Safeguarding and General Data Protection Regulation (GDPR) Compliance
What data is stored
For each student registered on Number.school, their name is stored, and an encrypted password (the original of which is not retrievable by anyone, including administrators),their usage data, in terms of working and answers to questions. No other personal information beyond name is stored.
For each teacher, it stores their email address, school and also what classes they have set up.
Who can access what data
Students can access only their own data after log in.
Teachers can access assessment data of any student within their classes. Teachers can administer student accounts, for example changing their name or changing their class.
It is not possible for a teacher to access the data of another school.
Only administrators can view data from other schools to ensure the smooth running of the platform. Currently this is only myself (M Eastmond, a former full-time teacher). I naturally have full DBS clearance.
Your right to delete stored data and account deletion
Student accounts can be deleted by teachers at their respective school. Any user may request to have their account deleted via an email to email@example.com The email request must match the email address of the account being deleted.
Number.school will automatically delete inactive accounts where the user has not logged in over 2 years.
How your data is protected
The site server is located at a secure Google data centre in the European Union.
All data accessed via user accounts have appropriate checks to ensure the account has the correct permissions to view the data.
In the unlikely event of any data breach, the nature of the breach, in addition to the resulting action to remedy such a breach, will be clearly communicated.
The server has an SSL certificate (in layman's terms, the 'padlock' symbol that appears in your browser), meaning that data is transmitted securely.
Disaster Recovery Plan for EU Legislation
"(a) the pseudonymisation and encryption of personal data;"
As per "What data is stored", the only personal data stored is email address and name, along with assessment data purely based on usage of the platform. Passwords are encrypted and cannot be unencrypted.
(b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
Any code which accesses the database ensures appropriate permissions to view/modify/delete the data, as per "Who can access what data". The server is managed at a secure data centre by Google, which has a "100% uptime guarantee".
(c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
Backups are made daily by the server administrator, which can be restored as necessary.
(d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.”
I review code as per (b) to ensure access to data is appropriate restricted as described. With regards to the effectiveness of the server, this is as per Google's own GDPR compliance.