Privacy statement

Draft for review. Replace the bracketed items before publishing and have a data protection adviser check it.

Plan Do Review stores no pupil information and sends no pupil information anywhere. It is a planning tool that runs in the web browser of the member of staff using it.

What happens to what staff type in. Pupil details, notes, targets and photographs are held in the browser's memory only while the page is open. They are not saved on a server, in a database or on the device. They disappear when the page is closed or refreshed. The tool has no accounts and no pupil records to keep, share or lose.

What the tool remembers. Only school settings: the school name, crest, colour theme, staff names and web links. For licensed schools these are set by us in a settings file and are not entered by staff. They must not include pupil information.

What the tool does not do. The planner sets no cookies and uses no analytics, advertising or tracking. School addresses are protected by a sign-in service, which sets one cookie to remember that a member of staff has signed in. It does not use artificial intelligence or send notes to any outside service. Pupil text is matched to strategies by the browser itself.

What leaves the browser. Only what a member of staff chooses to copy, print or download, such as a plan or profile PDF. These files can contain pupil information, so the school is responsible for storing and sharing them under its own policies.

Technical requests. All files, including fonts and the PDF library, are served from our own domain. Our hosting provider, [provider], receives ordinary technical information such as the IP address of each visit and keeps short-term logs. [Confirm your host's logging and location.] None of it includes pupil information.

Your responsibilities. Staff should enter initials rather than full names. The school remains the data controller for anything staff enter and for the files they create, and decides the lawful basis, retention and access.

Contact. [Company name], [address], [email protected]. [Add your full privacy notice for business contacts, or link to it.]

Questions data protection officers ask

Question	Answer
Does the product store pupil data?	No. Entries live in the browser's memory while the page is open and are gone when it is closed or refreshed. There is no database, no account system and no server copy.
Does it send pupil data anywhere?	No. The page makes requests only to our own domain for its files and your school's settings. Nothing staff type in is sent.
Who is the controller and who is the processor?	The school is the controller of anything its staff enter and of the plans and PDFs they create. Because we never receive or hold pupil information, we do not expect to act as a processor. Your DPO should confirm this view.
What could staff enter?	Free text, so anything: initials, strengths, needs, medical conditions, personal care and safeguarding-related notes, and a photograph. The tool cannot stop a user typing a full name, so staff training and your policy matter. Much of it is special category data once typed.
What is the lawful basis? Is a DPIA needed?	Those are for the school to decide, as for any SEN support plan. The product holds no pupil data, which keeps the risk low, but your wider use (downloaded PDFs, photographs, shared plans) can be included in your own assessment.
Does it use AI, profiling or automated decisions?	No. A keyword matcher in the browser suggests barriers from pasted notes, and staff choose what to use. No decision about a pupil is made by the tool.
Does it use cookies, analytics or tracking?	The planner sets none and has no analytics or advertising. Our security settings stop it loading anything from other companies. The sign-in for school addresses sets one cookie to remember that a member of staff has signed in. [Confirm against your access provider's documentation.]
What third parties are involved?	None receive pupil information. Our hosting provider, [provider], serves the files and sees IP addresses and browser details in its logs.
Are there international transfers?	No pupil data is transferred. [State where your host serves the site from and whether any technical logs leave the UK or EEA.]
How is it secured?	There is nothing to breach on our side because pupil information is never held. The site is served over HTTPS with a strict content security policy, and access to each school's address is limited to that school's staff. Risks that remain are on the school's side: shared computers, downloaded PDFs, photographs and who the files are sent to.
What about retention, access requests and breaches?	We hold no pupil information to keep, disclose, erase or lose. Requests and incidents involving downloaded files are for the school to handle under its own procedures.
What do you hold about us?	Business contact details and invoices for the licence. Please never send us pupil information, including in support emails.
What if the product changes?	We will tell you before any change that would mean storing or sending pupil information, and we will agree a data processing agreement first.