Revision Census 2024 Data Policy

Revised 2024.03.01

The Revision Census 2024 will survey UK secondary school students on matters relating to their independent learning, to better understand how we can make independent learning more effective within participating schools, but also in non-participating schools around the country and beyond.

From 25 May 2018, the General Data Protection Regulation (GDPR) will replace the Data Protection Act and govern the way that organisations use Personal Data.  Personal Data is information relating to an identifiable living individual.

Transparency is a key element of the GDPR, and this Data Policy is designed to inform you what data is being collected, why, and how it will be processed and protected.

The Revision Census 2024 will not handle Personal Data due to our use of anonymisation (see Section 3) and is therefore exempt from GDPR under Recital 26. Nevertheless, we wish to hold ourselves to the highest possible standards, and so have drafted this notice to the same standards as if we were collecting Personal Data.

Table of contents

1.        Key definitions

  1. Data Subjects: students completing the Revision Census 2024 questionnaire.
  • Partner Schools: schools that have agreed to participate in the Revision Census 2024, thereby allowing the Revision Census 2024 to survey students attending that school.
  • Personal Data: defined in the GDPR as “any information relating to an identified or identifiable natural person (‘data subject’)”.
  • Anonymised Data: the GDPR and its restrictions does not apply to Personal Data that has been anonymised “including for statistical or research purposes” (Recital 26), i.e. data about an individual who is not identified or identifiable.
  • Student-Level Data: refers to data on individual Data Subjects, whether or not that individual data subject is identifiable. Student-Level Data could, for example, be either anonymised or not; if not anonymised, then student-level data would constitute Personal Data.
  • School-Level Data: refers to data on individual schools (but not individual Data Subjects within that school), for example, the average scores across all the Data Subjects within one Partner School only.
  • Aggregated Data: refers to data in which no individual Partner School or Data Subject can be identified, for example, average scores for all Data Subjects in the nationwide sample, or segmented by demographic factors such as age, gender or school type.

2.        Who is collecting the data?

Data is being collected for the Revision Census 2024, a research partnership between leading academics (led by Prof. Henry Roediger and colleagues of the Memory & Cognition Lab at Washington University in St Louis) and independent researchers (led by William Wadsworth and Dr Alix Hibble of Exam Study Expert, an independent UK social enterprise dedicated to researching and supporting the uptake of effective study strategies).

Revision Census 2024 Lead Investigator William Wadsworth will act as Data Controller, Information Commissioner’s Office registration number ZA555847.

3.        Scope of data collection

Data Subjects will complete an online questionnaire. The Revision Census 2024 will collect predominantly non-personal information, including:

  • Approaches to independent learning and revision
  • Attitudes to independent learning and academic success
  • Demographic data, e.g. age and gender

As well as specific special category data:

  • Ethnic origin
  • Nationality

We will not under any circumstances ask for a Data Subject’s name, or any other information that will make individual Data Subjects identifiable to the Revision Census 2024.

We may, at the request of a Partner School, collect a pseudonym identifier for each Data Subject, provided that only the Partner School has access to those identifiers to de-anonymise the data. See Section 6.2 for more information on our pseudonymisation policy.

4.        Purpose

Data is being collected as part of a scientific study on the state of independent learning in school students today, including measuring the extent to which students use effective learning techniques.

Only Aggregated Data will be made available in the public domain (see Definition 7). Public uses of Aggregated Data may include the following:

  • Research papers published in academic journals.
  • Dissemination of findings and their implications to a non-academic audience through the mass media and education industry media.

School-Level Data will only be made available to the Partner School to which it refers. Partner Schools may share such data with other Partner Schools should they wish (for example, with peer schools in the same trust or local group).

Student-Level Data will only be accessible to Partner Schools if they have requested it, under a strict pseudonymisation / anonymisation regime (see Section 6.2).

Partner Schools may use the School-Level or Student-Level data provided to them by the Revision Census 2024 for internal purposes, including sharing with their staff, their students, or their parents, as the Partner School sees fit.

Partner Schools must hold written permission from the Revision Census 2024 Data Controller before sharing any data or findings from the Revision Census 2024 publicly. This may include (but is not limited to) use of favourable statistics on school websites, in promotional literature or in press releases. We expect to gladly grant such permission in the vast majority of cases, but may need to deny it in others, for example, if this would amount to publication of key findings ahead of Revision Census 2024 researchers themselves making such findings publicly available.

5.        Justification

5.1     Lawful basis for data collection under the gdpr

For Partner Schools from whom the Revision Census 2024 will collect Anonymised Data, the Revision Census 2024 will not be collecting Personal Data therefore no justification for collection is required under GDPR.

For Partner Schools who have requested pseudonymised data, the Revision Census 2024 will be collecting Personal Data on behalf of the school, although for the avoidance of doubt, the only organisation to hold data defined as “Personal Data” will be the Partner School, and not the Revision Census 2024. Lawful basis must nevertheless be in place for any collection of Personal Data.

The basis for collecting data for the Revision Census 2024 is Legitimate Interests. The Revision Census 2024 has undertaken a Legitimate Interest Assessment, which can be summarised as follows:

  • What is the legitimate interest: scientific research, advancing our understanding of the science of effective learning, and supporting the uptake of more effective learning practices among students. Specifically, through collecting data on how school students approach independent learning, we hope to identify opportunities to help more students study effectively, improving their academic effectiveness, and their ability to score well in school examinations and progress to further study and / or rewarding careers.
  • Why is the processing required to achieve legitimate interests: cognitive psychologists have a wealth of laboratory data on what learning techniques are effective, but only very limited understanding of the extent to which effective techniques are being adopted by students. There is no other way to understand how students are approaching independent learning today other than by directly collecting data on how they approach learning, either through interviews, diary studies, or survey work. The survey method was selected in part because it was the least intrusive data collection methodology that still achieved the research aims, thereby minimising our impact on Data Subjects.
  • Balance against individuals’ interests, rights and freedoms: we will protect individuals’ freedoms by providing an opt-out for individual questions should the Data Subject not wish to answer them. The aims of the research are in line with the generally-accepted aims of school students and their parents and teachers; specifically, to perform better in school tests and exams by using more effective learning strategies. By feeding back results of the survey to each Partner School, together with recommendations for more effective study practices at that school, we aim to maximise the chances of each Data Subject directly benefitting from participation in the Revision Census 2024.

5.2     Special category data

A second lawful basis would be required to justify collecting and processing special category personal data (“sensitive personal information”, as defined under the GDPR’s Article 9) such as ethnicity.

For Partner Schools where we are collecting pseudonymised data, we will prevent any organisation having access to special-category Personal Data thus:

  • The Revision Census 2024 will not have access to the pseudonym identifiers, and therefore be processing the data as being Anonymous Data rather than Personal Data (see Section 6.2).
  • When the Revision Census 2024 shares Student-Level pseudonymised data with Partner Schools who have access to the additional information required to identify Data Subjects, we will exclude all special category data. We expect the Partner School to typically hold this data internally (e.g. student’s ethnicity), collected under a separate data collection regime with separate justification, as per the Partner School’s own data policy.

Since neither the Revision Census 2024 nor Partner Schools will hold sensitive Personal Data at any point, we do not require an additional second lawful basis for special category data.

Again, for Partner Schools from whom the Revision Census 2024 will collect Anonymised Data, the Revision Census 2024 will not be collecting Personal Data therefore no justification for collection is required under GDPR.

Alternative Lawful Bases include “Consent”; asking Data Subjects for their permission to collect, store and process data. We have chosen not to use Consent as the lawful basis for data collection and processing under the GDPR, for two reasons:

  • ICO guidelines state that consent is often not the most appropriate lawful basis for collecting data from either children, or for research / statistical purposes.
  • The minimum age at which children can give informed consent themselves is 13, and we wish to collect data from younger children.

Hence using an alternative lawful basis for data collection (see Section 5.1).

However, we must acknowledge the issue of consent to be compliant with research ethics norms set out by the British Education Research Association (BERA), of which the Lead Investigator is a member (BERA Number 025164). See https://www.bera.ac.uk/publication/ethical-guidelines-for-educational-research-2018-online.

In order to meet ethical (rather than GDPR / legal) standards, our approach to consent is summarised as follows:

  • Informed gatekeeper consent: we will survey Data Subjects in a Partner School subject to the agreement of School Head or appropriate member of the senior leadership team in their capacity as a gatekeeper, in line with BERA guidelines.
  • Informed student consent: before taking the survey, students will be provided with an easily-understandable overview of the purposes of the research and their rights, both read out to them by their teacher, and also in writing before they begin the survey. Participants will be given the option to provide “don’t want to answer” responses to questions they do not wish to answer.
  • Parental information: we advise schools to inform parents about the Revision Census 2024, and will provide a template letter for schools to adapt and use. This is not a firm requirement, however, as parental consent is not required for a data subject to participate, either from a GDPR-compliance or a research ethics perspective.

The Revision Census 2024 has consulted with BERA and the National Children’s Bureau’s Research Ethics Advisory Group to ensure all appropriate ethical safeguards are in place.

6.        Anonymisation and pseudonymisation

6.1     Anonymised data

Data will normally be anonymised at point of collection because no information will be given by the Data Subjects that will allow them to be individually identified.

6.2     Pseudonymised data

Some Partner Schools have requested access to Student-Level Data. In order to support these requests, Data Subjects in such Partner Schools will be given a modified survey which includes an additional question asking them to input a pseudonym identifier.

This identifier can only be linked to individual Data Subjects’ identities by the Partner School.

Pseudonymised data is considered Personal Data under the GDPR, if (and only if) the same organisation holds the additional information required to identify individual Data Subjects.

  • The Revision Census 2024 will at no point hold the additional information required to identify individual Data Subjects from the pseudonymisation identifiers, and will therefore not be processing personal information.
  • Partner Schools who have requested Student-Level Data will be presented with pseudonymised Student-Level Data by the Revision Census 2024, and will hold the additional information required to identify individual Data Subjects. At that point, Partner Schools will, therefore, be processing personal information.

It is therefore imperative that the Partner School chooses a pseudonym identifier to which the Revision Census 2024 could have no access through any reasonable means, and at no stage shares the additional information required to identify Data Subjects from their pseudonym with the Revision Census 2024.

For the avoidance of doubt, a given Partner School will only have access to Student-Level Data on students attending that school.

How such Partner Schools process, store and share the pseudonymised data they will receive from the Revision Census 2024 must be covered by the school’s existing data policies. The Revision Census 2024 cannot be held responsible for any misuse of Personal Data once the dataset has been received by the Partner School in question.

7.        Data collection and storage

7.1     Collection

Data will be collected from Data Subjects using an online questionnaire hosted on a secure website hosted by Smart Survey, a leading GDPR-compliant and ISO27001 certified research platform with over 250,000 users worldwide. Smart Survey’s privacy policy can be viewed at https://www.smartsurvey.co.uk/privacy-policy.

Data will be collected during a two-month window in 2024.

7.2     Storage

The Revision Census 2024 will hold data securely for the set amount of time shown in our data retention schedule (7.3).

Technical and organisational measures to ensure the security of stored data will include:

  • Digital data held in encrypted hard-drives, protected by secure password
  • Encrypted cloud back-up from Microsoft, with data securely held within the EU
  • Not making hard copies (printing out) of Student-Level or School-Level data
  • Conducting regular testing and reviews of measures

7.3     Retention schedule

Data will be retained as follows:

  • Where Student-Level Data has been appended with a pseudonym identifier, we will retain the pseudonym identifier tag for a maximum of 12 months after data collection stops, after which the pseudonym identifier data will be destroyed.
  • The Revision Census 2024 reserves the right to retain all other data (which under no circumstances will include Personal Data) for a minimum of 10 years, in line with common practice for long-term scientific research programmes. Any data held will be reviewed annually to ensure no unnecessary data is being retained.

8.        With whom will we share data

The Data Controller will share data with research partners as part of the process of analysing and evaluating findings and preparing conclusions for publication. Research partners will include:

  • Research assistants hired specifically for the purpose of analysing the data from the Revision Census 2024.
  • University-affiliated academics worldwide collaborating on the Revision Census project.

In both cases, the following protections will be applied to the data before it is shared by the Data Controller:

  • School name will be pseudonymised using an identifier code, so research partners will not be able to access School-Level data.
  • Any pseudonym identifiers appended to the dataset to allow Partner Schools to access Personal Data on individual students will be removed.

For the avoidance of doubt, no Personal Data will be transferred outside of the EEA.

We will also share limited data with Partner Schools (see Section 4 for details).

9.         Special consideration

We will follow ICO recommendations for communicating privacy information to children, including the use of simple and age-appropriate language at the point of data collection to explain what data we are collecting and why.

10.   Requesting access to data

Data Subjects have rights relating to their Personal Data, including access, rectification and deletion. Given the Revision Census 2024 will never hold Personal Data, such legal rights will not apply; moreover, it would be practically impossible to honour such requests as we would have no way to isolate the data subject in question from the research data.

Partner Schools who are processing and storing Student-Level Personal Data on their own students collected on their behalf by the Revision Census 2024 may wish to make provisions for such rights to be exercised; in that case, such requests must be between the Data Subject and the Partner School, without the involvement of the Revision Census 2024. This should be covered by the Partner School’s existing data policies.

11.   Contact

If you would like to discuss anything in this privacy notice, please contact William Wadsworth, Data Controller and Lead Investigator at census@examstudyexpert.com.