Spark Design Academy
Data Protection & Privacy Policy
(Including Learner Privacy Notice, AI Usage Statement & Data Sharing Principles)
Version: v2.0
Effective Date: 15 May 2026
Review Date: 15 May 2027
Approved By: Emma Ledger – Principal, Spark Design Academy
1. Purpose
Spark Design Academy (“SDA”, “we”, “our”, “us”) is committed to protecting and respecting the privacy of learners, schools, partners, staff, and stakeholders.
This policy explains how SDA collects, processes, stores, shares, and protects personal data in accordance with:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Applicable international data protection legislation where relevant
This document also acts as:
- SDA’s public Privacy Notice
- Learner Privacy Notice
- AI Usage & Processing Statement
- General Data Sharing Framework for educational partners
2. Scope
This policy applies to:
- All SDA staff, contractors, tutors, assessors, consultants, and partners
- All learners enrolled onto SDA programmes
- Schools, academies, trusts, and educational partners
- Website visitors and marketing enquiries
- All personal data processed by SDA in digital, written, visual, audio, or verbal form
3. Who We Are
Spark Design Academy (“SDA”, “we”, “our”, “us”) is a UK-based education provider delivering creative learning programmes, online courses, and industry-led educational experiences.
For all privacy, data protection, or personal data enquiries, please contact:
📧 info@sparkdesignacademy.co.uk
4. Definitions
Personal Data
Any information relating to an identifiable individual.
Examples include:
- Name
- Email address
- Telephone number
- Learner records
- Assessment evidence
- Video/audio recordings
Special Category Data
Sensitive personal data including:
- Health information
- Safeguarding concerns
- Ethnicity
- Additional support needs
Processing
Any activity involving personal data including:
- Collection
- Storage
- Sharing
- Recording
- Deletion
Data Subject
The individual whose personal data is processed.
5. Lawful Basis for Processing
SDA processes personal data under the following lawful bases:
PurposeLawful BasisDelivering courses and assessmentsContractCommunicating with learners and schoolsLegitimate InterestSafeguarding obligationsLegal ObligationCertification and quality assuranceLegal ObligationMarketing communicationsConsent / Legitimate InterestPlatform analytics and improvementLegitimate Interest
6. Data We May Collect
SDA may collect and process the following categories of data:
Learner Information
- Full name
- Email address
- Telephone number
- Date of birth
- Portfolio submissions
- Assessment evidence
- Attendance and engagement data
School / Partner Information
- Staff names
- Contact details
- Organisation information
- Delivery records
Technical Information
- IP address
- Browser/device information
- Login activity
- Website analytics
Media Content
- Videos
- Photography
- Recorded sessions
- Podcast appearances
- Testimonials
7. How We Use Personal Data
We use personal data to:
- Deliver educational programmes
- Assess learner work
- Provide learner support
- Issue certificates and qualification outcomes
- Communicate with schools, parents, and learners
- Maintain safeguarding standards
- Improve our services and learner experience
- Provide technical and AI-assisted support
- Comply with legal and regulatory obligations
8. AI Tutor & AI-Assisted Learning
Spark Design Academy may use AI-assisted systems to support learning experiences.
This may include:
- AI-powered tutor support
- Learning guidance tools
- Content recommendation systems
- Automated assistance features
Important principles:
- AI systems are designed to support learning, not replace human educators.
- Final assessment decisions are always subject to human oversight.
- Learners should not upload sensitive personal information into AI chat systems.
- AI interactions may be securely logged for:
- quality assurance
- safeguarding
- system improvement
- learner support
SDA does not use fully automated decision-making that produces legal or significant effects on learners.
9. Teachable Platform Privacy Notice
SDA delivers elements of its programmes through the Teachable learning platform.
When learners access SDA courses through Teachable, certain personal data may be processed by Teachable on SDA’s behalf.
This may include:
- Login information
- Course progress
- Payment information
- Device/browser data
- Learner engagement analytics
Teachable may process data on servers located outside the United Kingdom.
Where international transfers occur, SDA relies on:
- UK adequacy regulations
- Standard Contractual Clauses (SCCs)
- Appropriate contractual safeguards
For more information, please visit:
Teachable Privacy Policy
10. Data Sharing
SDA only shares personal data where necessary and lawful.
This may include sharing data with:
- Awarding organisations
- Schools and academy trusts
- Educational delivery partners
- Safeguarding authorities
- Technology providers
- Payment processors
- Professional advisers and regulators
We do not sell personal data to third parties.
11. International Data Transfers
Some SDA systems and technology providers may process data outside the United Kingdom.
Where this occurs, SDA ensures appropriate safeguards are in place, including:
- UK International Data Transfer Agreements
- Standard Contractual Clauses
- Appropriate security and contractual protections
12. Safeguarding & Child Protection
SDA recognises that safeguarding responsibilities may require the processing and sharing of personal information.
Where safeguarding concerns arise, information may be shared with:
- schools
- parents/guardians
- safeguarding leads
- local authorities
- law enforcement agencies
This will only occur where necessary, proportionate, and lawful.
13. Data Retention
SDA retains personal data only for as long as necessary.
Typical retention periods include:
Data TypeRetention PeriodLearner assessment records6 yearsSafeguarding recordsIn line with safeguarding guidanceFinancial records6 yearsMarketing enquiriesUp to 24 monthsInactive learner accountsPeriodically reviewed and deleted
14. Learner Intellectual Property
Learners retain ownership of original creative work they produce during SDA programmes unless otherwise agreed in writing.
SDA retains ownership of:
- Course structures
- Educational frameworks
- Assessment methodologies
- AI systems
- Downloadable resources
- Teaching materials
- Recorded content
- Platform systems
- Branding and associated intellectual property
Learner work will not be publicly used without appropriate permission.
15. Cookies & Analytics
SDA websites and platforms may use:
- Cookies
- Analytics tools
- Tracking technologies
These help us:
- Improve website performance
- Understand user behaviour
- Enhance learner experience
- Support marketing effectiveness
Users can manage cookie preferences through their browser settings.
16. Security Measures
SDA takes appropriate technical and organisational measures to protect personal data, including:
- Secure password policies
- Multi-factor authentication where appropriate
- Access controls
- Encrypted systems and platforms
- Secure cloud storage
- Staff confidentiality obligations
17. Data Subject Rights
Individuals have rights under UK GDPR, including:
- Right of access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to object
- Right to data portability
Requests should be sent to:
📧 info@sparkdesignacademy.co.uk
18. Data Breaches
Any suspected data breach must be reported immediately.
SDA will:
- Investigate incidents promptly
- Assess risk
- Notify relevant authorities where required
- Communicate with affected individuals when necessary
19. Complaints
If you are unhappy with how SDA processes personal data, please contact us first so we can attempt to resolve the issue.
You also have the right to complain to the Information Commissioner’s Office (ICO):
Information Commissioner’s Office (ICO)
20. Policy Review
This policy will be reviewed annually or sooner where:
- Legislation changes
- Systems change
- Operational requirements evolve
- Safeguarding guidance updates
Contact
Spark Design Academy
📧 info@sparkdesignacademy.co.uk