Privacy notice

Part 1: general information

Thank you for visiting the Hwb platform, which is operated by the Welsh Government (we or us). This privacy notice sets out how we collect and use personal information when you use Hwb services. When we say ‘personal information’ in this notice, we mean information that relates to you and can be used to identify you.

This privacy notice does not apply to other websites and services which may be accessible via the Hwb platform. We encourage you to read the privacy notices on the other websites you visit.

Your rights

You have rights in relation to the personal information we hold about you. These are:

the right to request access to your own personal information that we hold and this is sometimes known as a 'subject access request'
the right to have any inaccurate information we hold about you corrected (rectification)
the right to have your information deleted (erasure)
the right to request the restriction or suppression of your personal data (restrict processing)
the right to object to the use of your personal information for certain purposes (objection)
the right to your information in a portable format
the right to object to decisions about you being made by wholly automated means

Many of the rights listed above are limited to certain defined circumstances and we may not be able to comply with your request in full. We will tell you if this is the case. You can read more about your rights on the Information Commissioner’s Office (ICO) website.

If you make a request to us, we will respond to you within one calendar month. We will not charge a fee for dealing with your request.

How to contact us

This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed.

If you want to request further information about our privacy notice, exercise any of your rights or make a complaint, please email us at dataprotectionofficer@gov.wales or write to:

Data Protection Officer
Welsh Government
Cathays Park
Cardiff
CF10 3NQ

If you have any other questions about the Hwb platform or Hwb services, please email us at support@hwbcymru.net or write to:

Digital Learning Division (Hwb)
Welsh Government
Llys-y-ddraig
Penllergaer Business Park
Swansea
SA4 9NX

Feedback, comments and complaints

We try to meet the highest standards when collecting and using personal information. For this reason, we welcome your feedback and take any complaints we receive about this very seriously. We encourage people to tell us if they think that our collection or use of information is unfair, misleading or inappropriate.

If you do contact us, we may need to contact other government departments in order to answer your query. If you have a technical question, we may need to pass it to our technology suppliers.

We do not pass on any of your personal information when dealing with your enquiry, unless you have given us permission to do so. Once we have replied to you, we keep a record of your message for audit purposes.

Changes to this privacy notice

If this privacy notice changes in any way, we will place an updated version on the Hwb website. If we make any significant changes, we will inform you of those changes.

This privacy notice was last updated on 21^st August 2024.

Part 2: technical information

Browsing the website without logging in

The website is structured so that you can visit it without either identifying yourself or revealing any personal information. If you choose not to log in to the website, we will not collect any personal data that specifically identifies you. However, we will automatically collect certain information when you visit our website which may include technical information, such as the Internal Protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating systems and platform.

This information is used to ensure the content of the website is presented in the most effective manner for you and for your device.

Uses of your information

We will use this information to:

develop, test and improve our systems
ensure that the content of our website is presented in the most effective manner for you and for your computer
administer our website
for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
carry out statistical analyses, including benchmarking exercises, to enable us to understand you better and improve our services

Logging in to the Hwb platform

Visitors to the Hwb website who have a Hwb account are able to log in to use the platform and services. Please refer to 'Part 3 specific information by user type’ below for more information about personal information shared with the Welsh Government and the services available to different Hwb users.

Retention of your personal information

Personal information that is used for the creation of your unique Hwb account will be retained for the period that your account remains active. This period is dependent on the type of account you have, in accordance with the following retention periods:

Accounts for learners and staff in maintained schools in Wales are automatically created from data in your school’s Management Information System (MIS) i.e. SIMS or Teacher Centre. We call these 'MIS accounts'. MIS accounts remain active as long as your details remain part of your school’s MIS. When you leave school or are no longer employed in the Welsh maintained schools sector, your account will be automatically deactivated and subsequently deleted* after 12 months, unless we receive a request to reactivate the account within this period.

Non-MIS accounts are manually created by authorised Hwb administrators for users who do not have a learner or staff record in a school’s MIS. These users may include governors, supply teachers, local authority staff, regional consortia staff, Estyn inspectors, Post-16 staff etc. Non-MIS accounts are activated for a set period of time i.e. 1 month, 3 months, 6 months or to the end of the academic year (i.e. 31 August) All non-MIS accounts are automatically deactivated after the set period ends or when the academic year ends and then deleted* after 12 months, unless the account period is extended by a Hwb administrator or a request to reactivate the account within the 12 month period is received.

When a Hwb account is deleted, all personal information associated with it is deleted. This includes all associated Hwb services, including a user's Microsoft 365 account and Google Workspace for Education account. Visit the Microsoft Privacy Statement and Google Help Centre for more information or contact your school, or organisation, about deletion of accounts.

Where there are extenuating circumstances, e.g. a formal investigation or litigation is underway or contemplated, a user’s Hwb account may be held until we are instructed otherwise.

More information about managing accounts and account retention periods is available in our Support Centre.

The retention period of personal information which is uploaded to Hwb services may be impacted by contractual changes between the Welsh Government and the relevant service provider, or alternatively may be removed in line with local data retention periods set by individual schools, local authorities and organisations. Please contact your local school, local authority or organisation for further information on local data retention periods.

Cookies

Like many websites, the Welsh Government uses cookies on the Hwb website. Cookies are small pieces of information sent by a web server to a web browser which enable the server to collect information from the browser.

Our cookies collect information related to your IP address, operating system and your usage of our website.

When you visit our website, we use essential cookies to enable navigation and provide use of its basic features, such as maintaining your account details for the duration of the session. These essential cookies are necessary to the running and use of the website and cannot be declined.

We also use cookies to enhance the functionality of the website by, for example, storing any preferences you enter. You have the option to decline cookies that measure your use of the website.

More information about cookies is available from the ICO. For more information on Hwb cookies, please refer to the Hwb Cookie Policy.

Part 3: specific information by user type

This platform has been developed by the Welsh Government so that anyone may browse without needing to log in.

Your information will be used differently if you decide to log in, or depending on whether you are a learner, staff, governor or someone else who works in the wider Welsh education sector.

Learner

The Welsh Government will provide a unique and secure Hwb account for all learners in maintained schools in Wales which can be used to access the personalised assessments and Hwb services. More information about personalised assessments is available on Hwb. Your Hwb account is automatically created and kept up-to-date from information we receive from your school’s Management Information System (MIS) which is maintained by your school.

If you want to use the digital tools and services that are available to learners on the platform, you will need to log in.

For learners, the Welsh Government will collect and use your personal information in the ways set out below:

1. Creating your unique Hwb account – what information do we collect about you?

Your school will provide the following personal information about you to the Welsh Government to create your unique Hwb account:

First name
Middle name(s)
Name
Date of birth
Sex
School name and number
Year group, National Curriculum year group, registration group, class groups and subject groups
School admission number
Enrolment status i.e. whether you are currently on roll (active account) or if you have left the school (deactivated account)
Registration status i.e. if you attend one or more schools
Your unique pupil number (UPN) which is then encrypted
Your generic school role i.e. to determine you are a learner

We create your account and each time you log in to the platform we will check your details. The personal information used to create your unique Hwb account is stored on the Microsoft Cloud in a secure area operated by the Welsh Government and situated within the United Kingdom and/or European Economic Area.

The Welsh Government has a legal obligation to provide a unique and secure Hwb account for all learners in Wales, which can be used to access the personalised assessments (please see Section 4 below).

Providing a safe and secure platform for learners to use is an important part of our mission to improve education standards in Wales. Using your personal information to enable you to log in securely is essential and is carried out in the public interest.

2. Logging into the Hwb platform

Once we have created your Hwb account, you will be able to log in to the platform to access the personalised assessments and Hwb services (see point 5 for full details).

Whenever you use your Hwb account, we use your personal information to identify you and allow you to use the platform. We keep a record of every time you log in for audit purposes and that record is kept for one year.

Using your personal information to identify you and check your browsing session is an important part of ensuring that the platform remains secure. This is essential and is carried out in the public interest.

3. Using the Hwb platform

You do not need to provide any further personal information to us to use the platform.

Depending on how you use the platform, you may choose to provide us with other personal information. For example, you can upload information, personalise your profile page or choose to share information with others. It is up to you to decide what specific information you upload. Any information you upload will be processed on our behalf by our service providers.

Important notice

We do not recommend that you upload personal information which falls within ‘special categories’ of personal information recognised by data protection law. These include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health and information concerning a person's sex life or sexual orientation. Information relating to criminal offences and convictions is treated in a similar way.

If you do choose to upload any such information, it is important for you to understand that it may be available for other users of our platform to see.

Any personal information uploaded by you onto the platform will be used by the Welsh Government and its contractors in accordance with your instructions.

Advice and guidance in relation to the storage of information on the Hwb platform and the associated external services is available in the Hwb Trust Centre and Support Centre.

4. Personalised Assessments

As part of our commitment to improving educational standards in Wales, the Welsh Government has introduced online personalised assessments for learners in Years 2 to 9 in maintained schools in Wales.

The Welsh Government has a legal obligation to provide assessment arrangements for reading and numeracy for learners. Personalised assessments will be taken by learners via the Hwb platform. Your school will tell you when these need to be completed and give you all the information you need.

Personalised assessments are different from traditional tests because the questions are generated based on the learner’s response to the previous question. This provides an individual assessment experience and tailors the level of challenge for each learner. Personalised assessments will be accessed by each learner via their secure log-in to the Hwb platform.

The personalised assessments are developed by a consortium of partners, led by AlphaPlus Consultancy Ltd, on behalf of the Welsh Government. We will collect your assessment feedback and share with your school.

For personalised assessments, your data is collected and retained in line with the school data collection privacy notice.

Details of the data processed by our supplier on our behalf are as follows:

AlphaPlus Consultancy Ltd – Online Personalised Assessments (statutory service)
First name
Last name
Date of birth
Sex
Hwb username
Hwb email address
Hwb unique identifier (Object ID)
School name and number
Year group, National Curriculum year group, registration group, class groups and subject groups
School admission number
Enrolment status i.e. whether you are currently on roll (active account) or if you have left the school (deactivated account)
Registration status i.e. if you attend one or more schools
Your unique pupil number (UPN) which is then encrypted
Your generic school role i.e. to determine you are a learner
A code based on your unique pupil number (UPN) i.e. an encrypted UPN
Your generic school role i.e. to determine you are a learner

4.1 Trials of personalised assessments

From time to time, the Welsh Government will carry out large-scale trials of new assessment material in which schools will be asked to participate. The purpose of these trials is to support the development of the online personalised assessments, check that new questions are working as intended, and gain feedback from learners and teachers. Schools wishing to participate will be asked to register in advance.

If your school is taking part in a trial, you may be asked to take an assessment, using your Hwb log-in details at school. Your teacher will explain how to access the assessment and give you any specific instructions.

Your answers will be kept confidential and will be used to help us understand how the assessments are working. Your answers will be kept by the Welsh Government for 18 months after the end of each trial, after which time the information will be destroyed. More information about personalised assessments is available on Hwb.

Live trialling of single questions

From time to time your assessment may include a single additional ‘trial’ question at the end. Your answer to the question will not be part of your assessment outcome or be included in any reporting.

Adding a trial question to an assessment is a way of collecting data on how learners answer the new questions before they are added to the assessment question bank. If you get a trial question it will be matched to your curriculum year and it will always be the last question in an assessment. Your answer to the trial question will be held alongside your other assessment data.

5. Hwb services

When you log in, the platform will automatically enable you to access and use the following services:

Microsoft 365(including Word, Excel and Outlook email) and Minecraft: Education Edition, which are all provided by the Microsoft Corporation.
The suite of approved Google Workspace for Education Core Services, which are provided by Google, Inc.
Thinqi tool suite, which is provided by CDSM Interactive Solutions Ltd.
Just2easytool suite, which is provided by Just2easy Ltd.
Adobe Express (including Adobe Creative Cloud if licenced), which is provided by Adobe Systems Software Ireland Limited.
Apple services, which are provided by Apple Inc (if your school has opted-in).

Hwb services are made available by the Welsh Government for use by schools and learners, but they are operated by the contractors listed above. The Welsh Government will securely send specific information to these contractors to allow you to access their services. Any other personal information that you choose to upload as part of your use of these services will be handled by the relevant contractors.

As Hwb services are provided by our contractors, any personal information that you share using these tools will be shared with these contractors, and potentially securely transferred to locations outside of the UK and European Economic Area. To ensure that your personal information is protected, we have put in place the appropriate contractual protections and security measures. For example, we ensure that your information is stored in a coded form so it cannot be read by others.

Details of our suppliers and the data they process are as follows:

CDSM Interactive Solutions Ltd – Hwb platform

First name
Last name
Hwb username
Hwb email
School name and number

Just2easy – J2e Tool suite

First name
Last name
Hwb username
School number

Microsoft Corporation – Office 365

First name
Last name
Display name
Hwb username
Hwb email address
Role
School number
School name

Google Inc. – Google Workspace for Education

First name
Last name
Hwb username
Hwb email address
School name and number
Class Groups

Adobe Systems Software Ireland Limited – Adobe Express (and Adobe Creative Cloud if licenced)

First name
Last name
Hwb username
Hwb email address

Apple Inc. – Apple services (only applies if your school has opted-in to Apple services)

First name
Last name
Hwb username
Hwb email address
School name and number
Year and class groups

6. Sharing of your information

We may share information about you with other parts of the Welsh Government, local authorities, schools or with our partner organisations where we are satisfied that their intended use of your information is for educational or related purposes that are compatible with our use of your information to provide the Hwb platform, there is a legitimate interest in sharing that information or we are required by law to share. Please see above for the types of information shared with those organisations.

Where your information is shared with a partner organisation, we will ensure that they can only use your information for limited purposes and that they keep your information secure. You should refer to the privacy notices of those organisations in the Additional Information section below.

7. If you contact us

We will collect personal information about you if you complete an online form or contact us for any other reason. The exact personal information will depend on what you choose to provide us with. We will use your personal information to respond to your enquiry or request on the basis of your consent.

A summary of this Privacy Notice for learners is available in Appendix I.

Staff

All staff in maintained schools in Wales are provided with a Hwb account, which can be used to access the personalised assessments and Hwb services. Your Hwb account is automatically created and kept up-to-date from information we receive from your school’s Management Information System (MIS) which is maintained by your school.

If you want to use the digital tools and services that are available to staff on the platform, you will need to log in.

For staff, the Welsh Government will collect and use your personal information in the ways set out below:

1. Creating your unique Hwb account – what information do we collect about you?

Your school will provide the following personal information about you to the Welsh Government to create your unique Hwb account:

First name
Last name
Title
School staff code
Staff member ID
School name and number
Year, registration and class groups
Generic school role i.e. to determine if you are a member of staff
Staff role e.g. headteacher, deputy headteacher, teacher, teaching assistant, IT technician, administrator etc

We create your account and each time you decide to log in to the platform we will check your details. The personal information used to create your unique Hwb account is stored on the Microsoft Cloud in a secure area operated by the Welsh Government and situated within the United Kingdom and/or the European Economic Area.

The Welsh Government has a legal obligation to provide a unique and secure Hwb account for all teachers in Wales, which can be used to access the personalised assessments (please see Section 4 below).

Providing a safe and secure platform for use by staff is an important part of our mission to improve education standards in Wales. Using your personal information to enable you to log in securely is essential and is carried out in the public interest.

2. Logging into the Hwb platform

Once we have created your Hwb account, you will be able to log into the platform and access the areas that are specifically made available to staff. It is up to you and your school if you wish to log into the platform, however, you will need to log in to the platform to access personalised assessments (please see Section 4 below).

When you first log in to the platform, you will be shown our ‘End User Licence Agreement’ (important notice). This provides links to the ‘Hwb Terms and Conditions’ that will govern your use of the platform, as well as this ‘Hwb Privacy Notice’. You will be required to click to confirm that you accept the terms and conditions. If the terms and conditions or privacy notice change, you will be required to re-accept the End User Licence Agreement.

Using your personal information to identify you and check your browsing session is an important part of ensuring that the platform remains secure. This is necessary for the performance of our task and is carried out in the public interest.

3. Using the Hwb platform

You do not need to provide any further personal information to us to use the platform.

Important notice

We do not recommend that you upload personal information which falls within ‘special categories’ of personal information recognised by data protection law. These include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health and information concerning a person’s sex life or sexual orientation. Information relating to criminal offences and convictions is treated in a similar way.

If you do choose to upload any such information, it is important for you to understand that it may be available for other users of our platform to see.

Any personal information uploaded by you onto the platform will be used by Welsh Government and its contractors in accordance with your instructions.

Advice and guidance in relation to storage of information on the Hwb platform and the associated external services is available in the Hwb Trust Centre and Support Centre.

4. Personalised Assessments

As part of our commitment to improving educational standards in Wales, the Welsh Government has introduced online personalised assessments for learners in Years 2 to 9 in maintained schools in Wales.

The Welsh Government has a legal obligation to provide assessment arrangements for reading and numeracy for learners in Wales.

Information derived from the assessments of individual learners, and information available for collation at a group or class, year and school level, can be seen by members of staff who have been given relevant access. The level of staff access is determined by the school’s headteacher.

For personalised assessments your learners’ data is collected and retained in line with the school data collection privacy notice.

Details of the data processed by our supplier are as follows:

First name
Last name
Hwb username
Hwb email address
School name and number
Year, registration and class groups
Generic school role i.e. to determine you are a member of staff
Staff role e.g. headteacher, deputy headteacher, teacher, teaching assistant, IT technician, administrator etc

4.1 Trials of personalised assessments

From time to time, the Welsh Government will carry out large-scale trials of new assessment materials in which schools will be asked to participate. The purpose of these trials is to support the development of the online personalised assessments, check that new questions are working as intended, and gain feedback from learners and teachers. The assessments are developed and trialled by a consortium of partners, led by AlphaPlus Consultancy Ltd, on behalf of the Welsh Government. Schools wishing to participate will be asked to register in advance.

If your school is taking part in a trial, you may be asked to schedule assessments for your learners, using your Hwb log-in details. You should explain to your learners how to access the assessments and give any specific instructions, as per the provided guidance.

Your learners’ responses will be kept confidential and will be used to evaluate the functioning of the assessments. Their responses will be retained by the Welsh Government for 18 months after completion of the trial, after which time the information will be destroyed. More information about personalised assessments is available on Hwb.

Live trialling of single questions

From time to time an assessment may include a single additional ‘trial’ question at the end. The answer to the question will not contribute to learners’ assessment outcome or be included in any reporting.

Adding a trial question to an assessment is a way of collecting data on how learners respond to new questions before they are added to the assessment question bank. If learners receive a trial question it will be matched to their curriculum year and it will always appear as the last question in an assessment. Your learners’ responses to the ‘trial’ questions will be held alongside their other assessment data.

5. Hwb services

The platform will automatically enable you to access and use the following services:

Microsoft 365(including Word, Excel and Outlook email) and Minecraft: Education Edition, which are all provided by the Microsoft Corporation.
The suite of approved Google Workspace for Education online tools, including YouTube, which are provided by Google, Inc.
Thinqi tool suite, which is provided by CDSM Interactive Solutions Ltd.
Just2easytool suite, which is provided by Just2easy Ltd.
Adobe Express (including Adobe Creative Cloud if licenced), which is provided by Adobe Systems Software Ireland Limited.
Apple services, which are provided by Apple Inc (if your school has opted-in).
360 safe Cymru and 360 digi Cymru, which are provided by South West Grid for Learning Trust Ltd (SWGfL).

Hwb services are made available by the Welsh Government for users of the platform, but they are operated by the contractors listed above. The Welsh Government will securely send specific information to these contractors to allow you to access their services. Any other personal information that you choose to upload as part of your use of these services will be handled by the relevant contractor.

The Welsh Government believes that making the Hwb services listed above available to staff, is an important part of our mission to improve education standards in Wales. The use of your personal information to enable you to access and use these services is necessary for the performance of this task and is carried out in the public interest.

The use you make of the Hwb services is a matter for you and depends on how you and your school choose to carry out your legal obligations. Please follow any instructions that you are given by your school and the terms and conditions of our End User Licence Agreement. Any personal information you do upload to these external services will be used by our contractors in accordance with your instructions.

Details of our suppliers and the data they process are as follows:

CDSM Interactive Solutions Ltd – Hwb platform

First name
Last name
Hwb username
Hwb email address
School name and number

Just2easy – J2e Tool suite

First name
Last name
Hwb username
School name and number

Microsoft Corporation – Microsoft 365

First name
Last name
Display name
Hwb username
Hwb email address
Generic school role
School name and number
Local authority

Google Inc. – Google Workspace for Education (including YouTube)

First name
Last name
Hwb username
Hwb email address
School name and number
Class Groups

Adobe Systems Software Ireland Limited – Adobe Express (and Adobe Creative Cloud if licenced)

First name
Last name
Hwb username
Hwb email address

Apple Inc.: Apple services (only applies if your school has opted-in to Apple services)

First name
Last name
Hwb username
Hwb email address
School name and number
Year and class groups

South West Grid for Learning Trust Ltd (SWGfL): 360 safe Cymru and 360 digi Cymru

First name
Last name
Hwb username
Hwb email address
School name and number
Local authority
Staff role

Freshworks Ltd: Freshservice

First name
Last name
Hwb username
Hwb email address
School name and number
Generic role
Hwb administrator status
Local authority

6. Sharing of your information

7. If you contact us

We will collect personal information about you if you complete an online form, register for an event (please see Part 4 below), or contact us for any other reason. The exact personal information will depend on what you choose to provide us with. We will use your personal information to respond to your enquiry or request on the basis of your consent.

Governor

Governors for maintained schools in Wales may be provided with a Hwb account. These accounts are allocated and maintained directly by each school or local authority. If you want to access all of the digital tools and resources on the platform that are available to governors, you will need to log in.

For governors, the Welsh Government will collect and use your personal information in the ways set out below:

1. Creating your unique Hwb account – what information do we collect about you?

Your school or local authority will provide the following personal information about you to the Welsh Government to create your unique Hwb account:

First name
Last name
Your role i.e. governor
School name and number

We create your account and each time you decide to log in to the platform we will check your details through. The personal information used to create your unique Hwb account is stored on the Microsoft Cloud in a secure area operated by the Welsh Government and situated within the United Kingdom and/or the European Economic Area.

The development of a safe and secure platform for use by governors is an important part of our mission to improve education standards in Wales. Using your information to provide unique and secure log-ins for individual governors is carried out in the public interest.

2. Logging into the Hwb platform

Once we have created your Hwb account, you will be able to log in to the platform and access the areas that are specifically made available to governors. It is entirely up to you whether you wish to log in to the platform.

3. Using the Hwb platform

You do not need to provide any further personal information to us in order to use the platform.

Important notice

We do not recommend that you upload personal information which falls within ‘special categories’ of personal information recognised by data protection law. These include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health and information concerning a person’s sex life or sexual orientation. Information relating to criminal offences and convictions is treated in a similar way.

If you do choose to upload any such information, it is important for you to understand that it may be available for other users of our platform to see.

Any personal information uploaded by you onto the platform will be used by Welsh Government and its contractors in accordance with your instructions.

Advice and guidance in relation to storage of information on the Hwb platform and the associated external services is available in the Hwb Trust Centre and Support Centre.

4. Hwb services

The platform will automatically enable you to access and use the following services:

The Microsoft 365 suite of online tools, which is provided by the Microsoft Corporation, e.g. Word, Excel and Outlook (email).
The Google Workspace for Education Fundamentalssuite of online tools, including YouTube, which is provided by Google, Inc.
Thinqi tool suite, which is provided by CDSM Interactive Solutions Ltd.
Freshservice, which is provided by Freshworks Ltd.

Hwb services are made available by the Welsh Government for use by users of the platform, but they are operated by the contractors listed above. The Welsh Government will securely send specific information to these contractors in order to allow you to access their services. Any other personal information that you choose to upload as part of your use of these services will be handled by the relevant contractor.

The Welsh Government believes that making available the Hwb services listed above to governors is an important part of our mission to improve education standards in Wales. The use of your personal information to enable you to access and use these services is necessary for the performance of this task and is carried out in the public interest.

The use you make of the Hwb services is a matter for you and depends on how you and your school or local authority choose to carry out your governor duties. Please follow any instructions that you are given by your school or local authority and the terms and conditions of our End User Licence Agreement. Any personal information you do upload to these external services will be used by our contractors in accordance with your instructions.

Details of our suppliers and the data they process are as follows:

CDSM Interactive Solutions Ltd – Hwb platform

First name
Last name
Hwb username
Hwb email address
School name and number
Role (i.e. Governor)

Microsoft Corporation – Office 365

First name
Last name
Hwb username
Hwb email address
School name and number
Role (i.e. Governor)

Google Inc. – Google Workspace for Education Fundamentals

First name
Last name
Hwb username
Hwb email address
School name and number

Freshworks Ltd – Freshservice

First name
Last name
Hwb username
Hwb email address
School name and number
Role (i.e. Governor)
Hwb administrator status
Local authority

5. Sharing of your information

We may share information about you with other parts of the Welsh Government or with our partner organisations where we are satisfied that their intended use of your information is for educational or related purposes that are compatible with our use of your information to provide the Hwb platform, there is a legitimate interest in sharing that information or we are required by law to share. Please see above for the types of information shared with those organisations.

6. If you contact us

We will collect personal information about you if you complete an online form, register for an event (please see Part 4 below), or contact us for any other reason. The exact personal information will depend on what you choose to provide us with. We will use your personal information in order to respond to your enquiry or request on the basis of your consent.

Other education stakeholder

As well as learners, staff and governors, the Welsh Government can provide a Hwb account to other education stakeholders. These accounts are allocated and maintained by the Welsh Government.

If you want to use the digital tools and services that are available to other education stakeholders on the platform, you will need to log in.

For other education stakeholders, the Welsh Government will collect and use your personal information in the ways set out below:

1. Creating your unique Hwb account – what information do we collect about you?

Your organisation will provide the following personal information about you to the Welsh Government to create your unique Hwb account:

First name
Last name
Your role
Name of your organisation
Job title
Alternative email address
Contact number

Each time you log in to the platform we will check your details. The personal information used to create your unique Hwb account is stored on the Microsoft Cloud in a secure area operated by the Welsh Government and situated within the European Economic Area.

The development of a safe and secure platform for use by those involved in education in Wales is a part of our mission to improve education standards in Wales. Using your information to provide unique and secure log-ins for individual education stakeholders is necessary for the performance of this task and is carried out in the public interest.

2. Logging into the Hwb platform

Once we have created your Hwb account, you will be able to log into the platform and access the areas that are specifically made available to other education stakeholders. It is entirely up to you whether or not you wish to log into the platform.

When you first log in to the platform, you will be shown our ‘End User Licence Agreement’ (Important Notice). This provides links to the ‘Hwb Terms and Conditions’ that will govern your use of the platform, as well as this ‘Hwb Privacy Notice’. You will be required to click to confirm that you accept the terms and conditions. If the terms and conditions or privacy notice change, you will be required to re-accept the End User Licence Agreement.

Using your personal information to identify you and check your browsing session is an important part of ensuring that the platform remains secure. This is necessary for the performance of this task and is carried out in the public interest.

3. Using the Hwb platform

You do not need to provide any further personal information to us in order to use the platform.

Important notice

We do not recommend that you upload personal information which falls within ‘special categories’ of personal information recognised by data protection law. These include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health and information concerning a person’s sex life or sexual orientation. Information relating to criminal offences and convictions is treated in a similar way.

If you do choose to upload any such information, it is important for you to understand that it may be available for other users of our platform to see.

Any personal information uploaded by you onto the platform will be used by the Welsh Government and its contractors in accordance with your instructions.

Advice and guidance in relation to storage of information on the Hwb platform and the associated external services is available in the Hwb Trust Centre and Support Centre.

4. Hwb services

Depending on the permissions approved by your organisation’s Hwb administrator, the platform may enable you to access some or all of the following additional services:

Microsoft 365(including Word, Excel and Outlook email) and Minecraft: Education Edition, which are provided by the Microsoft Corporation.
The Google Workspace for Education Fundamentalssuite of online tools, including YouTube, which are provided by Google, Inc.
Thinqi tool suite, which is provided by CDSM Interactive Solutions Ltd.
Just2easytool suite, which is provided via CDSM Interactive Solutions Ltd subcontractor Just2easy Ltd.
Adobe Express (including Adobe Creative Cloud if licenced), which is provided by Adobe Systems Software Ireland Limited.
Apple services, which are provided by Apple Inc (if your school has opted-in).
360 safe Cymru and 360 digi Cymru, which are provided by South West Grid for Learning Trust Ltd (SWGfL).
Freshservice, which is provided by Freshworks Ltd.

Hwb services are made available by the Welsh Government for users of the platform, but they are operated by the contractors listed above. Welsh Government will securely send specific information to these contractors to allow you to access their services. Any other personal information that you choose to upload as part of your use of these services will be handled by the relevant contractor.

The Welsh Government believes that making the Hwb services listed above available to appropriate education stakeholders in Wales is an important part of our mission to improve education standards in Wales. The use of your personal information to enable you to access and use these services is necessary for the performance of this task and is carried out in the public interest.

The use you make of the Hwb services is a matter for you, and depends on how you and your organisation choose to carry out your legal obligations. Please follow any instructions that you are given by your organisation and the terms and conditions of our End User Licence Agreement. Any personal information you do upload to these external services will be used by our contractors in accordance with your instructions.

Details of our suppliers and the data they process are as follows:

CDSM Interactive Solutions Ltd – Hwb platform

First name
Last name
Hwb username
Hwb email address

Just2easy – J2e Tool suite

First name
Last name
Hwb username

Microsoft Corporation – Microsoft 365

First name
Last name
Display name
Hwb username
Hwb email address
Local authority (if relevant)

Google Inc. – Google Workspace for Education Fundamentals (including YouTube)

First name
Last name
Hwb username
Hwb email address

Adobe Systems Software Ireland Limited – Adobe Express (and Adobe Creative Cloud if licenced)

First name
Last name
Hwb username
Hwb email address

Apple Inc. – Apple services (only applies if your school has opted-in to Apple services)

First name
Last name
Hwb username
Hwb email address

South West Grid for Learning Trust Ltd (SWGfL) – 360 safe Cymru and 360 digi Cymru

First name
Last name
Hwb username
Hwb email address
Local authority (if relevant)

Freshworks Ltd – Freshservice

First name
Last name
Hwb username
Hwb email address
Hwb administrator status
Local authority (if relevant)

5. Sharing of your information

We may share information about you with other parts of Welsh Government, local authorities, schools or with our partner organisations where we are satisfied that their intended use of your information is for educational or related purposes that are compatible with our use of your information to provide the Hwb platform, there is a legitimate interest in sharing that information or we are required by law to share.

6. If you contact us

We will collect personal information about you if you complete an online form, register for an event (please see Part 4 below), or contact us for any other reason. The exact personal information will depend on what you choose to provide us with. We will use your personal information in order to respond to your enquiry or request on the basis of your consent.

Part 4: additional information

Third party apps, Google apps and extensions for Chrome

If you chose to use your Hwb account to access Microsoft third party apps, Google apps and extensions for Chrome (including apps provided through managed Google Play), or other third party services that have been approved by your school, local authority or organisation, we accept no responsibility for their use. It is your responsibility to read and accept the terms and conditions and privacy notices of each Microsoft third party app, Google apps and extensions for Chrome or other third party apps that you choose to use.

Please contact us for more details of the specific data sharing arrangements we have in place.

Events Booking Service

The platform provides a booking service for events created and managed by either the Welsh Government or another organisation. This booking service is operated on our behalf by CDSM Interactive Solutions Limited.

If you wish to register for an event, you will need to provide your personal details. If you are an authorised user (with an existing Hwb account), this will be done automatically if you are logged in. If you are not an authorised user, you will need to manually enter your details (including your name, email address, the name of your organisation and your location).

Your personal data will be shared with the event organiser for them to manage your registration. The event organiser will be responsible for handling your information in accordance with data protection requirements.

Appendix I

Are you a learner? Here’s a brief explanation of the Hwb Privacy Notice

Our privacy notice tells you how the Welsh Government uses personal information about you and other users of the Hwb platform.
Your 'personal information' means any information that relates to you and can be used to identify you.
Your school has lots of information about you and shares some of this with the Welsh Government so that we can give you a Hwb account to use online services like Microsoft 365 and Google Classroom.
The Welsh Government will work to keep your personal information safe and not share it if we don’t need to.
Every learner and teacher in maintained schools in Wales has a Hwb account. You can use it to access educational tools and resources, as well as the numeracy and reading personalised assessments.
Your teachers will tell you when to use your Hwb account to take the assessments (usually from when you are in year 2 up to year 9).
The Hwb platform also allows you to log in to other educational services, for example, Microsoft Word, Excel, Outlook (email), Minecraft for Education or Google for Education. The Welsh Government will then securely share some of your personal information with our suppliers so that you can use their services.
The Welsh Government will keep your personal information while you are in school and your Hwb account is active and for one year once you leave and it is de-activated. We will keep information about the assessments for longer than this.
You have certain rights relating to your personal information. If you want to find out more, the Information Commissioner’s Office (ICO) website has everything you need to know.

Privacy notice

Part 1: general information

Your rights

How to contact us

Feedback, comments and complaints

Changes to this privacy notice

Part 2: technical information

Browsing the website without logging in

Uses of your information

Logging in to the Hwb platform

Retention of your personal information

Cookies

Part 3: specific information by user type

Learner

1. Creating your unique Hwb account – what information do we collect about you?

2. Logging into the Hwb platform

3. Using the Hwb platform

Important notice

4. Personalised Assessments

4.1 Trials of personalised assessments

5. Hwb services

6. Sharing of your information

7. If you contact us

Staff

1. Creating your unique Hwb account – what information do we collect about you?

2. Logging into the Hwb platform

3. Using the Hwb platform

Important notice

4. Personalised Assessments

5. Hwb services

CDSM Interactive Solutions Ltd – Hwb platform

Just2easy – J2e Tool suite

Microsoft Corporation – Microsoft 365

Google Inc. – Google Workspace for Education (including YouTube)

Adobe Systems Software Ireland Limited – Adobe Express (and Adobe Creative Cloud if licenced)

Apple Inc.: Apple services (only applies if your school has opted-in to Apple services)

South West Grid for Learning Trust Ltd (SWGfL): 360 safe Cymru and 360 digi Cymru

Freshworks Ltd: Freshservice

6. Sharing of your information

7. If you contact us

Governor

1. Creating your unique Hwb account – what information do we collect about you?

2. Logging into the Hwb platform

3. Using the Hwb platform

Important notice

4. Hwb services

5. Sharing of your information

6. If you contact us

Other education stakeholder

1. Creating your unique Hwb account – what information do we collect about you?

2. Logging into the Hwb platform

3. Using the Hwb platform

Important notice

4. Hwb services

5. Sharing of your information

6. If you contact us

Part 4: additional information

Third party apps, Google apps and extensions for Chrome

Relevant Partner Privacy Notices

Events Booking Service

Appendix I

Are you a learner? Here’s a brief explanation of the Hwb Privacy Notice