Privacy Policy

1.0 Who We Are

We are a private tuition provider based in the UK.

• Company Name: Upper Bound Tuition
  
  

• ICO Reference: ZC005193
  
  

• Data Protection Officer/GDPR Lead: Joe Whitaker
  
  

• Contact: joe.whitaker@ub-tuition.co.uk

2.0 The Data We Collect

We may collect and process the following types of personal data:

2.1 Students

• Name, school year, exam board, subjects studied
  
  

• Email address
  
  

• Learning needs, including special educational needs (SEN) or medical information (if voluntarily provided and relevant to tuition)
  
  

2.2 Parents/Guardians

• Name, address, phone number, email address
  
  

• Payment and billing details
  
  

2.3 Tutors

• Name, address, phone number, email address
  
  

• CV, qualifications, DBS check, references
  
  

3.0 How We Use Your Data

We use personal data for the following purposes:

• To provide and arrange tuition services
  
  

• To communicate with parents, students, and tutors
  
  

• To issue invoices and process payments
  
  

• To meet safeguarding and child protection obligations
  
  

4.0 Legal Basis for Processing

We rely on the following lawful bases under the UK GDPR:

• Contract – processing data to deliver tuition services
  
  

• Legal obligation – e.g. safeguarding and HMRC record-keeping
  
  

• Legitimate interest – managing and improving our services
  
  
  

5.0 How We Store and Protect Data

• Data is stored securely on password-protected systems and encrypted cloud services
  
  

• Access is limited to authorised staff and tutors only
  
  

• We take appropriate technical and organisational measures to safeguard personal data
  
  

6.0 Sharing Your Data

We may share data with:

• Tutors (only information necessary to deliver lessons)
  
  

• Payment processors such as banks
  
  

• Service providers we use for communication or data storage (all GDPR-compliant)
  
  

We do not sell or share personal data with third parties for marketing purposes.

7.0 Data Retention

• Student and parent details: retained while tuition is active, and deleted within 12 months after services end (unless required for legal reasons)
  
  

• Tutor records: retained while engaged with us, and securely deleted thereafter
  
  

• Invoices and financial records: retained for 6 years, as required by HMRC
  
  

• Safeguarding records: retained in line with statutory guidance
  
  

8.0 Your Rights

Under GDPR, you have the right to:

• Request a copy of the personal data we hold about you (Subject Access Request)
  
  

• Ask us to correct any inaccurate data
  
  

• Request deletion of data that is no longer required
  
  

• Object to processing, or request we restrict use of your data
  
  

• Withdraw consent for marketing at any time
  
  

Requests can be made by contacting us using the details above.

9.0 Data Breaches

We have procedures in place to identify, report, and manage data breaches.

• If a serious breach occurs, we will notify the ICO within 72 hours and inform affected individuals when required.
  
  

10.0 Contact Us

If you have any questions or concerns about how your data is handled, please contact:

Data Protection Officer (DPO): Joe Whitaker
Email: joe.whitaker@ub-tuition.co.uk

You also have the right to complain to the Information Commissioner’s Office (ICO) if you believe your data rights have been breached: www.ico.org.uk.