Privacy Policy

How we collect, use, and protect your data

Effective date: August 2026 — Version 1.4

1. Who We Are

Learning Lens is operated by Jamie Scobie, trading as Learning Lens (sole trader, based in Scotland), registered with the Information Commissioner's Office under registration number ZC200575. For the purposes of data protection legislation (the UK General Data Protection Regulation and the Data Protection Act 2018), we are the data processor of information submitted to the Learning Lens platform. The school or local authority that subscribes to Learning Lens is the data controller and determines the purposes and means of processing.

Our Data Protection contact can be reached at: jamie@mylearninglens.app

2. What Data We Process

2.1 Account Data

When you create an account, we collect: your email address, your display name, your role within your school (e.g. Teacher, Principal Teacher, DHT, Head Teacher), your department, and the name of your school. This data is necessary to provide the service and to enforce role-based access controls that ensure users see only the data appropriate to their role.

2.2 Observation and analytics data

The platform processes the following data about classroom observations and school-level analytics:

• The name of the observer (a staff member at the school)
• The name of the teacher being observed (a staff member at the school)
• The department, stage, and subject of the observed lesson
• Pedagogical practice tags selected during the observation (drawn from a research-grounded taxonomy)
• Pupil response tags indicating general engagement patterns (e.g. "high engagement," "on task") — these describe the class as a whole, not individual pupils
• Free-text notes on strengths and areas for development
• Whether the visit is flagged as "worth seeing" or requiring follow-up
• Timestamped event logs from real-time observation capture
• Aggregated analytics and report outputs derived from the above

Important: Learning Lens does not process any pupil personal data. No pupil names, Scottish Candidate Numbers (SCNs), dates of birth, or other pupil identifiers are collected, stored, or processed. The data subjects are school staff members only.

2.3 Future features

If future features are introduced that would process pupil personal data:

• This privacy policy will be updated before any pupil data processing begins
• A Data Protection Impact Assessment will be completed for each such feature
• Schools will be required to confirm their own lawful basis for processing before those features are activated

No pupil data processing will begin without updated documentation and explicit school consent.

3. Lawful Basis for Processing

We have conducted a Legitimate Interest Assessment for the processing of observation data. The assessment concluded that the school's legitimate interest in evidencing and improving learning and teaching, under its statutory self-evaluation duties in Scotland (HGIOS4), outweighs any privacy impact on staff members, provided the processing remains within the non-disciplinary, developmental scope set out in the Terms of Service, given that:

• Classroom observation is an established and expected part of professional practice in Scottish schools
• The data collected is professional in nature (pedagogical practices, not personal characteristics)
• Staff are informed of the processing through this policy and through the school's own staff privacy notice

4. How We Store and Protect Data

4.1 Infrastructure

• Data is stored in a PostgreSQL database hosted by Supabase on Amazon Web Services (AWS) in the EU (Frankfurt, eu-central-1) region.
• All data is encrypted in transit (TLS 1.2+) and at rest (AES-256).
• The application is served over HTTPS via Vercel's global CDN.
• Authentication is managed by Supabase Auth with secure session tokens (JWT).

4.2 Access Controls

• Row Level Security (RLS) is enforced at the database level, ensuring that users can only access data belonging to their own school.
• Role-based access within each school restricts data visibility: teachers see only their own observation records; middle leaders see their department; SLT and admin see school-wide data.
• No Learning Lens staff have routine access to customer data. Database access for maintenance or support is logged and conducted only when necessary.

4.3 Data Isolation

Each school's data is logically isolated through RLS policies. School A cannot access School B's data under any circumstances, regardless of application-level bugs, because the isolation is enforced at the database engine level.

4.4 Evaluative Prose

Evaluative prose in Learning Lens (for example the quantifier-based summary sentences shown in analytics) is generated by deterministic templates from the school's own aggregated observation data. No large language model or third-party AI service processes school data, observation data, or any other personal data.

5. Data Sharing

We do not sell, rent, or share your data with any third party for marketing or commercial purposes.

Data is shared with the following processors solely for the purpose of providing the service:

Supabase, Vercel, Google, and Sentry maintain their own GDPR compliance documentation and Data Processing Agreements (where applicable), which are incorporated by reference.

6. Data Retention

• Account data is retained for the duration of the school's subscription and deleted within 90 days of subscription cancellation, unless the school requests earlier deletion.
• Observation data is retained for the duration of the school's subscription. Schools can delete individual observation records at any time through the application.
• On subscription cancellation, the school may request a full data export (CSV format) before deletion. We will provide this within 30 days of the request.
• Diagnostic error reports (Section 8) are held by Sentry under its own retention schedule for no longer than 90 days from the date the fault occurred, after which they are deleted automatically. They are not exported, aggregated, or retained by us separately.

7. Data Subject Rights

Under UK GDPR, data subjects (staff members whose data is processed) have the following rights:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate data.
• Right to erasure: You may request deletion of your data, subject to the school's legitimate interest in retaining observation records for professional dialogue, self-evaluation under HGIOS4, and collaborative improvement planning, in line with the non-disciplinary use commitment in the Terms of Service.
• Right to restrict processing: You may request that we limit the processing of your data while a concern is investigated.
• Right to object: You may object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds.
• Right to data portability: You may request your data in a structured, commonly used, machine-readable format.

To exercise any of these rights, contact us at jamie@mylearninglens.app or contact your school's data controller directly. We will respond within 30 days.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you believe your data has been handled unlawfully.

8. Cookies, On-Device Storage, and Analytics

Learning Lens does not use advertising or tracking cookies, and no data is shared with advertising networks.

Rather than cookies, the application stores essential working data in your browser: your authentication session in local storage, a short-lived profile cache in session storage, and — to support offline observation capture — queued visits and drafts in IndexedDB. This on-device storage is essential to providing the service and can be removed at any time by signing out and clearing your browser's site data.

We use Vercel Analytics for cookieless, aggregate page-view statistics (no personal data, no cookies, no device fingerprinting), as listed in Section 5.

Error reporting. When the application encounters a fault, it sends a diagnostic report to Sentry (Section 5) so that we can identify and fix the problem. These reports are deliberately limited to technical information: the error type and message, a stack trace of our own application code, your browser and operating system version, your language setting, and the paths of the page where the fault occurred and the page you navigated from. Those paths may include a record identifier, such as a visit reference, but we strip query strings and URL fragments before the report is sent, so authentication tokens and search terms are never included. We do not attach your name, email address, user account identifier or IP address to these reports, and we do not transmit cookies, the content of any request or response, or any observation, reflection or walkthrough data. We do not use session recording or session replay of any kind — no recording is made of what appears on your screen or what you type.

9. International Transfers

Your data is stored within the EU (AWS Frankfurt region, eu-central-1). This ensures GDPR sovereignty without reliance on UK adequacy decisions. Vercel's CDN may cache static application assets (JavaScript, CSS, images) on global edge servers, but no personal data is included in cached assets.

Diagnostic error reports (Section 8) are likewise held within the EU: we use Sentry's EU region, where data at rest is stored in Frankfurt, Germany. Sentry is a US-incorporated company, so its Data Processing Addendum incorporates Standard Contractual Clauses and the UK International Data Transfer Addendum to cover any access from outside the EEA.

One incidental exception applies: business email correspondence handled through Google Workspace (Section 5) is processed on Google's global infrastructure under UK Standard Contractual Clauses and Google's Data Privacy Framework certification. No observation or platform data is processed through it. If our infrastructure arrangements otherwise change such that personal data may be transferred outside the EU/EEA, we will update this policy and ensure appropriate safeguards (such as Standard Contractual Clauses) are in place.

10. Conversation Request Form

When you submit a conversation request form on our website, we collect your name, work email address, school name, and role. We use this information solely to contact you to arrange a conversation about Learning Lens.

• Lawful basis: Consent (Article 6(1)(a)) — by submitting the form, you consent to us contacting you to arrange a conversation.
• Retention: Conversation request data is retained for 12 months from the date of submission and then deleted.
• Deletion: You may request deletion of your conversation request at any time by emailing jamie@mylearninglens.app.

We do not share conversation request data with any third party.

11. The Wholesight Demo (/projects/wholesight)

The Wholesight page is an interactive demonstration built on a wholly synthetic dataset. It contains no real pupil, school or staff data of any kind.

When you finish a run, we record one anonymous row so that we can show visitors how other people played the case. That row contains only: which of the three readings you backed, which intervention and framing you chose, five true/false values describing the shape of the falsifier you wrote (whether it named a target, a direction, a magnitude, a horizon, and a single evidence channel), how that falsifier resolved, your final attribution, and how many of the five data cuts you opened.

• We do not store the text you type. The falsifier you write is scored in your browser and discarded. It is never transmitted, and there is no field in which it could be stored.
• We do not record any identifier. No account, no IP address, no cookie, no session ID, no device fingerprint. The row cannot be linked to you, to your visit, or to any other row.
• Lawful basis: Legitimate interests (Article 6(1)(f)) — understanding how a demonstration is used. As the record contains no personal data, no personal data is processed.
• Retention: Retained indefinitely as anonymous aggregate counts.

Your browser stores a single flag in local storage so that replaying the case does not record a second row. You can clear it at any time by clearing site data.

12. Teacher Anonymisation and Data Retention

Schools can anonymise the profiles of staff who have left. Anonymisation replaces the staff member's name and email with "Former Staff" while preserving observation data for aggregate analytics. This is handled through the Staff Management page by school administrators.

Schools can also set a data retention period (1–7 years, default 3 years). After this period, narrative fields (strengths, development points) on visits are purged while practice tags and event data are retained for aggregate analysis. This is a manual process initiated by the school administrator.

13. Export Controls

All data exports (PDF reports, CSV exports) are logged with the exporter's identity, the export type, and a timestamp. CSV exports containing raw teacher-level data are restricted to admin and SLT roles. Export logs are visible to school administrators.

14. Changes to This Policy

We will update this policy when our processing activities change, particularly when new modules are introduced. Material changes will be communicated to school administrators via email at least 30 days before taking effect. The current version is always available within the application.

15. Contact

Learning Lens (Jamie Scobie, trading as Learning Lens)

Based in Scotland — ICO registration ZC200575

Email: jamie@mylearninglens.app