Pupil data: Century Tech

Roedd y cais yn rhannol lwyddiannus.

Dear Shireland Collegiate Academy,

This Feedom of Information request relates to your interaction with Century-Tech Limited (registered number 08482934). (The Company)

Under the Act, most public authorities may take up to a maximum of 20 working days to respond, counting the first working day after the request is received as the first day. For schools, the standard time limit is 20 school days, or 60 working days if this is shorter -- I understand this will begin on your return after the Christmas holidays 2018-19.

Please provide copies of:

1) Your contracts, memoranda of understanding, or other agreements (which may include but not exclusively data sharing agreements) between the Trust or each of your school(s) and the company; (Century-Tech Limited or its partners and representatives)

2) Limited with regard only its introduction, School Governor and/ or all Parents' meeting minutes or notes of discussion carried out with them and/or staff, before the Century Tech AI was introduced into the school. [if none known of, please simply state this rather than search all historical documents]

3a) Any Information Governance documents, Data Protection Impact Assessments (or pre-GDPR Privacy Impact Assessments) created by you or the Company with regards to your joint working / project;

3b) If not already listed in 1-3 please provide a list of all the individual data type items, that have been transfered to the Company. (such as but not only, first and last name, DOB, ethnicity, attainment scores, special educational needs, home address and postcode, school name).

4) Copies of any agreement that allows Century Tech (the Company) to use pupil or staff personal data for its AI product training development and how.

5) How many (quantity) of pupil and/or staff records (each totalled per school location if used across more than one in your organisation such as a Trust) the company has acquired, has today, or has had access to from the academy. (Confirm the extraction date, the planned retention period, and current processing status.)

6) Whether the Company is still using the data today and if so, from how many and which sites, and from its date of first access. If no longer being processed, the date of destruction.

7) Whether the school is using the Company product today and if so, in how many and which sites.

8) Any correspondence / communication / privacy notice regards the introduction and/or ongoing use of the product which has been given to current pupils / pupils' parent/guardians and its interaction with the child regards data collection, processing, profiling or automated decsion-making.

9) Whether you have offered children a Right to Object, or whether the use of the tool has been compulsory.

10) If you offered children a Right to Object, please provide a copy of that notice.

11) If personal data were but are no longer being processed and have been destroyed, a copy of the data destruction notice.

Thank you for your consideration.
Sincerely,

Jen Persson

Mrs M ADAMS, Shireland Collegiate Academy

3 Atodiad

Dear Ms Persson

 

1) Your contracts, memoranda of understanding, or other agreements (which
may include but not exclusively data sharing agreements) between the Trust
or school(s) and the company; (Century-Tech Limited or its partners and
representatives)

 

We have attached the Original Subscription Terms and the Addendum to
Subscription for your convenience.

Original Subscription Terms came into effect from November 2016.

Addendum to Subscription came into effect on the 24th May 2018.

 

2) Limited with regard only its introduction, School Governor and/ or all
Parents' meeting minutes or notes of discussion carried out with them
and/or staff, before the Century Tech AI was introduced into the school.
[if none known of, please simply state this rather than search all
historical documents]

 

None known

 

3) Any Information Governance documents, Data Protection Impact
Assessments (or pre-GDPR Privacy Impact Assessments) created by you or the
Company with regards to your joint working / project;

 

We have not carried out any Data Protection Impact Assessment for this
join working with this product.

4) Copies of any agreement that allows Century Tech (the Company) to use
pupil data for its AI product training development and how

 

As 1), Original Subscription Terms and Addendum to Subscription attached.

No personal (pupil or staff) data is used to train CENTURY’s artificially
intelligent algorithms. All personal data is wholly and entirely owned by
the data subject and CENTURY uses this data only to create secure logins
for each user and to display students’ learning data to educators.

 

5) How many (quantity) of pupil and/or staff records (each totalled per
location if used across more than one in your organisation such as a
Trust) the company has acquired, has, or has had access to from the
academy. (confirm the extraction date, the planned retention period, and
the current processing status.)

 

The table below details the number of users imported and on which date.
For all, the planned retention period is until the end of subscription.

 

Total Number Total Number Number of
of Student of Teacher these users
Date of Import Users Imported Users Imported now deleted Date of deletion
28/11/2016 361 20 0 n/a
12/04/2017 0 1 0 n/a
26/04/2017 0 1 0 n/a
27/04/2017 1 0 0 n/a
04/05/2017 1 0 1 14/07/2017
21/06/2017 0 8 0 n/a
22/06/2017 1 0 0 n/a
11/10/2017 (1
deleted)

05/02/2018 (2
deleted)
14/07/2017 (5
06/07/2017 741 283 8 deleted)
13/07/2017 3 0 0 n/a
17/07/2017 1 0 0 n/a
14/08/2017 0 1 0 n/a
05/09/2017 0 23 0 n/a
06/09/2017 204 0 0 n/a
08/09/2017 0 1 1 13/02/2018
09/10/2017 0 1 1 05/02/2018
11/10/2017 1 0 0 n/a
12/10/2017 2 0 0 n/a
13/10/2017 0 1 0 n/a
25/10/2017 1 0 0 n/a
06/11/2017 1 0 1 05/02/2018
09/11/2017 1 0 0 n/a
06/12/2017 1 0 0 n/a
19/12/2017 1 0 0 n/a
08/01/2018 0 1 0 n/a
23/01/2018 40 0 1 05/02/2018
16/02/2018 1 0 0 n/a
20/02/2018 0 1 0 n/a
25/06/2018 0 4 0 n/a
16/07/2018 13 28 0 n/a
30/08/2018 1 0 0 n/a
06/09/2018 312 18 0 n/a
25/09/2018 36 4 0 n/a
25/10/2018 4 0 0 n/a
18/12/2018 0 11 0 n/a
10/01/2019 4 11 0 n/a
25/01/2019 0 3 0 n/a

 

 

6) Whether the Company is still using the data today and if so, from how
many and which sites, and from its date of first access. If no longer
being processed, the date of destruction.

 

Still in use.

 

7) Whether the school is still using the Company product today and if so,
in how many and which sites.

 

Yes.

 

8) Any correspondence / communication / privacy notice regards the
introduction and/or ongoing use of the product which has been given to
current pupils / pupils' parent/guardians and its interaction with the
child regards data collection, processing, profiling and automated
decision-making.

 

Century Learning is considered a service provider and sharing of data with
them is noted within our Privacy Notice available on our Website.

9) Whether you have offered children a Right to Object, or whether the use
of the tool has been compulsory.

 

For schools that shared MIS data via GroupCall, GroupCall handles any
opt-out requests, and does not send the information to CENTURY. For
non-Groupcall users, we process opt-out and deletion requests in a timely
manner, in compliance with GDPR.

 

10) If you offered children a Right to Object, please provide a copy of
that notice.

 

11) If personal data were but are no longer being processed and have been
destroyed, a copy of the data destruction notice.

 

Kind regards

 

Melanie Adams, Chartered FCIPD
Human Resources Director

 

 

Any rights not expressly granted herein are reserved.  All statements
expressed in this document represent the personal view of the sender
unless the contrary is stated. Shireland Collegiate Academy Trust accepts
no liability for the personal views of any sender. This communication
contains information which is confidential and may also be privileged. It
is for the exclusive use of the intended recipient(s). If you have
received this communication in error, you must not copy or distribute this
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anyone. Please notify us by telephone or return e-mail, and then delete
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accept responsibility for viruses; you must scan for these. Please note
that e-mails sent to and from the academy are routinely monitored for
record keeping, quality control and training purposes, to ensure
regulatory compliance and to prevent viruses and unauthorised use of our
computer systems.

For more details please contact: [1][email address].

Shireland Collegiate Academy is a member of the Shireland Collegiate
Academy Trust, a Chartable Company Limited by Guarantee registered in
England & Wales. Company No: 6336693

Registered Office:

Shireland Collegiate Academy Trust
Registered in England
Waterloo Road
Smethwick
West Midlands B66 4ND

References

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