Primary Foundations Tuition
Privacy Policy

1. Who is responsible for your information?

Adele Woodward, trading as Primary Foundations Tuition, is the data controller for the personal information described in this notice.

Email: adele@primaryfoundationstuition.co.uk

Telephone: 07773 888017

2. Information collected

Depending on how you contact or use the service, the following information may be collected:

Parent or carer contact details, including name, email address, telephone number and address.
Child details, including name, age or year group, school year, learning goals, assessment information and relevant educational needs.
Relevant SEND, disability, health or medical information that a parent or carer chooses to provide or that is needed to deliver tuition safely and appropriately.
Session records, including attendance, progress, learning targets, resources used and brief teaching notes.
Enquiry and communication records, including information submitted through the website form, email, telephone or messaging services.
Payment and accounting records, such as invoices and payment status. Primary Foundations Tuition does not store customers' card details.
Website information, such as IP address, browser or device information, pages visited and cookie preferences, where this is collected by Wix or related analytics tools.

3. How information is obtained

Most information is provided directly by a parent or carer through enquiries, registration forms, conversations and tuition sessions. Information may also arise from assessments and observations during tuition, or be collected automatically when someone uses the website.

4. Why information is used

To respond to enquiries and arrange tuition.
To plan, deliver and adapt personalised tuition.
To monitor progress and communicate appropriately with families.
To keep children safe and respond to safeguarding concerns.
To maintain necessary administrative, insurance, accounting and tax records.
To operate, secure and improve the website and services.
To use photographs or testimonials only where appropriate permission has been obtained.

Personal information is not sold. It is not used for direct marketing unless the appropriate consent or another lawful basis applies, and marketing preferences can be changed at any time.

5. Lawful bases for using information

The lawful basis depends on the purpose for which the information is used:
Contract — to take steps requested before tuition begins and to provide the tuition that has been arranged.
Legitimate interests — to communicate with families, plan and improve tuition, maintain proportionate business records and protect the service, provided these interests are not overridden by the rights and interests of the parent or child.
Legal obligation — where information must be kept or used to meet tax, accounting, safeguarding or other legal requirements.
Consent — for optional activities such as identifiable photographs, testimonials or marketing where consent is the appropriate basis. Consent can be withdrawn at any time without affecting earlier lawful use.
Some SEND or health information may be special-category data. Where this applies, Primary Foundations Tuition identifies both an Article 6 lawful basis and an additional Article 9 condition. Where explicit consent is relied upon, it will be requested clearly and may be withdrawn. In an emergency or safeguarding situation, another condition permitted by law may apply.

6. Sharing information

Information is shared only where necessary and proportionate. This may include:

Trusted service providers supporting website and form hosting, email and cloud storage, online tuition, learning platforms, banking, payment processing or accounting. These may include Wix, Microsoft and Google where their services are used.
Professional advisers, insurers or technical support providers where necessary.
Schools or other professionals where a parent or carer has requested or agreed to this, unless sharing is otherwise required by law or safeguarding duties.
The police, local authority, safeguarding bodies, HMRC, courts or regulators where disclosure is required or permitted by law.

Service providers are expected to protect personal information and use it only for the relevant service or as otherwise permitted by law.

7. International transfers

Some technology providers may process information outside the UK. Where this occurs, Primary Foundations Tuition takes reasonable steps to ensure that an approved transfer mechanism or other appropriate safeguard is in place, such as UK adequacy regulations or approved contractual safeguards.

8. Storage and security

Digital records are stored using password-protected devices and accounts, with access restricted to the tutor and authorised service providers where necessary.
Paper records, if used, are stored securely.
Reasonable steps are taken to protect information against loss, misuse, unauthorised access or disclosure.
Information is reviewed and securely deleted or destroyed when it is no longer required.

9. How long information is kept

Retention depends on the type of information and why it is needed:

Enquiries that do not lead to tuition are normally retained for up to 12 months after the last contact.
Client contact details, tuition records and routine session notes are normally retained during tuition and for up to two years after tuition ends, unless there is a clear reason to retain them for longer.
Financial and tax records are retained for the period required by HMRC and other applicable law.
Safeguarding records may be retained for longer where necessary, taking account of their nature and relevant legal or professional guidance.
Photographs, testimonials and consent records are retained only while they remain relevant, or until consent is withdrawn where consent is the basis.

10. Children's information

Children's information is used only where it is relevant to tuition, safety, administration or a legal obligation. A parent or carer will normally provide information and manage the tuition relationship. Data-protection rights belong to the child; depending on the child's age and understanding, the child may exercise those rights directly or a parent or carer may act on their behalf.

Primary Foundations Tuition does not normally contact a child directly without the knowledge of their parent or

11. Cookies and website analytics

The website is hosted using Wix. Wix and connected tools may use essential cookies and, where enabled, analytics or other optional cookies. Visitors can use the site's cookie banner or settings to accept, reject or manage non-essential cookies. Browser settings can also be used to control cookies, although some site functions may be affected.

12. Your information rights

Depending on the circumstances, you or your child may have the right to:

Ask for access to personal information and receive a copy.
Ask for inaccurate or incomplete information to be corrected.
Ask for information to be deleted in certain circumstances.
Ask for the use of information to be restricted in certain circumstances.
Object to processing based on legitimate interests or to direct marketing.
Receive certain information in a portable format where the right to data portability applies.
Withdraw consent at any time where consent is the lawful basis.
Complain about how personal information has been handled.

These rights are not absolute and may depend on the circumstances. To make a request, contact Adele Woodward using the details above. Identity may need to be verified before a request is completed.

13. Complaints

Please contact Primary Foundations Tuition first if you have a concern so that it can be considered and, where possible, resolved. You also have the right to complain to the Information Commissioner's Office (ICO):

Website: www.ico.org.uk/make-a-complaint

Telephone: 0303 123 1113

14. Updates to this policy

This privacy policy may be updated to reflect changes in law, technology or business practice. The most recent version will be published on the Primary Foundations Tuition website with its updated date.

Primary Foundations Tuition Privacy Policy