Dear Swale Academies Trust,

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.

The Company website statement on this page says: "{name} Swale Academies Trust. I am a strong supporter of CENTURY and our school chain has been a fortunate early pioneer of the learning technology. Swale Academies Trust has adopted CENTURY throughout its schools and the impact it is having on both the teachers and students is outstanding." [source: https://www.century.tech/case-studies/ ]

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 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 in the 12 months before the Century Tech AI was introduced into the school

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;

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

5) How many (quantity) of pupil and/or staff records (each totalled per location) the company has acquired, has or has had access to from the Trust. (confirm current 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.

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

8) Any correspondence / communication / privacy notice regards the 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 decsion-making.

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

Thank you for your consideration.
Sincerely,

Jen Persson
defenddigitalme

Dear Swale Academies Trust,
this FOI request was due within 20 working days, by October 23. Today November 2, there has been no response.

Please can you acknowledge the request, and let me know if and when you expect to reply with information, to save time and effort on everyone's part, going through the Internal Review and then decsion notice process.

Thank you.

Sincerely,
Jen Persson

5 Attachments

Dear Jen Persson, 

 

This Freedom 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.

 

The Company website statement on this page says: "{name} Swale Academies
Trust. I am a strong supporter of CENTURY and our school chain has been a
fortunate early pioneer of the learning technology. Swale Academies Trust
has adopted CENTURY throughout its schools and the impact it is having on
both the teachers and students is outstanding."
[source: [1]https://www.century.tech/case-studies/]

 

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 school(s) and the company; (Century-Tech Limited or its partners and
representatives)

 

Please find attached the original Subscription Terms and the Addendum to
Subscription.

 

2) Limited with regard only its introduction, School Governor and/ or all
Parents' meeting minutes or notes of discussion carried out in the 12
months before the Century Tech AI was introduced into the school

 

There are no minuted meetings/ notes of discussions.

 

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;

 

Apart from the T&Cs between individual schools, there were no impact
assessments devised for this joint working/ project drawn up between Swale
Academies Trust and Century Tech.

 

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

 

As above (1) please find attached the original Subscription Terms and the
Addendum to Subscription

 

5) How many (quantity) of pupil and/or staff records (each totalled per
location) the company has acquired, has or has had access to from the
Trust. (confirm current status)

 

Current Current
Number of Number of Status Status
Name Students Teachers Students Teachers
   
Regis Manor
Primary School 436 80 0 0
Westlands School 2201 658 0 0
Meopham School 571 110 0 0
Sittingbourne 0 0
Community College 1285 366
The Eastbourne 0 0
Academy 654 135

 

 

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.

 

In full compliance with the DPA and GDPR, CENTURY holds personal data and
anonymised data in separate and secure databases. When a school ceases to
be a CENTURY subscriber / user, CENTURY deletes ALL personally
identifiable data, including in any backups, in compliance with the GDPR.

 

CENTURY does not sell or otherwise monetise data. CENTURY uses anonymised
(and not personal) data generated through use of its platform to improve
its recommendation algorithms which seek to improve students’ learning
outcomes.

 

Name Date First User Onboarded Data in Use
Regis Manor Primary School 2017-11-16 Data being deleted
Westlands School 2016-10-10 Data being deleted
Meopham School 2017-02-23 Data being deleted
Sittingbourne Community
College 2017-11-10 Data being deleted
The Eastbourne Academy 2017-12-12 Data being deleted

 

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

 

None.

 

8) Any correspondence / communication / privacy notice regards the 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 decsion-making.

 

There has been no automated decision-making. Please find attached Swale
Academies Trust Privacy Notices for Pupils, Parents and Staff.

 

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 (a third-party data
integration service), GroupCall handles any opt-out requests, and does not
send the information to CENTURY. For non-GroupCall users, we process any
opt-out and deletion requests in a timely manner, and in compliance with
GDPR.

 

Thank you for your consideration.

Sincerely,

 

Jen Persson

defenddigitalme

 

--
Cat Taylor
Head of Projects and Estates, Swale Academies Trust
01795 418569 (direct)
[2][email address
Swale Academies Trust
Ashdown House
Johnson Road
Sittingbourne
Kent, ME10 1JS
Registered in England and Wales
Company Number: 07344732

References

Visible links
1. https://www.century.tech/case-studies/
2. mailto:[email address]

Dear C Taylor,
thank you for the reply.

May I please ask you to clarify some of the response (partly where numbers were provided as they are not in table format and the system reply appear to have included added zeroes?) and I would like to ask for a confirmation and clarification to some of the answers.

Many thanks.
Sincerely,
Jen Persson

Re reply to question
3): Please provide 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;

You replied, "Apart from the T&Cs between individual schools, there were no impact assessments devised for this joint working/ project drawn up between Swale Academies Trust and Century Tech."

>> Please can you provide these if different from the one example you provided, or confirm that this one document was the same entered in to for each school?

Re reply to question 4:
4) You provided an Addendum to Subscription >> please can you confirm the date of that addendum, as it entered into agreement.

Re reply to question 5:
5) How many (quantity) of pupil and/or staff records (each totalled per location) the company has acquired, has or has had access to from the Trust. (and confirm current status)

Regis Manor Primary School
Pupils: Four hundred and thirty Six
Staff: Eighty

Westlands School
Pupils: Two thousand, Two hundred and one
Staff: Six hundred and Fifty Eight

Meopham School
Pupils: Five hundred and seventy one
Staff One hundred and ten

Sittingbourne Community College
Pupils: One Thousand Two hundred and Eighty Five
Staff: Three hundred and sixty six

The Eastbourne Academy
Pupils: Six hundred and Fifty Four
Staff One hundred and Thirty five

6) In answer to the question, "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.: --- please can you clarify what "Data being deleted" means and from which orgainsation -- the company or school?

To clarify: Please provide the cerificate(s) of deletion for:

Regis Manor Primary School 2017-11-16 Data being deleted
Westlands School 2016-10-10 Data being deleted
Meopham School 2017-02-23 Data being deleted
Sittingbourne Community College 2017-11-10 Data being deleted
The Eastbourne Academy 2017-12-12 Data being deleted

9) Whether you have offered children a Right to Object, or whether the use of the tool has been compulsory? Since the privacy notices you provided make no reference to Century Tech it is hard to see how this right was offered from what has been provided.

Please can you clarify whether parents and children were offered any Right to Object -- your answers explain HOW any opt outs would have been handed by the GroupCall integration, or for schools that do not use that integration tool, but does not answer the question WHETHER there were any opt outs if any were offered.

Please therefore clarify and confirm:

a) was any opt out offered
b) did any children / parents refuse the use of the tool as a result?

Please find the responses to your questions below. 

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