Privacy Policy

2.1 Student Information

When a student uses Dr Connor, we collect:

• Name: First name and last name
• Age band: Age band (e.g., 10-11,16-17) for appropriate content adaptation
• Email address: For account login and essential communications. Schools typically provide alphanumeric school email identifiers (for example, S1237808@school.sch.uk) rather than name-based addresses, so accounts are pseudonymous
• Teacher code: Links the student to their designated teacher and school
• Conversation transcripts: Complete record of all interactions with Dr Connor
• Usage metadata: Login times, session duration, number of interactions, topics discussed

What we deliberately do not collect from students: date of birth (only age band), contact details beyond email address, or any government identifiers. We do not collect home addresses, parents' personal contact details, financial information, device contacts, photos, or geolocation data and we do not intentionally collect or require special category data. The platform does not access a device's camera, microphone, or location. We collect the minimum necessary.

2.2 Teacher and School Information

When teachers create accounts, we collect:

• Name: Full name
• Email address: For account login and communications
• School name: To identify the institution and link student registrations correctly

We also process the names, roles, organisations and work contact details of school staff and business contacts who correspond with us (for example, head teachers and data protection officers), in order to respond to enquiries, set up and manage the service, and fulfil our contracts. This data is never combined with student data.

2.3 Payment Information

Dr Connor does not process or hold parent payment data.

During the Pilot, the service is provided free of charge to all participating students and schools.

If your school continues with Dr Connor after the pilot, the school is invoiced directly. Where schools pass costs on to families, this is handled entirely through the school's own payment infrastructure (such as ParentPay or similar systems). Dr Connor has no visibility of or access to parent payment details at any point.

2.4 Technical Information

We automatically collect:

• Device information: Browser type, operating system
• IP address: For security and fraud prevention
• Cookies: Essential cookies for login and session management. We also use Google Analytics cookies with your consent - see Section 12.2.

3.1 To Provide the Service

• Enable students to interact with the Socratic AI tutor
• Personalise responses based on age and learning context
• Maintain conversation history for continuity
• Provide teacher dashboards with usage insights.

3.2 For Safeguarding

We monitor all student conversations using automated systems and human review to identify concerning content, including:

• Self-harm or suicidal ideation
• Abuse, bullying, or exploitation
• Radicalisation or extremism
• Inappropriate or harmful content

When concerning content is flagged, authorised Dr Connor staff review the conversation and contact the designated teacher directly so that appropriate safeguarding procedures can be followed. No notification is ever sent to a school solely on the basis of an automated output: human confirmation is always required. All flags and outcomes are logged. Referrals support the school's statutory safeguarding duties under the applicable national framework.

Important: Dr Connor flags potential safeguarding concerns. It is not a crisis service and does not replace your school's safeguarding responsibilities. Your school retains full legal and professional responsibility for investigating concerns and taking appropriate action.

3.3 To Improve the Platform

• Analyse usage patterns to enhance the Socratic method effectiveness
• Identify technical issues and improve performance
• Develop new features based on how students learn

All analysis for improvement purposes uses aggregated, anonymised data wherever possible. We do not use student conversation content or student-generated material to train, fine-tune, or develop AI models, whether operated by Dr Connor or any sub-processor. Service quality monitoring, including detecting repetitive conversation patterns that indicate a student needs different support, uses anonymised interaction data only and does not involve feeding student content into model training pipelines.

3.4 For Communication

We send essential communications only:

• Account creation and password reset emails
• Safeguarding alerts to designated teachers
• Service updates affecting your use of the platform
• Survey requests for feedback during the Pilot (optional participation)

We do not send marketing emails during the Pilot.

3.5 Student Intellectual Property

Students retain copyright in the content they generate while using the platform, including the questions, ideas, and written work they produce in conversation with Dr Connor. Dr Connor does not claim ownership of student-generated content.

Student-generated content will not be used for commercial purposes, including AI model training, fine-tuning, or marketing, without the express written consent of the school.

6.1 The Student

Students can view their own conversation history and account information at any time through their Dr Connor account.

6.2 Designated Teachers

The designated teacher linked to a student's account can:

• View dashboard summaries of student usage (time spent, topics covered, engagement metrics)
• Request and view full conversation transcripts (provided within 24 hours of request during the Pilot; instant access via dashboard from commercial launch)
• Receive safeguarding alerts about concerning content

Teachers can only access data for students linked to their teacher code. They cannot access data for other students at their school unless separately linked.

6.3 Parents and Guardians

Parents do not hold Dr Connor accounts. Parents wishing to discuss their child's use of the platform, including reviewing conversation history, raising concerns, or requesting account closure, should contact their school's designated teacher.

The designated teacher can submit requests to Dr Connor on a parent's behalf. We will respond to all such requests within the timescales set out in Section 11.

6.4 Dr Connor Staff

Authorised Dr Connor staff access data only when necessary for:

• Reviewing flagged safeguarding concerns
• Providing technical support
• Investigating reported issues
• Platform maintenance and improvement

Staff with this access are named personnel and bound by strict confidentiality obligations. All staff are trained in data protection. Staff access to data is logged and monitored.

6.5 Third-Party Service Providers

We use carefully selected service providers who process data on our behalf:

All third-party processors are bound by data processing agreements and process data only as instructed by us. If we add new sub-processors, we will notify schools at least 30 days in advance, and schools may object on reasonable grounds.

OpenAI maintains its own sub-processor list at platform.openai.com/subprocessors and remains contractually liable for its sub-processors' compliance.

6.6 Who Cannot Access Your Data

We do not share student data with:

• Other schools or educational institutions
• Marketing or advertising companies
• Data brokers or analytics firms
• Social media platforms
• Any other third parties except as required by law

7.1 UK Data Hosting

All student conversation data is stored on secure servers in the United Kingdom (AWS London region, eu-west-2). Student data never leaves the UK for storage purposes.

7.2 International Transfers

We minimise international data transfers. Where AI processing requires data to be sent to OpenAI's systems:

• The student's message text is sent to OpenAI OpCo, LLC for processing. Dr Connor does not transmit student names, email addresses, or account identifiers. However, conversation text entered by students may contain personal information at the student's own discretion
• Transfers are protected by appropriate safeguards (EU Standard Contractual Clauses adopted by the European Commission on 4 June 2021, as amended by the UK Addendum issued by the Information Commissioner under section 119A(1) of the Data Protection Act 2018). We do not rely on the UK-US Data Bridge for transfers to OpenAI
• Data is used only for generating responses. OpenAI deletes API request data within 30 days in accordance with their API data retention policy. We will notify schools of any material change to this period. All conversation records remain stored in the UK

8.1 Technical Security Measures

We protect your data using industry-standard security measures:

8.2 Operational Security Measures

• Staff access to data is logged and monitored
• Regular security training for all staff
• Incident response procedures are live

8.3 Data Breach Procedures

In the unlikely event of a data breach:

• We will notify affected schools within 72 hours of becoming aware of it
• We will cooperate fully with the school's assessment of whether notification to the Information Commissioner's Office (ICO) and to affected individuals is required - as data controller, the school is responsible for these notifications for student data. Where we are the controller (for example, for teacher account data), we notify the ICO and affected individuals as required by law
• We will take immediate steps to contain and remediate the breach
• We will provide clear information about what happened and what you should do

9.1 During the Pilot

Deletion is completed in full, including backup systems (Section 8.1), and we provide schools with written confirmation of deletion on request.

9.2 Transition to Commercial Service

If your school transitions to the commercial service after the pilot:

• Conversation transcripts and usage data will be retained according to the commercial service retention policy, which will be provided before the transition
• You will have the option to request deletion of all pilot data before transitioning
• Safeguarding records will continue to be retained for 5 years regardless of service status

9.3 Why These Retention Periods

Conversation transcripts (duration of the pilot): Retained during the pilot to allow continuous improvement of the platform and to provide teachers with access to conversation history.

Safeguarding records (5 years): UK law requires educational institutions to retain safeguarding records for a minimum of 5 years. We follow the same standard to protect students and demonstrate our safeguarding responsibilities.

Account data (90 days after closure): Allows for account recovery in case of accidental closure and ensures orderly data deletion.

10.1 Right to Access

You can request a copy of the personal data we hold about you. This includes full conversation history, account information, usage metadata, and any safeguarding records that reference you. We will provide this information within 30 days of your request.

10.2 Right to Rectification

You can request correction of inaccurate personal data, including your name, email address, or age band. Note: conversation transcripts are factual records of interactions and cannot be altered, but context or corrections can be added as a note.

10.3 Right to Erasure

You can request deletion of your personal data by closing your account (data deleted within 90 days) or by emailing support@dr-connor.com to request immediate deletion.

Important exception: We cannot delete safeguarding records that we are legally required to retain for 5 years under UK law. All other data will be deleted as requested.

10.4 Right to Restrict Processing

You can request that we limit how we use your data while we investigate a concern you have raised about accuracy or processing.

10.5 Right to Data Portability

You can request your conversation transcripts and usage data in a machine-readable format (JSON or CSV) for transfer to another service.

10.6 Right to Object

You can object to processing based on legitimate interests. Please note:

• We cannot provide the tutoring service without processing conversation data
• We cannot disable safeguarding monitoring. This is a core safety requirement.
• If you object to essential processing, the appropriate remedy is to close your account

10.7 Rights for Students Under 18

Students under 18 have the same rights. Requests can be made by a parent or guardian directly to support@dr-connor.com, or through the school's designated teacher. Students aged 16 to 17 may also make their own requests directly where they have sufficient understanding. We will assess each request individually to ensure we act in the student's best interests.

11.1 For Students Under 18

Parents or guardians can contact us via the school's designated teacher, who can submit requests on their behalf, or by emailing support@dr-connor.com directly with the student's registered email address and details of the request.

11.2 For Students 18 and Over

Email support@dr-connor.com directly from your registered email address with details of your request.

11.3 For Teachers

Email support@dr-connor.com from your registered email address with details of your request.

11.4 Response Times

To protect your privacy, we may ask for additional information to verify your identity before fulfilling requests.

12.1 Essential Cookies

During the Pilot, we use essential cookies required for the platform to function:

• Session cookies: Keep you logged in
• Security cookies: Prevent unauthorised access
• Preference cookies: Remember your settings

12.2 Tracking or Analytics

We use Google Analytics (operated by Google LLC as our data processor) to analyse how the platform is used and improve it. This involves collecting usage data including pages visited, session duration, and device information. We process this on the basis of consent, which you can withdraw at any time via our cookie banner. We retain event-level data for 2 months and user-level data for 14 months. Where this data is processed outside the UK, it is protected by Google's data processing terms and UK-approved transfer safeguards.

13.1 Age Requirements

Dr Connor is designed for use in schools and is accessed exclusively through a school or educational institution. The school is responsible for determining which students are enrolled and for ensuring appropriate notices and lawful bases are in place for all students before access is granted.

13.2 School Endorsement Model

Every student on Dr Connor has been enrolled through their school. The school nominates a designated teacher who manages the programme and acts as the primary safeguarding and communications contact. Students register using that teacher's unique code, which links them directly to the designated teacher.

This means:

• Every student has been endorsed by a responsible institution
• Every student is linked to a named adult within their school
• Parents are informed through the school, not directly by Dr Connor

Parents who wish to opt out of their child's participation should contact the school's designated teacher. Dr Connor will remove the student's account promptly upon receipt of an opt-out instruction from the school.

13.3 Enhanced Protections for Under-18s

• Safeguarding monitoring is mandatory and cannot be disabled
• Parents can request access to their child's conversation history via the school's designated teacher
• We do not collect unnecessary personal information
• Data is never used for profiling or marketing

13.4 ICO Age Appropriate Design Code

Dr Connor is used in schools and all student users are children for the purposes of UK data protection law, and the ICO's Age Appropriate Design Code (the “Children's Code”) applies. The best interests of the child are a primary consideration in the design of our service. We apply the Code's standards as follows:

• Minimising data collection to what is strictly necessary
• Providing privacy information in clear, accessible language
• Defaulting to high privacy settings
• Not using data for purposes that are not in children's best interests

15.1 Updates During the Pilot

We may update this Privacy Policy during the Pilot if we add new features that affect data processing, legal requirements change, or we identify ways to improve transparency.

15.2 How We Notify You

For significant changes, we will email registered users and schools at least 14 days before changes take effect and post the updated policy on our website. The Effective Date at the top of this document will be updated. Where we develop new features that change what personal data is processed or who can see it - for example, dashboards for parents or carers - these will be introduced only after updating this policy, and with advance notice to schools, students and parents.

15.3 Transition to Commercial Service

Before your school transitions to the commercial service, we will provide an updated Privacy Policy reflecting any new features or data practices, a clear explanation of what changes from the Pilot, and an option to opt out and have all data deleted before transitioning.

16.1 Privacy Contact

For all privacy-related enquiries, including data subject access requests and questions about this policy:

Toby MacLachlan (Privacy Contact) Email: privacy@dr-connor.com

Accountability for data protection sits at founder level: our privacy contact owns data protection compliance day to day and is the first point of contact for schools' data protection teams. Our scale of processing does not bring us within the mandatory appointment criteria for a statutory Data Protection Officer under Article 37 UK GDPR.

16.2 General Support

Email: support@dr-connor.com

16.3 Postal Address

Dr Connor Ltd Passfield Corner, Passfield Road Passfield, Liphook England, GU30 7RU

16.4 Complaints

If you are unhappy with how we have handled your personal data:

1. Contact our Privacy Contact (details above). We will investigate and respond within 30 days.
2. If still unsatisfied, you have the right to complain to the Information Commissioner's Office (ICO).

Information Commissioner's Office (ICO) Website: ico.org.uk Helpline: 0303 123 1113 Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF