EdPsychEd Ltd
Company No: 12925284
Registered in England and Wales
Registered Address: 81-83A ALLERTON ROAD, MOSSLEY HILL, LIVERPOOL, L18 2DA
1. Introduction
The EBSA Partnership Initiative, operated by EdPsychEd, is committed to protecting your privacy. This policy explains how we collect, use, share, and protect your personal information in relation to the EBSA Horizons training programmes.
This policy applies to all users of the EBSA Horizons training and related platform, including (but not limited to) Headteachers, School Leads, School Staff Users, Local Authority Heads of Service, and Local Authority Professionals. By participating in the EBSA Horizons training, visiting, or otherwise consuming, content from this website, you agree to these terms.
EdPsychEd is the primary data controller for the EBSA Partnership Initiative, responsible for processing personal data in compliance with UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
If you have any comments or enquiries regarding the practices outlined here, you can contact us via email: [email protected]
2. Definitions
Personal Data: Any information relating to an identifiable person.
Data Subject: An individual who can be identified by personal data.
Data Controller: The entity determining the purposes and means of processing personal data.
Data Processor: An entity processing personal data on behalf of the controller.
Processing: Any operation performed on personal data.
Legitimate Interests: A lawful basis for processing personal data under UK GDPR.
3. Personal Data We Collect
EdPsychEd collect different types of personal data depending on your role:
Headteachers, School Leads, Local Authority Heads of Service:
- Name, email address
- Progress within training courses
- School or organisation's progress
School Staff Users, Local Authority Professionals:
- Name, school email address
- Progress within training courses
4. How We Use Your Data
We use your personal data to:
- Administer the EBSA Horizons training programmes
- Track individual, school-wide, and service-wide progress
- Communicate about training and progress
- Share progress information with relevant parties
- Improve and optimise the training programmes
- Provide support and respond to queries
- Comply with legal obligations
We do not use your personal data for any marketing communications.
5. Legal Basis for Processing
We process your personal data based on legitimate interests, as per Article 6(1)(f) of the UK GDPR. This is necessary for implementing and monitoring the EBSA training initiative.
Our legitimate interests include:
- Ensuring effective delivery and management of the training programme
- Tracking and improving the initiative's success
- Providing targeted support to participants
- Maintaining consistency across participating schools and Local Authorities
We have balanced the legitimate interests with your individual rights and freedoms. If you have concerns, you have the right to object to this processing.
6. Data Sharing
We share your personal data only with relevant parties:
Headteachers and School Leads:
- Data shared with involved Local Authority employees
School Staff Users:
- Personal data shared with school's Senior Leadership Team and staff supporting the initiative
- Anonymised, aggregated data shared with involved Local Authority employees
Local Authority Heads of Service:
- Data shared with involved Local Authority employees
Local Authority Professionals:
- Personal data shared with Service's Senior Leadership Team and staff supporting the initiative
- Anonymised, aggregated data shared with involved Local Authority employees
We do not sell any personal information to third parties, or use for any marketing purposes.
7. Third-Party Service Providers
We use the following third-party service providers:
GoHighLevel: Our primary platform for managing the training programme.
Kajabi: Online training platform hosting.
Make.com: Workflow automation and integration platform.
Zapier: For automating processes and integrating systems.
Cloudflare: For website security and optimisation.
Notion: Documentation, project management, and collaboration platform.
These are established providers who are contractually obligated to use your personal data only for providing services to us and in compliance with all data protection laws. Please refer to their respective privacy policies for more information.
8. Data Minimisation and Retention
We collect and process only necessary personal data. We retain your data for the duration of the EBSA Horizons training initiative and for 5 years thereafter to:
- Evaluate long-term impact
- Respond to post-completion queries
- Comply with legal requirements
After this period, we will securely delete or anonymise your personal data. If you request earlier deletion, we will comply unless legally obligated to retain it.
9. Your Rights Under UK GDPR
Under UK GDPR, you have the following rights:
1. To be informed about the collection and use of your personal data
2. To access your personal data
3. To have inaccurate personal data rectified
4. To request erasure of your personal data in certain circumstances
5. To restrict processing of your personal data
6. To data portability
7. To object to processing based on legitimate interests
8. Rights related to automated decision making and profiling
To exercise your rights, please contact our DPO using the details provided in Section 15. We'll respond to your request within one month.
10. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- Data encryption
- Regular security assessments
- Access controls and authentication procedures
- Staff training on data protection
- Incident response plans
Our third-party service providers maintain similar security standards, which we regularly review. We conduct Data Protection Impact Assessments (DPIAs) which help us identify and minimise data protection risks. We review and update our DPIAs regularly to ensure ongoing compliance and protection of your personal data.
11. Comments and User-Generated Content
The EBSA Horizons training platform from EdPsychEd allows users to comment on courses. These comments are visible to users within your organisation/school and to the EBSA Horizons team. Please exercise caution when disclosing personal information in public areas of the platform, and do not share any identifiable information about others.
12. Links to Other Websites
The EBSA Horizons training platform (hosted by EdPsychEd) may contain links to external websites. We are not responsible for the content or privacy practices of these sites. Review the privacy policy of any site you visit.
13. Updates to This Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or for operational, legal, or regulatory reasons. We will notify you of any material changes via email or through a prominent notice on our website prior to the change becoming effective. We encourage you to periodically review this policy.
14. Contact Information
For questions about this Privacy Policy or your personal data, contact our Data Protection Officer:
Email: [email protected]
Registered Address: 81-83A ALLERTON ROAD, MOSSLEY HILL, LIVERPOOL, L18 2DA
Please include "Privacy Policy Inquiry" in the subject line of your email.
15. Complaints
If you have concerns about our data processing practices:
1. Contact our Data Protection Officer first. Our DPO can be contacted at: [email protected]. You may contact our DPO for any queries relating to data protection, to exercise your rights under GDPR, or to lodge a complaint about data processing
2. If unsatisfied, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113
16. Specific Privacy Notices
To help be as concise and transparent as possible, we provide specific privacy notices for different user groups:
a. Headteachers and School Leads
c. Local Authority Heads of Service
d. Local Authority Professionals
These notices should be read alongside this main Privacy Policy. In case of conflict, the specific notices take precedence for the respective user categories.
17. Data Breach Procedures
We have procedures to address suspected personal data breaches:
1. Detection and reporting
2. Containment and recovery
3. Risk assessment
4. Notification to affected individuals and authorities (if necessary)
5. Evaluation and response
If a breach occurs that may affect your personal information, we will:
- Promptly notify you with details and our response
- Inform you of potential consequences
- Advise on protective steps you can take
18. International Data Transfers
While we primarily operate within the UK, some third-party service providers may transfer data outside the UK. In such cases, we ensure appropriate safeguards to only transfer data to countries deemed to provide adequate protection by the UK government, and organisations that have established systems and track record of compliance. Contact us for further information on our data transfer mechanisms.
19. Cookies and Similar Technologies
The EBSA Horizons training platform (hosted by EdPsychEd) uses cookies and similar technologies to enhance user experience and collect usage information. We use:
1. Strictly necessary cookies
2. Analytical/performance cookies
3. Functionality cookies
You can set your browser to refuse cookies, but this may affect platform functionality. For more details, see our Cookie Policy below.
20. Children's Privacy
The EBSA Horizons training platform (hosted by EdPsychEd) is not intended for children under 18. We do not knowingly collect data from children. If you believe a child has provided us with personal data without parental consent, please do immediately contact us at [email protected], and we will remove the information.
21. Governing Law and Jurisdiction
This Privacy Policy is governed by the laws of England and Wales. Any legal proceedings related to this policy shall be brought exclusively in the courts of England and Wales.
Last updated: 16.09.2024
By using the EBSA Horizons training platform (hosted by EdPsychEd), you acknowledge that you have read, understood, and agree to this Privacy Policy.
Q1: What personal data do you collect?
We collect names, email addresses, and training progress data. See our Privacy Policy for details.
Q2: How do you use my data?
We use your data to administer the EBSA training programme, track progress, and communicate with you about the training.
Q3: Who do you share my data with?
We share data with relevant parties within your school/Local Authority and our third-party service providers. We never sell your data or use it for marketing purposes.
Q4: How long do you keep my data?
We retain your data for the duration of the EBSA Horizons initiative and for 5 years afterwards.
Q5: How do I exercise my GDPR rights?
Contact our Data Protection Officer at [email protected]. See our DSAR Procedure for details.
Q6: Is my data secure?
Yes, we implement robust security measures to protect your data. See our Information Security Policy for details.
Q7: Do you use cookies?
Yes, we use essential, analytical, and functional cookies. See our Cookie Policy for more information.
Q8: What if there's a data breach?
We have procedures in place to detect, report, and investigate personal data breaches. We'll notify affected individuals if required.
Q9: Can I delete my data?
Yes, you can request deletion of your data. However, we may need to retain some data for legal or administrative purposes.
Q10: How do I complain about data handling?
Contact our Data Protection Officer first. If unsatisfied, you can complain to the ICO.
EBSA Horizons Training Platform - EdPsychEd Ltd
By accessing and using the EBSA Horizons training platform, you acknowledge and agree to the joint controller arrangements outlined below.
1. Joint Controller Relationships
EdPsychEd Ltd acts as the primary data controller for the EBSA Horizons platform. However, we operate as joint controllers with the following parties for specific data processing activities:
1.1 With Local Authorities (Commissioned Service)
• EdPsychEd's role: Platform administration, technical management, training delivery, and dashboard provision
• Local Authority's role: Initiative commissioning, providing initial headteacher contact details, and strategic oversight through steering group access
• Joint decisions:
o Processing headteacher contact data for training invitations
o Providing LA steering group access to aggregated progress dashboards
o Sharing school-level progress data (anonymised) for initiative monitoring
1.2 With Schools (for School Staff Training)
• EdPsychEd's role: Platform administration, technical management, and training delivery
• School's role: Determining which staff require training, uploading staff contact details, and managing internal progress monitoring
• Joint decisions:
o Processing school staff contact data uploaded by school leads
o Providing school dashboard access to designated staff and senior leadership
o Sharing individual staff progress data with school leadership teams
1.3 With LA Services (for Service Staff Training)
• EdPsychEd's role: Platform administration, technical management, and training delivery
• Service's role: Determining professional development requirements, providing staff contact details, and monitoring service-wide progress
• Joint decisions:
o Processing service staff contact data
o Sharing progress data with service leadership teams
2. Respective Responsibilities
2.1 EdPsychEd Responsibilities:
• Primary platform administration and technical management
• Implementation of appropriate technical and organisational security measures
• Maintenance of this privacy policy and joint controller terms
• Primary contact point for data subject rights requests
• Management of third-party service providers
• Coordinating data breach response procedures
• Providing data protection training to our staff
2.2 Local Authority Responsibilities:
• Providing headteacher contact details for training invitations (under their existing statutory powers)
• Ensuring appropriate internal permissions are obtained for data sharing
• Managing steering group access to LA dashboards
• Supporting identity verification for data subject rights requests
• Implementing internal policies consistent with data protection requirements
• Promptly notifying EdPsychEd of any data protection concerns
2.3 School Responsibilities:
• Making decisions about which staff require training
• Uploading staff contact details via CSV files
• Managing school dashboard access (including senior leadership team access)
• Ensuring staff are informed about the training program and data processing
• Supporting identity verification for data subject rights requests from their staff
• Ensuring they have appropriate basis for requiring staff participation
3. Data Sharing Framework
3.1 Data We Share:
With Local Authorities:
LA Dashboard access for steering group members showing:
o Individual EBSA school lead names, contact details, and their personal training progress
o Anonymised aggregated school progress data (e.g., "School A: 15/20 staff completed Level 1" - no individual staff names or progress)
o Initiative-wide progress statistics across all participating schools
Note: LA steering group CANNOT access individual school staff names or personal progress data - this remains within school-only dashboards
With Schools:
School Dashboard access showing:
o All school staff names and individual training progress (for that specific school only)
o School-wide progress summaries for internal use
• Dashboard access can be extended to senior leadership team members as determined by school leads
Note: School dashboard data is NOT accessible to LA steering group - only aggregated/anonymised school progress data is shared with LA
With LA Services:
• Service staff individual progress data with service leadership
• Aggregated service-wide progress data
3.2 Data You Share with Us:
Local Authorities provide:
• Headteacher contact details for training invitations
• Steering group member details for dashboard access
Schools provide:
• Staff contact details uploaded via CSV files by designated school leads
• Senior leadership team details for dashboard access (where requested)
LA Services provide:
• Professional staff contact details for training access
4. Data Subject Rights
4.1 Primary Contact:
EdPsychEd acts as the primary contact for data subject rights requests. Contact us at: [email protected]
4.2 Response Process:
• We will acknowledge requests within 3 working days
• We will coordinate with the relevant joint controller partner for verification and response
• Full responses will be provided within 1 month (extendable to 3 months for complex requests)
• Both parties will cooperate to ensure complete and accurate responses
4.3 Joint Controller Partner Role:
• Assist with identity verification of their staff members
• Provide any additional information held outside the EBSA platform
• Support resolution of complex requests involving both parties' records
5. Data Security and Breach Procedures
5.1 Security Measures:
• EdPsychEd implements appropriate technical and organisational measures
• Joint controller partners must implement security measures for any data they hold
• All parties must ensure staff are trained on data protection requirements
5.2 Data Breach Response:
• EdPsychEd will notify joint controller partners of suspected breaches within 24 hours
• Joint investigation and response where both parties' data is affected
• Coordinated communication to data subjects and regulators where required
• Shared responsibility for breach reporting and remediation
6. Data Retention and Deletion
6.1 Retention Period:
Personal data will be retained for the duration of the EBSA Horizons training initiative plus 5 years thereafter for evaluation purposes.
6.2 Deletion Process:
• Secure deletion using industry-standard methods
• Coordination between joint controllers for complete data removal
• Certificates of destruction provided upon request
7.1 Joint Liability:
As joint controllers, both EdPsychEd and the relevant partner organisation acknowledge joint and several liability for compliance with UK GDPR in relation to joint processing activities.
7.2 Individual Liability:
Each party remains individually liable for:
• Their own data protection breaches
• Failures in their specific responsibilities outlined above
• Non-compliance with their internal data protection policies
8. Transparency with Data Subjects
8.1 Information Provided:
Data subjects are informed of joint controller arrangements through:
• Role-specific privacy notices
• This joint controller terms document
• Platform registration information
8.2 Contact Information:
Data subjects can contact either joint controller, but we encourage initial contact through:
• EdPsychEd: [email protected] (primary contact)
• Your Organisation: [Your organisation's data protection contact]
9. Changes to Joint Controller Arrangements
9.1 Notification:
We will notify joint controller partners of any material changes to these arrangements with at least 30 days' notice.
9.2 Continued Use:
Continued use of the EBSA Horizons platform after changes constitutes acceptance of revised joint controller terms.
10. Termination
10.1 End of Joint Controller Relationship:
When your organisation's participation in EBSA Horizons ends:
• Data sharing between joint controllers will cease
• Each party will securely handle any retained data according to their retention policies
• Joint liability continues for the period data was jointly processed
10.2 Data Return/Deletion:
Upon termination, we will either:
• Securely delete your organisation's data from our systems, or
• Return data in a commonly used format if requested
• Provide certification of deletion where required
11. Governing Law and Jurisdiction
These joint controller terms are governed by the laws of England and Wales and subject to the jurisdiction of English courts.
12. Contact for Joint Controller Matters
For questions about these joint controller arrangements:
EdPsychEd Data Protection Officer
Email: [email protected]
Address: 81-83A Allerton Road, Mossley Hill, Liverpool, L18 2DA
Last updated: 03.07.25
EdPsychEd is committed to GDPR compliance. We:
1. Process personal data lawfully, fairly, and transparently.
2. Collect data for specified, explicit, and legitimate purposes.
3. Minimise data collection to what's necessary.
4. Keep personal data accurate and up-to-date.
5. Limit data retention to what's necessary.
6. Ensure appropriate security of personal data.
7. Are accountable for and can demonstrate compliance with GDPR principles.
We've implemented measures including:
- Regular staff training on data protection
- Robust data protection policies and procedures
- Data Protection Impact Assessments where necessary
- Appointment of a Data Protection Officer
For questions about our GDPR compliance, contact [email protected].
Purpose of Processing: The EBSA Partnership Initiative processes personal data to deliver and manage the EBSA Horizons training programme, track progress, and improve outcomes for children experiencing Emotionally Based School Avoidance (EBSA).
Necessity Test: The processing of personal data is necessary to:
• Administer the training programme effectively
• Track individual and collective progress
• Provide targeted support to participants
• Evaluate the initiative's impact
• Ensure consistency across participating schools and Local Authorities
We have considered alternative methods and concluded that processing this personal data is the least intrusive way to achieve these purposes.
Balancing Test: We have carefully balanced our legitimate interests against the individual's interests, rights, and freedoms:
1. Nature of the legitimate interests:
o Improving educational outcomes for vulnerable children
o Enhancing professional development for educators
o Promoting consistent EBSA support across Local Authorities
2. Impact on individuals:
o Minimal privacy impact
o Data used solely for the stated purposes
o No sensitive personal data processed
o No automated decision-making or profiling
3. Safeguards:
o Data minimisation principles applied
o Strict access controls
o Regular security assessments
o Clear privacy notices provided
o Easy opt-out process available
Based on this assessment, we believe that the legitimate interests of the EBSA Partnership Initiative in processing this personal data are not overridden by the interests or fundamental rights and freedoms of the individuals concerned. The processing is therefore lawful under Article 6(1)(f) of the UK GDPR. This LIA is reviewed annually or when there are significant changes to the processing activities.
Last reviewed: 16.09.2024
To exercise your rights under GDPR, follow these steps:
1. Submit your request to [email protected] with "DSAR Request" in the subject line.
2. Provide your full name, email address associated with your EBSA Horizons account, and specify which right(s) you're exercising.
3. We'll verify your identity within 3 working days.
4. We'll process your request within one month. If complex, we may extend this by two months, but we'll inform you within the first month.
5. We'll provide the information electronically unless you request otherwise.
6. There's no fee for the first request, but we may charge a reasonable fee for repetitive or excessive requests.
For any questions, contact our Data Protection Officer at [email protected].
Last updated: 16.09.2024
Introduction
This Cookies Policy explains how the EBSA Partnership Initiative ("we", "us", or "our") uses cookies and similar technologies on the EBSA Horizons training platform (hosted by EdPsychEd). We use cookies to enhance your user experience and collect information about how you use our service.
What are Cookies?
Cookies are small text files placed on your device when you visit our website. They help us recognise your device and remember certain information about your visit.
Types of Cookies We Use
We use the following types of cookies:
a. Strictly Necessary Cookies: Essential for the operation of our platform. They enable core functionality such as security, network management, and accessibility.
b. Analytical/Performance Cookies: Allow us to recognise and count the number of visitors and see how visitors move around our platform. This helps us improve the way our platform works.
c. Functionality Cookies: Used to recognise you when you return to our platform. This enables us to personalise our content for you and remember your preferences.
Third-Party Cookies
Some cookies may be set by third-party services we use, such as GoHighLevel, Kajabi, Make.com, Zapier, Cloudflare and Notion.
Please refer to their respective cookie policies for more information.
How to Manage Cookies
Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impair your overall user experience.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
Changes to Our Cookie Policy
We may update this Cookie Policy from time to time. Please review this policy periodically for any changes.
Contact Us
If you have any questions about our use of cookies, please contact us at [email protected].
By continuing to use the EBSA Horizons training platform (hosted by EdPsychEd), you consent to the use of cookies as described in this policy.
Terms of Use
EdPsychEd and EBSA Horizons Terms of Use
Last updated: 16.09.2024
Thank you for using EBSA Horizons!
These Terms of Use ("Terms") govern your use of the EBSA Horizons training platform and services provided by EdPsychEd Ltd. Please read these Terms carefully before using the platform. By using the EBSA Horizons training programmes, you agree to be legally bound by these Terms. If you do not agree to these Terms, please do not use the platform.
1. Use of Service
The EBSA Horizons training programmes are intended for use by professionals in educational and related fields for the purpose of training in Emotionally Based School Avoidance (EBSA). You agree to use the service only for its intended purpose.
2. User Accounts
You are responsible for maintaining the confidentiality of your account credentials. You agree to notify us immediately of any unauthorised use of your account.
3. Intellectual Property
All content provided on the EBSA Horizons training programmes, including but not limited to text, graphics, logos, images, audio clips, digital downloads, and data compilations, is the property of EdPsychEd Ltd or its content suppliers and is protected by UK and international copyright laws.
4. User Content
You retain ownership of any content you submit to the platform. However, by submitting content, you grant EdPsychEd Ltd a worldwide, non-exclusive, royalty-free license to use, reproduce, and distribute that content in connection with the service (e.g. to be shown on the platform).
5. Prohibited Conduct
You agree not to:
- Use the service for any unlawful purpose
- Impersonate any person or entity
- Interfere with or disrupt the service or servers
- Attempt to gain unauthorised access to any part of the service
6. Disclaimer of Warranties
The service is provided "as is" without any warranties, express or implied. EdPsychEd Ltd does not warrant that the service will be uninterrupted or error-free.
7. Limitation of Liability
EdPsychEd Ltd shall not be liable for any indirect, incidental, special, consequential, or punitive damages resulting from your use of or inability to use the services, training and related materials.
8. Changes to Terms
We reserve the right to modify these Terms at any time. We will notify users of any significant changes via email or through a prominent notice on our platform.
9. Governing Law
These Terms shall be governed by and construed in accordance with the laws of England and Wales.
10. Data Protection
We process personal data in accordance with our Privacy Policy and all applicable data protection laws.
11. Termination
We reserve the right to terminate or suspend your access to the service at our sole discretion, without notice, for conduct that we believe violates these Terms or is harmful to other users, us, or third parties, or for any other reason.
12. Contact Information
If you have any questions about these Terms, please contact us at [email protected].
By using the EBSA Horizons training programmes, you acknowledge that you have read, understood, and agree to be bound by these Terms of Use.