Privacy version 2026-08-22-uk-v2
Privacy notice
1. Who is responsible
Literacy Guide is operated by Benjamin Bowler, trading as Literacy Guide. Privacy contact: benjamesbowler@gmail.com.
For school-directed learning, the school normally decides why learner information is used and is the controller. Literacy Guide acts as its processor when it follows those instructions. Literacy Guide is a controller for its own teacher-account security, service protection, legal records and direct website request logs. The real activity—not a label in a contract—decides the role.
2. The two current routes
School-authorised service
A teacher account creates classes and child profiles. Children sign in using a class code and three-picture credential. The service stores learning records so teachers can teach, assess and report. A teacher may create a time-limited invitation for a parent or guardian email. After that adult confirms the same email and accepts the invitation, they can see the linked child and only the family-ready report snapshots the school has deliberately released. The school can cancel an invitation, revoke the link or withdraw a report.
Anonymous try-out
The try-out creates no account, accepts no name, replaces application storage with temporary memory, disables database and authentication calls, and discards the session when the page closes. The hosting provider still receives ordinary request metadata needed to deliver the page, such as IP address, user agent, requested URL and time.
3. Information used
- Teachers: email, display name, school, account status, classes, settings, service activity, email-confirmation state and versioned legal acceptance.
- Parents and guardians: invited and confirmed email address, display name, preferred family language, future report-email preference, invitation and learner link, versioned legal acceptance, and report view or print audit events. Report emails are not sent during the current beta.
- Children: first name or chosen display name, class, picture-code credential material, accessibility/support settings, answers, progress, reading records, assessment evidence, reports, interventions and reward/game state.
- Device storage: essential sign-in state, settings, cached content, local progress, reports and retry queues needed for offline reliability and safe recovery.
- Security and reliability: time, release version, event type, one-way fingerprints, sync counts and redacted error details. The error pipeline is designed to exclude names, answers, tokens, full URLs and school, class or learner identifiers.
- Hosting requests: IP address, user agent, URL, time and related security/delivery logs held by Vercel and network providers.
Literacy Guide does not ask for a child’s email, surname, home address, phone number, precise location, uploaded photograph or free-form health/safeguarding notes. Schools must not add information that is not needed.
4. Why information is used
| Purpose | Responsibility and likely UK basis |
|---|---|
| Teaching, assessment, progress, reports and classroom administration | The school selects and documents its Article 6 basis—often public task for a state school or legitimate interests/contract where appropriate. Literacy Guide processes on documented school instructions. |
| School-invited family access to released reports | The school decides the purpose, invited adult and lawful basis for this school-controlled access. Literacy Guide processes the invitation, verified account, revocable link, released snapshot and access audit on the school’s documented instructions. |
| Accessibility and support settings | The school determines whether these reveal special-category data and records an Article 9 and Data Protection Act 2018 condition where required. |
| Teacher account requests and service delivery | Steps requested before a contract, performance of the beta terms, and legitimate interests in operating the service. |
| Security, fraud prevention, incident response and legal records | Legitimate interests and, where applicable, legal obligation. Interests are balanced against children’s rights and use data minimisation. |
Consent is not treated as a default school lawful basis. A school must make and record its own decision. There is no solely automated decision with legal or similarly significant effect, and scores do not replace a teacher’s judgement.
5. What Literacy Guide does not do
- No advertising, behavioural tracking or sale/rental of personal data.
- No direct messages, public profiles, child-to-child chat or stranger contact.
- No use of identifiable learner data to train an AI model.
- No learner prompts, answers or profiles sent to an AI provider in the deployed application.
- No optional analytics or marketing cookies.
6. Providers and international transfers
- Supabase supplies authentication, PostgreSQL storage, database functions, backups and platform support. The linked production project is currently in Sydney, Australia (ap-southeast-2).
- Vercel hosts and delivers the site and processes service-generated request/security data through its global network; its current DPA states that primary processing facilities are in the United States.
- Self-hosted fonts and media load from Literacy Guide. Google Fonts, advertising and analytics services are not used by the application.
These locations can involve a restricted transfer from the UK. Before onboarding a UK school with real learner data, the parties must verify the provider contract and appropriate safeguard (such as an applicable UK addendum/IDTA), complete the current ICO data-protection test, record the transfer chain and confirm the school accepts the storage location. A provider’s published document is not treated as proof that the operator’s account has completed the required contracting step.
7. Retention and deletion
The school controls its instructional retention within the product’s safeguards. Current default settings flag inactive learners after 365 days, delete archived learner records after 90 days, target provider deletion evidence within 30 days and backup expiry evidence within 35 days. A school can set permitted alternatives and choose archive or delete at year end.
Active learner deletion uses a staged, verified workflow covering database and browser copies. Provider and backup target dates do not prove deletion without provider or backup evidence; the product requires a retrievable evidence reference before propagation is marked verified. Guardian profiles, invitations, learner links, released-report snapshots and access audit events are retained only while needed for the school relationship, access control, rights handling, security, legal claims or statutory duties. Teacher accounts and legal/security records follow the same necessity rule. Anonymous try-out activity is not stored by Literacy Guide, although provider request logs follow the provider’s configured retention.
8. Rights and complaints
UK data-protection rights can include being informed, access, correction, erasure, restriction, objection, portability and safeguards around automated decisions. They depend on the basis and circumstances. Children have these rights too and may exercise them when they understand the request.
For a school learner record or family link, contact the school first or email Literacy Guide. Identity and authority will be checked and the request routed safely. Rights requests are normally answered within one month. To make a privacy complaint, email benjamesbowler@gmail.com with “privacy complaint” in the subject. We will acknowledge it within 30 days, investigate without undue delay, keep you informed and explain the outcome.
If you remain unhappy, you can complain to the Information Commissioner’s Office. You do not have to give up any court or statutory right.
9. Children, safety and changes
Settings are privacy-protective by default, only the minimum learner identity is requested, and school adults manage child and guardian access. Guardian sign-up alone reveals no learner record: a matching confirmed email must consume a current school invitation. A school must complete its own DPIA where processing is likely to be high risk and assess the Children’s Code, safeguarding, lawful basis, accessibility and procurement requirements that apply to its deployment.
Material changes to purposes, data, providers, storage locations, AI use, analytics or child access require a new dated notice and product review. We will not quietly use existing learner information for an unrelated purpose.