GreenPen Privacy Policy

1 Who we are

GreenPen is operated by Wright Education Group Ltd, Companies House No. 17128367, 128 City Road, London, EC1V 2NX. In this policy, “we”, “us” and “our” mean Wright Education Group Ltd.

2 Important distinction for school data

For pupil records, assessment information, teacher records and other school data entered into GreenPen by a school, the school is normally the controller and we act as processor. This means the school decides why and how that data is used, and we process it to provide, secure and support GreenPen under our agreement with the school.

For Garden International School Primary, the school is expected to provide its own privacy notice to pupils, parents, guardians and staff. Malaysian PDPA guidance indicates that privacy notices may need to be available in both Bahasa Malaysia and English. GreenPen’s English public policy should not replace the school’s own notice.

3 Personal data we process for schools

Pupil names, school identifiers, classes, groups and assessment records.

Teacher, staff and administrator names, work contact details, account details and roles.

Feedback, notes and educational records entered into GreenPen by authorised school users.

Usage, audit, security and technical logs needed to run, protect and support the service.

Support information provided when a school or user asks for help.

4 Personal data we control ourselves

Business contact details for school staff, suppliers and partners.

Account administration, billing, contract and payment records.

Website or enquiry information you send to us directly.

Security, diagnostic and usage information needed to protect and improve GreenPen.

5 How we use personal data

To provide, operate and maintain GreenPen.

To manage school accounts, authorised users, support requests, billing and contracts.

To secure GreenPen, prevent misuse, investigate incidents and fix bugs.

To synchronise teacher and group information where a school purchases a Wonde integration.

To comply with legal obligations and enforce our agreements.

6 What we do not do

We do not sell school personal data.

We do not use school personal data for advertising to pupils, parents or school users.

We do not use identifiable or pseudonymised student data for general-purpose AI model training.

7 Legal basis

Where we act as processor for a school, the school is responsible for identifying the legal basis for its processing and for providing required privacy notices. Where we act as controller for our own business records, we usually rely on contract necessity, legitimate interests, legal obligation or consent depending on the context.

8 Sharing and subprocessors

We share personal data only where necessary to provide, secure and support GreenPen, comply with law, or manage our business. Current core service providers include Supabase for backend and database services, Vercel for frontend hosting and deployment, and Wonde where a school purchases MIS integration. These providers may use their own infrastructure and subprocessors.

9 International processing

GreenPen is operated by a UK company and uses international cloud services. For Garden International School Primary, the primary database is intended to be hosted using Supabase in Singapore AWS ap-southeast-1. Vercel frontend hosting may involve processing in the United States and other locations used by Vercel and its service providers. We use contractual and organisational safeguards appropriate to the services involved.

10 Human access to student data

Human access to identifiable student data is limited to the minimum necessary for support, incident response, bug fixing and service operation.

Diagnostic extracts containing identifiable student data are destroyed after use when no longer required.

The Supplier will require personnel and third parties with access to Customer personal data to follow appropriate data-handling rules, including written confidentiality obligations, least-privilege access, use only on documented instructions, secure transfer and storage, no unauthorised local copies, prompt return or secure deletion of diagnostic material after use, and reporting of suspected security incidents.

11 Retention

School data is retained for the term agreed with the school. Following termination or expiry, we delete or anonymise personal data from active systems within 30 days, subject to routine backup expiry, legal retention requirements and agreed transition support. Business administration records may be kept for longer where needed for accounting, legal, security or contract purposes.

12 Your rights

If your request relates to pupil, parent, teacher or school records held in GreenPen, please contact your school first because the school is normally the controller. If you contact us directly, we may refer the request to the relevant school. For personal data that Wright Education Group Ltd controls directly, you may ask us to access, correct, delete or restrict use of your data, or object to certain processing, subject to applicable law.

13 Security

We use technical and organisational measures intended to protect personal data, including access controls, managed cloud security features, encrypted connections, least privilege access, logging, backup practices and incident response procedures. No online service can be guaranteed to be completely secure.

14 Contact

Questions about this policy or Wright Education Group Ltd’s own processing should be sent to the contact details published with GreenPen or in your school’s agreement. Questions about school-controlled pupil or staff records should usually be directed to the relevant school.

15 Updates

We may update this policy from time to time. The latest version should be made available through GreenPen or our website.