.
- NIESR/IES will send the data to the Fischer Family Trust (FFT) archive within three months of project completion. FFT will keep the data on behalf of EEF, at which EEF take responsibility for Data Protection Compliance
Please note that, under Data Protection legislation, and in compliance with the relevant data processing conditions, personal data can be kept for longer periods of time when processed purely for archiving purposes in the public interest, scientific or historical research, and statistical purposes.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including rights:
- To request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check we are lawfully processing it.
- To request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected.
- To request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- To object to processing your personal data: you can object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms
- To request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data.
- To request transfer of your personal data.
- To object to direct marketing (including profiling) and processing for the purposes of scientific/historical research and statistics.
- Not to be subject to decisions based purely on automated processing where it produces a legal or similarly significant effect on you.
If you wish to exercise any of the rights set out above in connection with this research project, please contact TipsByText@niesr.ac.uk
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this Notice
We may change this Privacy Notice from time to time. If we make any significant changes in the way we treat your personal information we will make this clear by contacting schools and ensuring they provide you with an updated version of this Privacy Notice.
Company details for the Research Team and Funder
- Behavioural Insights Ltd is a limited company registered in England and Wales.
○ Registration number: 08567792
○ Registered office: 58 Victoria Embankment, London, EC4Y 0DS
○ Email: firstname.lastname@example.org
- NIESR is a company listed by guarantee registered in England, and a registered charity.
○ Company Number: 341010
○ Charity registration number: 306083
○ Registered office: NESR, 2 Dean Trench Street, Smith Square, London SW1P 3HE
○ Email: TipsByText@niesr.ac.uk
- The Institute for Employment Studies is a charitable company limited by guarantee registered in England.
○ Registration number: 931547
○ Charity registration number: 258930
○ Registered office: Institute for Employment Studies, City Gate, 185 Dyke Road, Brighton, BN3 1 TL
- The University of Oxford is a civil corporation. The University enjoys charitable status as one of the exempt charities listed in Schedule 3 to the Charities Act 2011
○ Registered office: University Offices, Wellington Square, Oxford, OX1 2JD
○ Email: email@example.com
- The Education Endowment Foundation is a charity registered in England
○ Registered office: Millbank Tower, 21-24 Millbank, London SW1P 4QP
○ Charity registration number: 1142111
○ Company number: 07587909
○ Email: firstname.lastname@example.org