Privacy notice

PassWise (passwise.education) is a free tool for UK teachers who also tutor. It is run by Luke Eaton, based in Edinburgh, Scotland. In this notice, “PassWise”, “we” and “us” mean the operator of the service.

You can contact us about anything in this notice at luke.eaton.mail@gmail.com.

Data protection law separates the organisation that decides why and how data is used (the “controller”) from the organisation that handles data on its behalf (the “processor”). Who is the controller depends on the data and the workspace it sits in.

If you are a pupil or a parent and have a question about pupil data, the best first contact is the school or tutor who added you. We will help them answer it, and you can also contact us directly.

Teachers and tutors

• Your name and email address.
• Optional profile details you choose to add, such as display name, subjects, school and time zone.
• If you sign in with Google, the basic profile Google shares with us (name, email address and profile picture). We do not get access to your Google Drive, Gmail or other Google data.
• The content you create: questions, quizzes, classes, assignments, marks and feedback.
• Basic technical records needed to run and secure the service, such as sign-in times and error logs.

Pupils in a workspace

• A first name and an initial, entered by the teacher or tutor. We do not need a pupil email address.
• A PIN used to sign in.
• Answers, marks, feedback and progress over time.

Anonymous live-quiz participants

• The nickname typed in to join.
• A random device token, so the same device can rejoin the session.
• The answers given during that session.

For teacher and tutor account data, where PassWise is the controller:

• To provide the service you signed up for: running your account, workspaces, quizzes and marking. Lawful basis: contract.
• To send service emails such as sign-in links, password resets and notifications you have switched on. Lawful basis: contract.
• To keep the service secure and working, including preventing abuse and fixing faults. Lawful basis: legitimate interests.
• To meet legal obligations, for example responding to a lawful request. Lawful basis: legal obligation.

For pupil and participant data, we only use it to provide PassWise to the school or tutor, following their instructions. The school or tutor decides the lawful basis for collecting it.

We do not show adverts, we do not sell personal data, and pupil data is never used to train AI models.

PassWise uses Anthropic’s Claude models for two features:

• Question generation. A teacher can ask for draft questions on a topic. We send the teacher’s request, which should not include pupil names or other personal data.
• Essay-mark suggestions. For written answers, the AI can suggest a mark and feedback. These suggestions are shown only to the teacher, who reviews and approves them before anything reaches the pupil. The AI never makes a final decision about a pupil.

Anthropic processes this data on our behalf and does not use it to train its models.

Many pupils who use PassWise are children. We design with the ICO’s Age Appropriate Design Code (the Children’s code) in mind:

• We collect the minimum needed: a first name and an initial, with no pupil email address.
• High-privacy settings are the default. Pupil progress is visible only to the school or tutor and to anyone they choose to share it with.
• No adverts, no profiling for marketing, and no design that nudges pupils to share more.
• We aim to explain things to pupils in plain language.

In Tutoring workspaces, the tutor must get consent from a parent or carer before adding a pupil under 13. In School workspaces, the school is responsible for its own lawful basis and for informing parents.

We use a small number of trusted providers (sub-processors) to run PassWise. Each is bound by a contract that requires it to protect the data and use it only to provide its service to us.

Where data is processed outside the UK, we rely on UK adequacy regulations or the UK International Data Transfer Agreement or Addendum to keep it protected to UK standards.

We may also disclose data where the law requires it, or to protect the safety of a child or anyone else.

We only use essential cookies that keep you signed in and keep your session secure. We do not use analytics, advertising or tracking cookies, so there is no cookie banner. Your light or dark theme choice is stored in your own browser and never sent to us.

• Teacher and tutor accounts are kept while the account is open. When you delete your account, we delete your account data and the workspaces you own.
• Pupil data is kept for as long as the school or tutor keeps it in their workspace. They can delete it at any time.
• Anonymous live-quiz data is kept with the session results for the teacher until they delete it.
• Deleted data may remain in encrypted backups for a short period before being overwritten.

You can export or delete your account from your settings at any time, or ask us to do it by emailing luke.eaton.mail@gmail.com.

Data is encrypted in transit and at rest. Access to each workspace is restricted at the database level, so a teacher can only see the pupils and results in workspaces they belong to.

Under UK GDPR and the Data Protection Act 2018, you have the right to:

• access the personal data held about you;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to how your data is used;
• receive your data in a portable format.

Teachers and tutors can use the export and delete options in settings, or email us. For pupil data, contact the school or tutor, or email us and we will pass your request on and support them. Parents and carers can make requests on behalf of their children.

We will respond within one month. There is no charge.

If you are unhappy with how we have handled your data, please contact us first at luke.eaton.mail@gmail.com so we can try to put it right. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.

We will update this notice when the service or the law changes. The date at the top shows the latest version. If a change significantly affects how we use your data, we will tell account holders by email before it takes effect.