Data controller and contact details
Scottish Borders Council (including your child’s school) is the data controller. We are responsible for ensuring your child’s data is handled safely.
- Address: Newtown St Boswells, Melrose, TD6 0SA
- Enquiries: 0300 100 1800 | customeradvice@scotborders.gov.uk
- Education Service
- Data Protection Officer (DPO): dataprotection@scotborders.gov.uk
Protecting your child’s identity
Before using any application, we assess if we can achieve our goals without using personal data:
- Anonymisation: We use non-identifiable data for general reporting whenever possible.
- Pseudonymisation: We use unique ID numbers where possible instead of personal data within the software to add a layer of security against unauthorised identification.
Information we use and purpose
We have determined that the minimum data required to run Achieve is: First Name, Surname, Glow email address, target grade, self-evaluation rating (red, amber, green). We use this to:
- Assessment evidence for feedback and set personalised goals for students in the senior phase only for exam preparation.
- Track progress and engagement through quizzes with National Qualifications at National 5 and above and identify where extra teacher support is needed.
Legal basis and safety measures
- Lawful basis: We process this data under Public Task, as it is part of our official legal duty to provide education and monitor pupil progress.
- Security: We have conducted a Data Protection Impact Assessment (DPIA) and third-party assurance check.
- Retention: Data is held while your child is at school. Accounts are deactivated and deleted in line with our retention schedule once they leave or stop using the app.
Data sharing and decision making
- Who sees it: Access is restricted to relevant school staff and Hashtag Learning (the provider). Hashtag Learning uses sub-processors to help them deliver the service but is strictly forbidden from using data for any other purpose such as marketing or sales.
| Name | Country | Purpose | Is personal pupil data stored |
|---|---|---|---|
| Heroku (EU) | EU | Data centre | Yes |
| AWS | Ireland | Server hosting | No |
| Brevo | France | Product information and marketing | No |
| Stripe | Ireland | Online payments | No |
| Open AI | US | Virtual Tutor only | No |
- No automated decisions: While the software provides feedback, it does not make automatic decisions. A teacher always uses their professional judgment to plan for the next steps for your child.
Your rights and complaints
Depending on your child’s age and capacity (usually from age 12 in Scotland), they or their parent/guardian have the right to access their data or request corrections. They may also ask us to restrict processing or object in certain circumstances. For concerns or to exercise your rights, please contact the Headteacher or visit our Data protection and your rights webpage.
How to raise a complaint
We aim to directly resolve all complaints about how we handle personal information. If your complaint is about how we have handled your personal information, you can contact our Data Protection Officer by email dataprotection@scotborders.gov.uk or phone on 0300 100 1800.
However, you also have the right to lodge a complaint about data protection matters with the Information Commissioner's Office (ICO), who can be contacted by
- post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- phone on 0303 123 1113
- Visit the ICO website
If your complaint is not about a data protection matter, visit our Making Complaints webpage for more information.