1. Who we are
ACEL-Pro is provided by ALTA Education Limited.
ALTA Education Limited
Regent Court
70 West Regent Street
Glasgow
G2 2QZ
Scotland
Company number: SC784684
ICO registration reference: ZB750191
Date registered: 13 September 2024
Registration expires: 12 September 2026
For data protection queries relating to ACEL-Pro, please contact:
support@alta-education.com
2. What ACEL-Pro is
ACEL-Pro is a pupil-level evidence platform designed to support schools and local authorities
in building a clearer picture of mathematical learning over time.
It helps schools gather structured evidence of pupil progress, support teacher judgement,
and provide leaders with clearer information about learning, gaps and attainment.
ACEL-Pro is designed around data minimisation. We aim to process only the personal data needed
to provide the service.
3. Who is responsible for the data?
When a school or local authority uses ACEL-Pro, the school or local authority will usually be the
Data Controller.
This means they decide what personal data is entered into ACEL-Pro and how it is used within their
school or authority.
ALTA Education Limited will usually act as the Data Processor.
This means we process personal data only to provide ACEL-Pro and only in line with the instructions
of the school or local authority.
4. Personal data ACEL-Pro may process
Pupil data
ACEL-Pro may process the following pupil data:
- first name and last name, or a pseudonymised identifier if preferred by the school
- school
- year group
- class
- intervention group membership
- responses to mathematical tasks
- timestamps
- system-generated indicators of mathematical progress
- first language, only where a school chooses to use native-language scaffolding for a pupil
First language is used only to provide access to pre-prepared translated ALTA content where this
feature is enabled by the school.
Pupil input is not sent to any external AI or translation provider.
Staff data
ACEL-Pro may process the following staff data:
- name
- email address
- password, stored in hashed form and never in plain text
- school or local authority association
- user role, for example teacher, school leader or local authority user
- limited account and activity records relevant to use of the platform
5. Data ACEL-Pro does not routinely collect
ACEL-Pro is not designed to collect or require:
- pupil date of birth
- home addresses
- parent or carer contact details
- demographic or socioeconomic categories such as FSM or ASN
- special category personal data as part of its standard operation
ACEL-Pro is not designed to collect, store or process special category personal data such as health
information, ethnicity, biometric data or religious belief.
6. Why personal data is used
ACEL-Pro processes personal data only for the purpose of providing and maintaining the service.
This includes:
- providing curriculum-aligned mathematical practice
- building a longitudinal evidence base of pupil learning
- supporting teacher judgement with structured evidence over time
- giving school and local authority users appropriate insight into progress and attainment
- supporting moderation and attainment discussions
- providing optional native-language scaffolding where enabled by the school
- maintaining and supporting the secure operation of the platform
- providing technical and account support
We do not sell personal data.
We do not use pupil data for advertising.
7. Who can access data in ACEL-Pro?
Access is controlled by user role and organisational boundary.
Pupils
Pupils can access practice activities and, where enabled, their own learning history.
Teachers
Teachers can access information relating only to pupils and groups assigned to them.
School leaders
School leaders can access school-level information and, where appropriate, pupil-level information
within their own school.
Local authority users
Local authority users can access authority-level aggregated data and, where permitted by role,
school-level information relevant to their responsibilities.
ALTA Education support access
ALTA Education may access account information where necessary for technical support, maintenance
or fault resolution.
This access is restricted and subject to role and system controls.
8. Hosting and data location
The ACEL-Pro platform, including its core application, database and backups, is hosted using
IONOS Cloud Ltd.
IONOS has confirmed in writing that, for the relevant hosting setup:
- website files, databases and backups are hosted within its European infrastructure
- for UK-based services of this type, this is typically located in Germany
-
it has no indication that customer personal data for this hosting service is being stored,
accessed or processed outside the UK/EEA
Because the service is provided on shared hosting infrastructure, more granular contract-specific
location details may not always be available.
Based on the current written confirmation from IONOS, ACEL-Pro’s core hosting environment should
be understood as being hosted within the EEA, with Germany identified by IONOS as the typical
location for this setup.
9. Third-party providers
ACEL-Pro uses a limited number of third-party providers where needed to operate the service.
Current subprocessors are:
IONOS Cloud Ltd
Used for application hosting, database hosting and backups.
MailerSend
Used for transactional emails such as password setup, password reset and service notifications.
MailerSend has confirmed that its services are hosted in Belgium, with Google Ireland Limited as
hosting provider.
MailerSend acts as a processor under its Data Processing Addendum. MailerSend has also confirmed
that data may be processed or transferred globally where MailerSend or its subprocessors operate,
using Standard Contractual Clauses where required.
ALTA Education does not share personal data with third parties except where necessary to provide
the service through approved subprocessors.
10. Security
ACEL-Pro uses technical and organisational measures to help protect personal data.
These include:
- encryption of data in transit using TLS/HTTPS
- password storage in hashed form
- role-based access controls
- technical controls to limit administrative support access
- restricted access to production systems
- limited telemetry to support system health, security and troubleshooting
- no advertising cookies within the platform
-
two-factor authentication for higher-privilege customer accounts, including school and local
authority administrator users
- two-factor authentication for ALTA Education administrative access
-
password creation and reset rules aligned to modern security practice, including minimum length
requirements and checks against known compromised passwords
Further technical detail can be provided where needed as part of DPIA or IT/security review.
11. Cookies
The ACEL-Pro website does not use analytics or advertising cookies.
The ACEL-Pro platform may use essential cookies or similar technologies where needed for secure
login and basic service operation.
These are used only to provide the service and keep user sessions secure.
12. Retention and deletion
Personal data is retained only for as long as needed to provide ACEL-Pro and support the school
or local authority’s use of the service.
During the contract period, pupil learning data is retained to support longitudinal tracking of
progress over time.
When a school or local authority stops using ACEL-Pro, they may request an export of relevant data
before deletion. This export may be provided in a commonly used format, such as CSV, where
technically possible.
After the contract ends, or on written instruction from the Data Controller, personal data will be
deleted from live systems within an agreed period.
Backup copies may remain for a limited period as part of normal hosting and backup processes before
being overwritten or deleted. Backup data is not used for active processing and would only be
restored where needed for service continuity, security or disaster recovery.
Further detail on deletion timescales and backup retention can be provided as part of DPIA or
IT/security review.
13. Data subject rights
Individuals have rights under data protection law.
These may include the right to:
- access personal data
- correct inaccurate personal data
- request deletion of personal data
- restrict how personal data is used
- object to certain types of processing
Where ACEL-Pro is used by a school or local authority, requests about pupil or staff data should
usually be made to the school or local authority first, as the Data Controller.
ALTA Education will support the school or local authority where reasonably required to help respond
to these requests.
14. Personal data breaches
If ALTA Education becomes aware of a suspected personal data breach affecting ACEL-Pro, we will
investigate promptly.
Where a breach affecting personal data is confirmed, ALTA Education will notify the relevant school
or local authority without undue delay.
We will provide the information reasonably needed to support assessment, containment and any
reporting obligations.
15. Website enquiries
If someone contacts ALTA Education or ACEL-Pro through a website form or by email, we may process
their name, email address, organisation and message so that we can respond.
We will use this information only to deal with the enquiry and any related follow-up.
16. Complaints
Questions about ACEL-Pro and data protection can be sent to:
support@alta-education.com
Individuals also have the right to complain to the Information Commissioner’s Office if they are
concerned about how personal data is being used.
The Information Commissioner’s Office can be contacted through its website:
ico.org.uk