ACEL-Pro Privacy Notice

1. Who we are

ACEL-Pro is provided by ALTA Education Limited.

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.

Where ACEL-Pro is used by a school or local authority, the school or local authority is responsible for identifying the lawful basis for processing personal data. ALTA Education processes the data as processor, under 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.

ACEL-Pro does not make decisions about pupils that have legal or similarly significant effects. System-generated indicators are intended to support teacher and leader judgement, not replace it.

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 European infrastructure, with Germany identified by IONOS as the typical location for this setup.

ACEL-Pro’s transactional email is sent through Scaleway Transactional Email. Scaleway states that its Transactional Email service is hosted and processed entirely within the European Union.

On the basis of the current provider information available to ALTA Education, ACEL-Pro’s current core hosting, database, backups and transactional email subprocessors are located within the UK/EEA or EU. ALTA Education does not currently use a transactional email provider that requires routine transfer of ACEL-Pro customer personal data outside the UK/EEA or EU.

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.

Scaleway Transactional Email

Used for transactional emails such as password setup, password reset, security codes and service notifications.

Scaleway Transactional Email is used through Laravel’s standard SMTP mail transport. Transactional email data may include the recipient email address, message content needed to deliver the email, delivery metadata and related technical logs.

Scaleway states that, for its Transactional Email service, personal data is hosted and processed entirely within the European Union and that the Transactional Email technical stack is fully managed by Scaleway within the EU.

Scaleway’s public documentation identifies the Transactional Email service region as Paris (fr-par).

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. DPIA and information governance support

Schools and local authorities completing a DPIA or information governance review for ACEL-Pro can request additional technical or data protection information from support@alta-education.com.

17. 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