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Legal

Privacy notice

Last updated 2 October 2026

Placeholder — this is not the legal text. The headings are the structure the final document will follow. The wording is to be written and reviewed by a solicitor before this platform takes real learner data. Notes under each heading record what the platform actually does, for whoever drafts it.

On this page · 8 sections
  1. 01Data controller
  2. 02Data we hold
  3. 03Lawful basis
  4. 04Retention
  5. 05Your rights
  6. 06Subprocessors
  7. 07Breach notification
  8. 08Contact

Data controller

To be drafted by a solicitor

  • Who the controller is for apprentice, tutor and employer data (the training provider) and who the processor is (the platform).
  • Who is controller for platform-level data such as provider-admin accounts and billing.
  • ICO registration number and contact details for the platform.

What the platform does — notes for the drafter

  • Each training provider is a separate tenant on its own subdomain; its staff can see only its own learners.
  • Accounts are created by the provider (invitation or CSV import). There is no self sign-up.

Data we hold

To be drafted by a solicitor

  • Every category of personal data, with the source of each.
  • Any special category or criminal offence data, and the condition relied on.

What the platform does — notes for the drafter

  • Account: name, email, role, provider, employer (and optionally job title and photo).
  • Learning: lesson activities completed, scores, signed reflections, private notes, bookmarks.
  • Evidence files and reflections; off-the-job hours with approvals and signatures.
  • Tripartite progress reviews with notes and signatures from learner, tutor and employer.
  • Messages between learner, tutor and employer.
  • AI helper conversations, each classified with a one-word theme and scanned for welfare signals.
  • Safeguarding records where a concern has been raised (may include special category data).
  • Connected social-account analytics, only if the learner connects an account.

Lawful basis

To be drafted by a solicitor

  • The Article 6 basis for each purpose (delivering the apprenticeship, funding compliance, safeguarding, analytics with consent).
  • The Article 9 condition for safeguarding and any health information.
  • Automated processing: KSB tag suggestions and welfare scanning, and why neither is a solely automated decision under Article 22.

What the platform does — notes for the drafter

  • AI suggests KSB tags on reflections; a tutor decides what counts.
  • AI welfare scanning routes possible concerns to the provider’s safeguarding queue for a person to read. Nothing is escalated outside the provider automatically.
  • Analytics (PostHog) loads only after cookie consent.

Retention

To be drafted by a solicitor

  • How long each category is kept and why, including the apprenticeship funding retention requirement.
  • What happens at the end of the period.

What the platform does — notes for the drafter

  • Apprenticeship records (training records, progress reviews, evidence of achievement, off-the-job hours) are kept for 7 years after completion. The requirement is the DWP Provider Agreement: 6 years from the end of the financial year in which the last funding payment was made, which 7 years covers.
  • On an erasure request those records are kept with the name and email replaced by a reference code. Signatures and safeguarding records are kept unchanged.
  • Data exports are deleted 7 days after they are made.

Your rights

To be drafted by a solicitor

  • Each right (access, rectification, erasure, restriction, objection, portability) and how to use it.
  • The one-month response time and when it can be extended.
  • The right to complain to the ICO.

What the platform does — notes for the drafter

  • Learners can download all their data, ask for corrections and request account deletion themselves on the My data page in the platform.
  • Deletion has a 30-day cooling-off period and can be cancelled before it runs.
  • Safeguarding records and moderation notes are not in the automatic export; the provider reviews them first.

Subprocessors

To be drafted by a solicitor

  • Reference to the subprocessor list and how customers are told about changes.
  • International transfers and the safeguards used.

The current list is on the subprocessors page.

Breach notification

To be drafted by a solicitor

  • What happens if personal data is breached, who is told and when.
  • The processor’s duty to tell the provider without undue delay.

What the platform does — notes for the drafter

  • Providers have an incident log in their console. It records; it does not notify anyone.

Contact

To be drafted by a solicitor

  • Contact details for the platform (and DPO if appointed).
  • That learners should usually contact their training provider first.