SENse Learning - Privacy Notice for Employees and Workers

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Last updated: 28 October 2025, 18:11

This policy applies to SENse Learning Limited. References to “the Company,” “we,” “us,” or “our” mean SENse Learning Limited throughout this document.

Policy owner

Chief Technology Officer

Last updated

1 October 2025

Next update due

4 March 2026

1. Purpose

The Company is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the UK General Data Protection Regulation (GDPR) and the Data Protection Act (2018). It applies to all employees, workers and contractors.

The Company is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

2. Data Protection Principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way.

  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

  • Relevant to the purposes we have told you about and limited only to those purposes.

  • Accurate and kept up to date.

  • Kept only as long as necessary for the purposes we have told you about.

  • Kept securely

3. The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

We will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

  • Date of birth

  • Gender

  • Marital status and dependants

  • Next of kin and emergency contact information.

  • National Insurance number.

  • Bank account details, payroll records and tax status information.

  • Salary, annual leave, pension and benefits information

  • Start date and, if different, the date of your continuous employment

  • Leaving date and your reason for leaving

  • Location of employment or workplace

  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process). We also record your interview in order to improve our process inline with best safeguarding practice; to ensure consistency between interviews; to ensure fairness; to protect against discrimination.

  • Qualifications including QTS

  • Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).

  • Compensation history

  • Performance information

  • Disciplinary and grievance information

  • Information about your use of our information and communications systems

  • Any feedback that you give us

  • Recordings of teaching sessions

We also collect, store and use the following more sensitive types of personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

  • Information about your health, including any medical condition, health and sickness records, including:

  • where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;

  • details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and

  • where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.

  • Information about criminal convictions and offences.

4. How is your personal information collected?

We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. We also record teaching sessions.

We may also collect personal information from the trustees or managers of pension arrangements operated by the Company.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

5. How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • Where we need to perform the contract we have entered into with you.

  • Where we need to comply with a legal obligation.

  • Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

  • When you consent to give us feedback.

We may also use your personal information in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else's interests).

  • Where it is needed in the public interest or for official purposes

6. Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests.

The situations in which we will process your personal information are listed below.

  • Making a decision about your recruitment or appointment.

  • Determining the terms on which you work for us.

  • Determining whether your engagement is deemed employment for the purposes of Chapter 10 of Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) and providing you with a status determination statement in accordance with the applicable provisions of ITEPA 2003.

  • Checking you are legally entitled to work in the UK.

  • Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs).

  • Providing employment benefits to you.

  • Inviting you to participate in any share plans operated by the Company.

  • Granting awards under any share plans operated by the Company.

  • Administering your participation in any share plans operated by the Company, including communicating with you about your participation and collecting any tax and NICs due on any share awards.

  • Sharing your email address and phone number with parents/carers to organise sessions

  • Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.

  • Liaising with the trustees or managers of a pension arrangement operated by the Company, your pension provider and any other provider of employee benefits.

  • Administering the contract we have entered into with you.

  • Business management and planning, including accounting and auditing.

  • Conducting performance reviews, managing performance and determining performance requirements.

  • Making decisions about salary reviews and compensation.

  • Assessing qualifications for a particular job or task, including decisions about promotions.

  • Gathering evidence for possible grievance or disciplinary hearings.

  • Making decisions about your continued employment or engagement.

  • Making arrangements for the termination of our working relationship.

  • Education, training and development requirements.

  • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.

  • Ascertaining your fitness to work.

  • Managing sickness absence.

  • Complying with health and safety obligations.

  • To prevent fraud.

  • To monitor your use of our information and communication systems to ensure compliance with our IT policies.

  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

  • Equal opportunities monitoring.

From time to time, the Company uses carefully selected AI tools to improve the efficiency of administrative tasks and support productivity. In some cases, this may involve processing limited personal data about you. For example, we may use these tools to help to generate summaries of notes and feedback, to check spelling and grammar in reports, and to anonymise information and records before we store them. We only ever use AI tools for our own internal purposes, and ensure that data is not used to train or develop any underlying AI models.

7. If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

8. Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

  • In limited circumstances, with your explicit written consent.

  • Where we need to carry out our legal obligations or exercise rights in connection with employment.

  • Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public

10. Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below.

We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay, statutory sick pay, pensions and permanent health insurance. We need to process this information to exercise rights and perform obligations in connection with your employment.

  • If you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, we will use information about your physical or mental health, or disability status in reaching a decision about your entitlements under the share plan.

  • If you apply for an ill-health pension under a pension arrangement operated by the Company, we will use information about your physical or mental health in reaching a decision about your entitlement.

  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

  • We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

11. Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

12. Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy and our criminal convictions policy.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.

We are allowed to use your personal information in this way to carry out our legal obligations in relation to working with children. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

Local authorities and schools / academies may request information from your DBS certificate. This will include your name, the DBS certificate number, the date of the DBS certificate and if any issues are present. It is your choice if you consent to use sharing your criminal conviction data / DBS certificate information with either a local authority or a school / academy.

13. Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

  • Where we have notified you of the decision and given you 21 days to request a reconsideration.

  • Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

  • In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

14. Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We may from time to time share your data with our funding partners.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK (see “Transferring information outside the UK”)

If we do, you can expect a similar degree of protection in respect of your personal information.

Local authorities and schools / academies may request your QTS registration number. It is your choice if you consent to us sharing your QTS registration number with a local authority or a school / academy.

We may have to share your email and phone number with parents/carers so that they can contact you to organise sessions. 

15. Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

16. Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: payroll, pension administration, occupational health, employee assistance programme, private health insurance and cash plan, accounting.

We will share personal data relating to your participation in any share plans operated by the Company with third party administrators, nominees, registrars and trustees for the purposes of administering the share plans.

We will share personal data regarding your participation in any pension arrangement operated by the Company with the trustees or scheme managers of the arrangement in connection with the administration of the arrangements.

17. How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

18. When might you share my personal information with other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, disclosures to stock exchange regulators and disclosures to shareholders such as directors' remuneration reporting requirements.

19. Transferring information outside the UK

As a default, personal data is stored within the UK.

Some or all of your personal data may be stored or transferred outside of the UK for legitimate business needs, including for example, if our email server is located in a country outside the UK or if any of our service providers are based outside of the UK.

Where data is transferred outside of the UK, we store data in places with said Adequacy Status as defined by the UK Government, or where we can use the UK’s International Data Transfer Agreement for the transfer of personal data to processors outside the UK.

20. Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

21. Data retention

21.1. How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Please see our Data Retention Schedule for all retention periods.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

22. Rights of access, correction, erasure, and restriction

22.1. Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

22.2. Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Managing Director in writing.

22.3. No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

22.4. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

22.5. Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Managing Director. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you have any complaints in relation to this Privacy Notice or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You can also contact the Information Commissioner, seehttp://www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority

23. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

 

 

If you have any questions about this policy or how it applies to you, please contact the CTO at tech@sense-learning.com