Privacy Notice

Refocused Ltd provides a school-facing platform for managing interventions, provisions and related support records. We are registered in England and Wales under company number 16379914 and with the Information Commissioner’s Office under registration number ZC147647.

Registered office: 128 City Road, London, EC1V 2NX

Privacy contact: privacy@refocused.uk

The information we collect depends on how you interact with us. It may include:

• your name, role, school or organisation, work contact details and any message you send through our website or by email;
• customer, supplier and authorised-user information, including account, support, subscription and payment records;
• information entered into the platform by an authorised school or trust, such as pupil details, referrals, assessments, intervention and provision records, logs, files, meetings and reports; and
• basic technical and security information, such as IP address, device, login activity and audit records.

Please do not include pupil names, safeguarding information or other confidential school records in a public website enquiry. We do not currently use website enquiry forms to add people to newsletters or general marketing lists.

We use personal information to:

• respond to enquiries and arrange demos, training or webinars;
• provide, administer and support the Refocused platform;
• manage customer relationships, subscriptions, payments and records;
• protect accounts, users and systems; and
• meet legal, regulatory and contractual responsibilities.

Our main lawful bases are taking steps before or performing a contract, our legitimate interests in operating and protecting our services and relationships, and compliance with legal obligations. When we process school-controlled pupil or staff information, we act on the school’s documented instructions and the school determines the relevant lawful basis. Where information is required to enter into or perform a contract, we may be unable to provide the relevant service if it is not supplied.

When a school or trust enters pupil, staff or support information into the platform, the school or trust is normally the data controller and Refocused acts as its processor. This means the school decides why the information is used and Refocused processes it to provide and support the service.

School-controlled records may include special category information, such as health or disability information, and may also include SEND and safeguarding-related information. The school determines the lawful basis and any additional legal condition required for that processing. Refocused processes the information only under the school’s documented instructions.

Pupils and parents do not currently have direct platform accounts. We do not sell pupil information, use it for advertising, use it to train general-purpose artificial-intelligence models, or make solely automated decisions with legal or similarly significant effects.

If your request concerns information entered by a school, please contact the school or trust first. We will support the school in responding where required.

We share information only where needed. This may include the relevant school or trust, authorised users, trusted providers that help us host, communicate, take payments or support the service, professional advisers, and public authorities where the law requires it. We require appropriate confidentiality, security and data-protection controls.

Some service providers may process information outside the UK. Where this happens, we use the safeguards required by UK data-protection law. We do not sell personal information. You can contact privacy@refocused.uk for further information about the safeguards used.

We keep information only for as long as it is needed. As a general guide:

• website enquiries are normally kept for up to 12 months after the last meaningful contact;
• customer, supplier, contractual and financial records may be kept for the relationship and for up to six years afterwards where needed for legal or accounting purposes;
• school-controlled platform information is kept in line with the school’s instructions and contract; and
• technical and security records are kept only for as long as reasonably needed for security, accountability and legal purposes.

We use proportionate technical and organisational safeguards, including encryption, access controls, multi-factor authentication, audit logging, backups, software updates and incident-response procedures. No online service can be guaranteed to be completely secure, but we regularly review our controls.

Depending on the circumstances, you may have rights to access, correct, delete, restrict or object to the use of your information, to receive certain information in a portable format, and to withdraw consent where consent is used. These rights are not absolute, and we may need to confirm your identity.

Right to object: You may have the right to object to processing based on our legitimate interests. Contact privacy@refocused.uk to exercise this right.

For information controlled by Refocused, contact privacy@refocused.uk. For school-controlled records, contact the relevant school or trust first.

You can raise a data-protection complaint by emailing privacy@refocused.uk. We will acknowledge receipt within 30 days and, without undue delay, take appropriate steps to investigate, keep you informed where necessary and communicate the outcome.

You may also complain to the Information Commissioner’s Office. Visit ico.org.uk or call 0303 123 1113.

Our Cookie Policy explains the cookies and similar technologies used on refocused.uk and the Refocused platform. We may update this notice when our services or legal responsibilities change. The current version and effective date are shown at the top of the notice.

Privacy questions, rights requests and complaints: privacy@refocused.uk

Refocused Ltd, 128 City Road, London, EC1V 2NX