Privacy Notice for the EEF data archive
Purpose of processing
Data collected as part of EEF-funded evaluations is archived in order to estimate the long-term impact of the interventions, to better understand variation in children’s outcomes across evaluations, and to improve the methodological approaches we use to evaluate this impact.
This privacy notice should be read alongside EEF’s 'Privacy notice - information that we need to tell everyone' which covers information relevant to anyone whose data is used by the EEF, including your rights.
Source of the personal data
In most EEF-funded evaluations, the independent evaluator collects data from schools (or other educational settings) implementing the intervention, as well as from control schools (‘business as usual’), in order to estimate the extent to which any impact identified is related to the intervention. Depending on the project, data may also be collected directly from pupils, teachers or parents using methods such as surveys, interviews or lesson observations.
For when participant data is first collected, EEF recommend the following text is adapted as needed and included in all recruitment documents and information sheets for parents and schools, alongside other relevant information:
The project involves [insert details of activities involved and their aims]. Pupils will be asked to [insert data collection procedures, as applicable]. The responses will be collected by [test administrators, if applicable] and accessed by [evaluator]. For the purposes of research and archiving, the responses will be linked with information about the pupils from the National Pupil Database (NPD) and shared with [delivery partner, if applicable], the Department for Education, the EEF, the EEF’s archive manager, the Office for National Statistics and potentially other research teams. Further matching to NPD and other administrative data may take place during subsequent research.Your child’s data will be treated with the strictest confidence and [insert safeguards in place to protect their data], in line with [insert details of GDPR and Data Protection Act 2018 compliance]. We will not use your child’s name or the name of the school in any report arising from the research. We expect that your child will enjoy their involvement in the project, and they will be free to withdraw at any time. If you would prefer your child NOT to take part in any project testing [if applicable], or their data not to be processed as above, please inform [contact details and withdrawal procedures, e.g., withdrawal form attached]. If you would like more information about this project, please contact [delivery partner contact details].
Category of the personal data
The types of data collected on our evaluations vary from project from project, but the majority of evaluations will collect data on attainment or non-cognitive skills, as well as participant background data (such as economic disadvantage and gender). Details about the project aims and types of data collected will be detailed in the recruitment documents and privacy notices for each specific project.
Lawful basis for the processing
EEF evaluation data is processed by the archive manager on the basis of legitimate interests, according to the GDPR, Article 6, Paragraph 1(f), taking responsibility for protecting the fundamental rights and freedoms of the data subjects, and ensuring their interests are protected at all times.
Occasionally, the EEF archive, also processes special categories of personal data from evaluations according to the GDPR, Article 9, Paragraph 2(j), which specifies that processing is necessary for ‘archiving purposes in the public interest, scientific or historical research purposes or statistical purposes’. This processing is carried out with appropriate safeguards for protecting the rights and freedoms of the data subjects, according to the GDPR, Article 89.
Legitimate interests for the processing
We have conducted purpose, necessity and balancing tests and have concluded that the data processing is necessary for the purpose of fulfilling our legitimate interests, which could not be pursued through other means. These legitimate interests include gathering data about what educational interventions work best, under what conditions, for what participants, with a view to increasing attainment and reducing educational disadvantage, as well as measuring the long-term impact of those interventions, continuously improving our methodological approaches and publishing independent findings free of charge for the benefit of schools, the research community and wider society. These legitimate interests have been carefully balanced with the interests of the data subjects (typically, pupils) and the archive only processes personal data in line with the purposes communicated to the education settings and participants (or their parents/ guardians), giving them the option to withdraw from data processing at any time with no consequence. For more information, please contact EEF for a copy of the DPIA of the archive.
How the archive is stored
The archive is held in the Secure Research Service provided by the ONS. The evaluation data is already held in a project space in the SRS prior to being transferred across to the archive.
The evaluation data is retained in the archive indefinitely to enable researchers to track the impact of our projects on attainment at subsequent educational stages, with a view to better understanding the effectiveness of different teaching and learning approaches on increasing attainment and reducing educational disadvantage.
The data protection principle of storage limitation allows data to be stored for longer periods for the purpose of research, so long as measures are in place to protect the privacy of individuals. An important measure for the archive is that is does not contain any information that can be used to directly identify an individual pupil. For example, the archive does not include names, addresses or dates of birth.
The archive does contain the Pupil Matching Reference (PMR), gender, month and year of birth. This is to perform longitudinal and sub-group analyses without directly identifying any individual pupils. The PMR is an identifier used by the DfE that enables linking archive data to data held in the National Pupil Database.
Organisations who receive the archive data
The EEF data archive is managed by FFT Education (FFT) and held by the ONS within their Secure Research service.
FFT provides data extracts to EEF’s designated archive evaluator (currently based at Durham University) for the purpose of conducting secondary and longitudinal data analyses in order to track impact over time (using additional matching to NPD data obtained from the DfE), check data archive integrity and produce methodological outputs for the EEF Evaluation Advisory Board. EEF evaluation data may also be shared with other research teams and matched to other datasets for secondary research purposes.
It is intended that the archive will be accessible to the wider research community for secondary analyses that provide public benefit and are in line with the missions of the EEF, DfE and ONS.
The archive data is made available in SRS project spaces, which are held in the UK.
Your data protection rights
For more information on your rights, please see ‘Your rights’ under 'Privacy notice - information that we need to tell everyone'.