Privacy Policy

Hutchinson Education Limited (“HE”, “we”, “us”) provides tutoring and education consultancy services, bothdirectly through its Director and through self-employed Agency Tutors introduced to clients. Families, schools,and universities entrust us with personal academic information, and we treat that responsibility with discretionand care. For the purposes of UK data protection law, HE is the Data Controller for personal data collected andprocessed for the purposes set out in this policy. Agency Tutors engaged by HE are independent Data Controllersfor personal data they collect and process while providing tutoring services to clients. We comply with the UKGeneral Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (together “Data Protection Legislation”).

For queries or to exercise your data protection rights, contact: info@hutchinsoneducation.com

This policy applies to:

• The Director of HE, when delivering tuition and consultancy personally (also acting as DesignatedSafeguarding Officer (“DSO”))

• Agency Tutors engaged by HE to provide tuition to HE-introduced clients

• All other personnel working on behalf of HE

All individuals must read, understand, and confirm compliance with this policy.

• Parent/Guardian Data: Name, contact details (including email addresses and telephone numbers),occupation (if provided), correspondence records, billing address, and payment information (such as bankaccount or payment card details)

• Student Data: Name, date of birth, school, academic history, lesson records, progress notes, universitypreferences, personal statement/UCAS materials

• University/School Contact Data: Staff names, email addresses, telephone numbers, and institutionalcorrespondence relevant to student support

• Sensitive Data: Learning differences, health information, or safeguarding-related data, processed only withexplicit consent or where legally required (such as for safeguarding purposes under the lawful basis of vitalinterests or public interest). Educational or psychological reports provided by parents, schools, or otherprofessionals to support the Student’s learning needs

Data is collected directly from clients, students, or institutions (typically via email, portable storage devices, orduring consultations), with parental/guardian consent for students under 18.

We process personal data to:

• Deliver tuition and educational consultancy (via Director or Agency Tutors)

• Provide mentoring, admissions advice, or educational consultancy to students

• Communicate with universities, schools, or other educational institutions as needed for student support

• Monitor academic progress

• Manage scheduling and invoicing

• Respond to enquiries and maintain professional records

Data sharing with Agency Tutors:

• Agency Tutors receive only the personal data necessary to deliver lessons. Agency Tutors are independentData Controllers for personal data they collect and process in the course of providing tutoring services toclients.

• Agency Tutors must comply with HE’s Privacy and Safeguarding Policies when handling data received fromHE, and must provide their own privacy notice to clients or rely on HE’s Privacy Policy where authorised.

We do not sell or trade personal data.

HE does not use personal data for automated decision-making or profiling that produces legal or similarlysignificant effects.

We process personal data under:

• Contract performance - to provide tuition, consultancy, and mentoring services

• Legitimate interests - to operate our business professionally

• Legal obligation - for tax, accounting, or safeguarding purposes

• Consent - for sensitive personal data

Consent may be withdrawn at any time without affecting prior lawful processing.

We also collect, use and share aggregated data such as statistical or demographic data which is not personaldata as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’usage data to calculate the percentage of users accessing a specific service feature in order to analyse generaltrends in how clients interact with our services to help improve our service offering.

Data is shared only where necessary, including with:

• Professional advisers (accountants, legal advisers)

• Secure IT/cloud providers

• Online lesson platforms

• Payment processors

• Agency Tutors (for lesson delivery only, following HE’s policies)

• Schools or universities, only where necessary to provide agreed services

• Safeguarding or regulatory authorities, including local authority children’s services and the police, whenlegally required or where there is a risk of significant harm to a child

All third parties must handle data securely and lawfully.

Some third-party providers may be located outside the United Kingdom. Where personal data is transferredinternationally, HE ensures appropriate safeguards are in place in accordance with UK Data ProtectionLegislation, such as standard contractual clauses or adequacy decisions.

We require all third parties to respect the security of your personal data and to treat it in accordance with thelaw. We do not allow our third-party service providers to use your personal data for their own purposes andonly permit them to process your personal data for specified purposes and in accordance with our instructions.

HE may use online platforms, video conferencing tools, or cloud-based services to deliver tuition orconsultancy services. Where such platforms include links to third-party websites, plug-ins or applications,clicking on those links or enabling those connections may allow third parties to collect or share data about you.We do not control these third-party websites and are not responsible for their privacy statements. When youaccess third-party services, we encourage you to read the privacy policy of every service you use.

• HE is committed to protecting children and young people. The Director of HE acts as the DSO and isresponsible for receiving safeguarding concerns, maintaining safeguarding records, and liaising withexternal agencies where appropriate.

• HE provides safeguarding guidance and a policy to Agency Tutors delivering tuition.

• Agency Tutors are self-employed and responsible for the safety and safeguarding of students duringlessons they deliver.

• Agency Tutors must report any safeguarding concerns for HE-introduced clients to HE’s DSO (Director)for oversight and record-keeping.

• Director-delivered tuition: Director acts as DSO and manages all safeguarding matters directly.

• Safeguarding records are confidential and stored securely in line with Data Protection Legislation. Allpersonnel must make clear, factual notes of any disclosures or concerns, recording the date, time, location,context, and the child's exact words wherever possible.

• Parents/guardians are responsible for general supervision of their children, as appropriate.

• HE maintains a framework to promote safe practices and may request confirmation that tutors complywith safeguarding requirements, without assuming direct legal responsibility for tutors’ actions.

• Safeguarding considerations override general confidentiality obligations where there is a legal obligation, arisk of significant harm, or necessity to protect a child’s welfare.

• For students under 18, HE may process data for safeguarding purposes and cooperate with statutoryauthorities if there is a concern of risk or harm.

This policy should be read alongside HE’s Safeguarding Policy.

• Student academic records: Until completion of the academic/university cycle, then securely deleted oranonymised. Upon conclusion of the tutoring relationship, relevant emails and personal data will bedeleted from HE’s systems within a reasonable period

• Financial records: Six years per legal requirements

• Agency Tutor records: Duration of engagement plus six years

• University/school correspondence records: Retained as necessary for ongoing services or legal requirements

• Contact details of former clients: Where a client or former client (or their parent/guardian) has consentedto HE retaining their contact details for the purpose of maintaining the relationship or futurecorrespondence, HE may retain such contact details until consent is withdrawn. Academic records andlesson notes will still be securely deleted or anonymised in accordance with the retention periods set outabove

• Safeguarding records are retained in accordance with statutory guidance and for as long as necessary to protect the welfare of children and vulnerable persons.