1. Who We Are
Learner360 ("we", "us", "our") is a student relationship intelligence platform designed for educational institutions. We provide schools with tools to understand student wellbeing, manage pastoral care, and support student outcomes.
We are the data processor on behalf of each school. The school is the data controller for their students' and staff data.
Contact: info@learner360.co.uk
2. What Data We Collect
School Staff (Admins & Teachers)
- Name and email address
- Role and employment relationship to the school
- Login activity and session data
Students
- Name and email address (provided by the school)
- Questionnaire responses submitted within the platform
- Student profile information (interests, subjects, goals — entered by the student or staff)
- Safeguarding flags generated from responses
- Intervention records created by staff
School Interest Submissions
- School name, address, and type
- Contact person name, email, and phone
- Approximate staff and student numbers
3. How We Use Data
- To provide the Learner360 platform services to schools
- To generate wellbeing insights and safeguarding alerts for authorised staff
- To enable AI-powered queries about student data (processed by Anthropic Claude API)
- To send notifications about safeguarding concerns and platform activity
- To improve the platform and fix technical issues
We do not sell data, use it for advertising, or share it with third parties except as described in Section 5.
4. GDPR & Legal Basis
We operate in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our legal bases for processing are:
- Contractual necessity — to deliver the service agreed with the school
- Legitimate interests — safeguarding, platform security, and service improvement
- Legal obligation — where required to retain records by law
Schools are responsible for obtaining appropriate consent from students and parents where required under their own UK GDPR obligations as data controllers.
Where safeguarding data is processed, our legitimate interest is informed by schools' statutory duties under Keeping Children Safe in Education (KCSIE) and related guidance issued by the Department for Education.
5. Data Sharing & Third Parties
- Anthropic (Claude API) — Student response data may be submitted to the Claude API for AI query processing. Anthropic processes this data under their API terms. Data is not retained by Anthropic beyond the request.
- Hosting provider — Server infrastructure provider stores encrypted data on our behalf.
- Email provider — Used to send system notifications and password resets.
All third-party processors are bound by data processing agreements. Where a processor is located outside the UK, we rely on appropriate safeguards recognised under UK GDPR, such as the UK International Data Transfer Addendum (IDTA) or a UK-approved adequacy decision, to ensure your data receives an equivalent level of protection.
6. Data Retention
- Student and staff data is retained for the duration of the school's active subscription
- Upon cancellation, data is deleted within 30 days
- Safeguarding records may be retained longer where legally required
- Backups are purged within 90 days of deletion
7. Your Rights
Under GDPR, individuals have the right to:
- Access their personal data
- Rectify inaccurate data
- Request erasure ("right to be forgotten")
- Restrict processing
- Data portability
- Object to processing
Requests should be directed to your school's data controller (the school) in the first instance, or to us at info@learner360.co.uk.
If you are unhappy with how your data has been handled, you also have the right to lodge a complaint with the UK's supervisory authority, the Information Commissioner's Office (ICO), at ico.org.uk or by calling 0303 123 1113.
8. Security
- All data is transmitted over HTTPS (TLS encryption)
- Passwords are hashed using bcrypt — never stored in plaintext
- Access is role-based — teachers only see their own students
- Safeguarding data is access-controlled and audit-logged
- Regular security reviews are conducted
9. Cookies
Learner360 uses only essential session cookies required for login and security. We do not use tracking, advertising, or analytics cookies.
10. Changes to This Policy
We may update this policy from time to time. Schools will be notified of material changes via email. Continued use of the platform constitutes acceptance of the updated policy.
11. Contact
For privacy-related questions or data requests: info@learner360.co.uk