Legal
Privacy policy
This policy explains how Sendiphany collects, uses and protects personal data, including special category data about pupils, in line with UK GDPR and the Data Protection Act 2018.
Last reviewed
1. Who we are
Sendiphany Ltd (“Sendiphany”, “we”, “us”) is a UK company providing software for SENCOs to manage SEND administration, including drafting the school’s contribution to EHC plans and keeping pupil records, deadlines and local authority correspondence. Questions about this policy go to privacy@sendiphany.co.uk.
2. Controller and processor
For pupil, parent and carer, and staff-contribution data entered into Sendiphany, the school (or trust) is the data controller: it decides what is recorded and why. Sendiphany is the data processor and acts only on the school’s documented instructions, as set out in our data processing agreement. For the account details of staff users, for contact and demo enquiries, and for billing, Sendiphany is the controller.
3. What we collect
- Account data: name, work email address, role and school for each staff user, and security data such as sign-in times, failed attempts and whether two-factor authentication is enabled.
- Pupil data (as processor): name, date of birth, year group, unique pupil number where recorded, SEN status and area of need, and the special educational, health and care information school staff choose to record, including special category data under Article 9 UK GDPR where it is necessary to prepare EHC plan content and related records.
- Contributions (as processor): views submitted by parents, carers and school staff through secure, token-scoped links, with any consent to share that the contributor gives.
- Documents (as processor): files staff upload as evidence, held in private storage scoped to the school.
- Usage and audit data: an audit log of actions taken in the account (who did what and when), and records of emails we send, kept so the school can show its own compliance.
- Billing data: subscription status and invoices. Card details are collected and held by Stripe, not by us.
- Enquiries: what you send through the contact and demo forms, and the email address you give.
4. How we use it
- To provide the service to schools and their staff, which is the school’s instruction to us as processor and, for account data, our contract with the school.
- To send deadline reminders and service notifications to staff who have them switched on, and to send a local authority chase email where the school has opted in for a plan.
- To draft the school’s contribution to an EHC plan using an AI provider, only where the school has recorded its lawful basis and consent for the pupil, and with identifiers pseudonymised first (see section 5).
- To keep the service secure: rate limiting, login lockout, idle sign-out, audit logging and investigation of incidents.
- To take payment and issue invoices.
- To answer enquiries. We do not send marketing email to people who have only enquired, and we do not buy or sell contact lists.
5. AI processing
AI drafting is switched off for every pupil until a member of school staff records on the pupil’s record that the school has a lawful basis and consent for it. Before any content is sent to our AI provider, the pupil’s name, date of birth, school name and the names of listed adults are replaced with placeholders; real values are re-inserted only when the draft comes back and never leave the system. The provider is instructed to use only the evidence supplied and to flag missing information. Prompts and outputs are not used to train AI models. The draft is saved with the model used and the evidence it drew on, and it must be reviewed and edited by the SENCO before use. Pseudonymisation can only replace identifiers the school has recorded; a nickname or an unlisted professional in a pasted report will not be replaced, and the consent copy in the app says so. More detail is on the responsible AI page.
6. Sharing and sub-processors
We share personal data only with the sub-processors we need to run the service, listed with their purpose on the sub-processors page, and with the school that controls it. We do not sell personal data, share it with advertisers, or use pupil data for any purpose other than providing the service. We will disclose data where the law requires it and, where lawful, tell the school first.
7. International transfers
School data is stored in the United Kingdom: the database is hosted in London and the application’s server functions run in London. Some sub-processors process data outside the UK, mainly in the United States: Anthropic, which drafts plan text when a school uses the AI features, stores data in the US, and Resend and Stripe keep some account and transaction data there. Where personal data is transferred outside the UK, we rely on the UK International Data Transfer Agreement or Addendum, or on UK adequacy regulations, as set out in the data processing agreement. The region for each sub-processor is listed on the sub-processors page.
8. Retention
Pupil and school records are kept for as long as the school’s account is active and then dealt with on the school’s instruction: the school can export all of its data as JSON from the app at any time, and can request deletion of a pupil record or the whole account from the app. Erasure is verified and logged and takes place after a seven-day cooling-off period because it is irreversible. Account data for staff users is kept while they have access and for a limited period afterwards for security and audit purposes. Enquiry data is kept for as long as needed to deal with the enquiry and a reasonable period afterwards. Where law requires longer retention, we follow it.
9. Security
Data is encrypted in transit and at rest, each school’s data is separated by row-level security in the database, documents sit in private storage scoped to the school, two-factor authentication is available to every user, sessions sign out after 30 minutes of inactivity, and administrative access is restricted and logged. Our security page describes these measures and states plainly which certifications we do not yet hold.
10. Your rights
Under UK GDPR you can ask to access, correct, erase, restrict or receive a copy of your personal data, and object to certain processing. For pupil, parent and staff-contribution data the school is the controller, so requests should go to the school in the first instance; we help the school respond, as the data processing agreement requires. For account, enquiry or billing data, email privacy@sendiphany.co.uk. You can complain to the Information Commissioner’s Office at ico.org.uk.
11. This website
The public website does not run advertising or third-party analytics. The signed-in application sets the cookies needed to keep you signed in and to enforce the idle time-out, and nothing else. The contact and demo forms include a hidden field that catches automated submissions; it holds no data about you.
12. Changes and contact
We will update this policy as the service changes and show the review date at the top of the page. Material changes affecting schools are notified to the account owner. Sendiphany Ltd, privacy@sendiphany.co.uk.
This policy describes our practice and does not constitute legal advice.