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Introduction
This document forms a Data Sharing Agreement between ImpactEd and the Subscriber for the transit and protection of Data provided by the Subscriber while using the ImpactEd Platform. This Agreement outlines the purpose of Data sharing, the protections taken by ImpactEd and the roles and responsibilities of ImpactEd and theSubscriber.
Data Movement Overview
ImpactEd operates a secure, cloud-based Platform which processes Data in order to support school-led monitoring and evaluation. Personal Data processing takes place through the Platform and is protected through a number of mechanisms:
Data is processed relating to school staff and students (see details below). On setup, staff Data is provided to Administrators for the purposes of setting up User accounts. This can then be amended as new staff members are added to the Platform, or existing staff details are updated.
Student Data takes two forms. Enrolment Data relates to the variables required to setup students on the platform. This is transferred securely from school MIS to the Platform through a REST API or via an encrypted spreadsheet template accessed within the Platform, and can be updated as required by the Subscriber within the Platform. Self-Assessment Data relates to student responses to surveys taken through the Platform, which are generated and stored within the Platform, and can be exported by Users as needed.
Transfer and Use of Personal Information
Data is processed for (i) offering the monitoring and evaluation services provided by the Platform and (ii) anonymised research and statistical purposes to provide improvements to the Platform. ImpactEd will only process Data provided by the Subscriber or any User (i) in accordance with the written instructions of the Subscriber(including this Agreement) or (ii) where required to do so by applicable law, court, regulatory process or regulation, in which case ImpactEd shall, to the extent permitted by the Data Protection Legislation inform the Subscriber of that legal requirement before the relevant processing of the affected Data.
The data areas processed can be reviewed by the Subscriber at any time within the Platform, and a current list is provided below. While the Subscriber may determine access to the Data being processed at its sole discretion, the functionality of the Platform may be affected by Subscribers not providing specific fields.
ImpactEd will comply with all obligations and procedures set out under the Data Protection Legislation. Except as expressly stated, the Subscriber is the Controller and ImpactEd is the Processor.
Data Security and Processing Obligations
ImpactEd will implement and maintain all appropriate technical and organisational security measures: (i) to ensure a level of security appropriate to the risk to the Data when it is processed by ImpactEd including, as appropriate, the measures referred to in Article 32(1) of the GDPR, and (ii) to assist the Subscriber in the fulfilment of its obligations to comply with the Data Protection Legislation.
ImpactEd will:
The Subscriber will:
Data Lifecycle
Data will be processed for the duration of the Subscription Agreement. Upon termination or expiry of the Subscription Agreement, save where applicable legislation prevents this, all Personal Data will be fully anonymised and retained by ImpactEd for research purposes. ImpactEd hereby undertakes that no individual will be personallyidentified or identifiable by such retained and anonymised Data, and the Subscriber acknowledges that any anonymised Data does not fall under the protection of the relevant Data Protection Legislation. Prior to termination of the Agreement and the subsequent full anonymisation, the Subscriber will retain the option to access, exportand delete Personal Data.
Data Shared
For the purposes of operating the Platform, the Platform requires specific personal information about school staff and students. The Subscriber may determine access to the Data being processed at its sole discretion, although the functionality of the Platform may be affected by Subscribers not providing specific fields. Please note thatImpactEd system Administrators are only able to access student-level data on an anonymised basis.
This personal information is based on a range of criteria. An indicative overview of the data types shared is outlined below; school requirements and data availability mean that in many cases a lesser level of data than listed is actually transferred. A full list of fields processed is visible at all times within the Subscriber’s data sharing dashboard provided by Wonde and is maintained at: http://tiny.cc/IEpermissions which should always be taken as the latest version of the Data processed. The Subscriber may approve or revoke data access at any time through the Wonde dashboard. Please note that denial of access to requested fields may affect or reduce Platform functionality.
Overview of data types shared
Data pertaining to school staff:
Data pertaining to school students:
Subprocessors
ImpactEd uses certain Subprocessors to assist it in delivering the Platform. ImpactEd requires its Subprocessors to satisfy the same Personal Data processing requirements as it has agreed to with the Subscriber. ImpactEd undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy andconfidentiality practices of proposed Subprocessors that will or may have access to or process Personal Data.
ImpactEd shall remain fully liable to the Subscriber for the performance of the Subprocessor’s Data protection obligations within the liability as outlined in our Terms and Conditions. The following page contains an up-to-date list (as of the date of this Agreement) of authorised Subprocessors used by ImpactEd to process Data:http://tiny.cc/IEsubprocessor
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