Privacy Policy

Last Updated: 25/09/2024

1. Purpose of this Privacy Policy

At Vision Marker, we are committed to protecting the privacy and security of the data we process. This Privacy Policy outlines our practices regarding the handling of information we receive from our clients, specifically student data. It also informs you about your privacy rights and how the law protects you.

2. Who We Are

Vision Marker is an educational technology company providing automated marking and feedback services to schools and national exam boards. Our registered office is 5 Sunstone Mews, Cheltenham, GL52 7ZU.

3. Our Role as a Data Processor

Vision Marker acts as a data processor for schools and exam boards (our clients), who are the data controllers. We process student responses to questions as provided by our clients.

4. Methods of Data Collection

We receive student responses through secure channels established with our clients. Data is collected by our clients during examinations or assessments and transmitted to us via encrypted means such as Secure File Transfer Protocol (SFTP) or other secure methods agreed upon in our data processing agreements.

5. Information We Process

Student Responses: We process images of handwriting or raw typed text of student responses to questions.

Anonymised Data: Typically, we process anonymised data that does not identify any individual.

Potential Non-Anonymised Data: In cases where student responses inadvertently contain personally identifiable information (PII), we handle such data securely and in compliance with applicable laws.

6. Data Quality and Responsibilities of Data Subjects

As we process data provided by our clients, we rely on them to ensure the accuracy and quality of the data collected. If you are a student or parent and believe your data is inaccurate, please contact your school or exam board directly.

7. How We Use the Information

We use the student responses solely for the purpose of:

• Generating marks and feedback, which we return to our clients.
• Improving our automated marking and feedback systems through data analysis.

8. Lawful Basis for Processing Data

We process student responses based on our legitimate interests in providing educational technology services, as agreed upon in our contracts with schools and exam boards. These legitimate interests include:

• Improving educational outcomes: Enhancing the accuracy and efficiency of assessments to contribute to better educational experiences.
• Advancing educational technology: Refining and improving our AI and machine learning algorithms.
• Supporting educational institutions: Assisting schools and exam boards in managing their assessment processes effectively.
• Research and development: Understanding learning patterns and assessment techniques to develop more effective educational tools.

We balance our legitimate interests against potential privacy impacts. By using anonymised data whenever possible, we ensure minimal privacy implications.

9. Data Retention

We retain student responses and generated marks for 90 days after the completion of the marking process, after which they are securely deleted from our systems.

10. Data Security

We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

• Encryption of data at rest and in transit.
• Regular security testing and vulnerability assessments.
• Strict access controls and authentication measures.
• Regular staff training on data protection and security.
• Secure handling procedures for any non-anonymised data.

11. Monitoring and Enforcement Procedures

We regularly monitor our compliance with this privacy policy and applicable laws. Internal audits and assessments are conducted to ensure data is handled appropriately. Any breaches or potential issues are promptly investigated, and corrective actions are implemented.

12. Sharing of Information

We do not share the information we process with any third parties. The marks and feedback we generate are returned only to the client who provided the original responses.

13. Your Rights

As we process data on behalf of our clients, any requests regarding your data should be directed to your school or exam board. However, if we hold any non-anonymised personal data about you, you have the right to:

• Request access to your personal data.
• Request correction of inaccurate data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing.
• Request transfer of your data.
• Withdraw consent where applicable.

To exercise these rights, please contact your school or exam board. If you contact us directly, we will forward your request to the relevant data controller.

14. Vision Marker as a Data Processor

We process personal data solely on behalf of our clients and in accordance with their instructions. Vision Marker does not act as a joint controller for any personal data processing activities.

15. Data Processing Agreement

We operate under a data processing agreement with each of our clients, outlining our obligations and responsibilities, including:

• Subject Matter and Duration: Details of the processing services provided and the length of time we process the data.
• Nature and Purpose: The specific purposes for which the data is processed.
• Type of Personal Data and Categories of Data Subjects: Definitions of the data involved.
• Obligations and Rights: Our commitments to data security and the client's rights.
• Technical and Organisational Measures: Detailed security protocols and measures in place to protect data.

16. International Data Transfers

All data is processed and stored within jurisdictions agreed upon with our clients. If data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission.
• Binding Corporate Rules.
• Adequacy decisions by relevant data protection authorities.

17. Automated Decision-Making

Our services involve automated decision-making through AI and machine learning to provide marking and feedback. These processes are designed to be fair, transparent, and unbiased. We regularly test and monitor our systems to maintain accuracy and fairness.

18. Accessibility

We are committed to making our services accessible to everyone. If you need assistance or have accessibility concerns, please contact us at james@vision-marker.com or barry@vision-marker.com.

19. Changes to This Policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date.

20. Contact Us

If you have any questions about this privacy policy or our data practices, please contact us at:

Email: james@vision-marker.com or barry@vision-marker.com

21. Policy Review

This privacy policy is reviewed annually to ensure compliance with applicable laws and regulations and to incorporate best practices in data protection.