Hwb

Llywodraeth Cymru
Welsh Government

Hwb

Digital Learning for Wales

Cymraeg

Hwb Privacy Notice



Contents

  • Part 1: General Information
  • Part 2: Technical Information
  • Part 3: Specific Information by User Type
  • Part 4: Additional information
  • Appendix I
  • Appendix II
  • _____________________

    Part 1: General Information

    Thank you for visiting the Hwb website, which is operated by the Welsh Government (we or us). This privacy notice sets out how we collect and use personal information when you visit the website. 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 which may be accessible via the Hwb website. 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. 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 at https://ico.org.uk/your-data-matters.

    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 website, please email us at hwb@gov.wales or write to:

      Digital Learning Unit
      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 at https://hwb.gov.wales/privacy. If we make any significant changes, we will inform you of those changes.

    This privacy notice was last updated on 7th January 2019.

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    Part 2: Technical Information

    When you use the Hwb website, we will collect certain technical personal information about you, as set out below.

    If you do not log in to the Hwb website

    The website is structured so that you can visit it without either identifying yourself or revealing any personal information at all. If you choose not to log in to the website, we will not collect any personal data that specifically identifies you. However, we may still collect some information about your browsing session (as set out below).

    Information we automatically collect about you

    We automatically collect certain information whenever you visit our website. This includes technical information, such as the Internal Protocol (IP) address used to connect your computer to the internet, your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating systems and platform.

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

    Uses of your personal information

    We will use your personal information to:

    • develop, test and improve our systems;
    • ensure that the content of our websites are presented in the most effective manner for you and for your computer;
    • administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and/or
    • carry out statistical and market analyses, including benchmarking exercises, to enable us to understand you better and improve our services.
    Retention of your personal information

    Personal information that is used for the creation of a unique account will be retained for the period that your account remains active and for one year whilst the account is subsequently inactive. After this time, any personal information associated with the creation of a Hwb user account will be deleted, which includes, where relevant, their Microsoft Office 365 account and Google G Suite for Education account.

    Any personal information that is uploaded to the website or its associated services will remain for the duration of the contract between the Welsh Government and the relevant service provider, or may be removed in line with local data retention periods set by individual schools. Please contact your local school for more information.

    Cookies

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

    Our cookies collect information relating to your IP address, operating system and about your usage of our website. By continuing to browse the website, you agree to our use of cookies. When you visit our website, we use strictly necessary cookies to enable navigation and provide use of its basic features, such as maintaining your account details for the duration of the session. We also use cookies to enhance the functionality of the website by, for example, storing any preferences you enter.

    Our website uses Google Analytics, the most widely-used website statistic service. When you visit our site, Google Analytics stores a cookie on your computer or mobile device. This cookie is then used to provide us with usage data, which helps us to improve our users' experience. This means we can count how many people visit this website and analyse which pages are the most popular. In return for the service it provides, Google can access the cookie's stored analytical data. Google does not get access to specific user-identifiable data, such as your name, e-mail address or log-in details, via this website.

    You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies; go to the Help menu on the menu bar of your browser, which should provide you with a range of options in respect of cookies. However, if you select this setting you may be unable to access certain parts of the website. Unless you have adjusted your browser setting so that it will refuse cookies, Welsh Government’s system will issue cookies when you log on to the website.

    To learn more about cookies you can visit http://cookiecentral.com.


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    Part 3: Specific Information by User Type

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

    If you do choose to log in, then your information will be used differently depending on whether you are a learner, a teacher, a governor or someone else who works in the wider education sector.

    Please navigate to the relevant section using the hyperlinks below:

    A diagram of the Hwb accounts available and the access rights associated with each type of user is in Appendix I.

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    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. To learn more about personalised assessments please visit https://hwb.gov.wales/personalised-assessments. 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 resources for learners on the website, 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 give us the following personal information about you in order to create your unique Hwb account:

  • Legal first name
  • Middle name(s)
  • Legal last name
  • Preferred first name
  • Preferred last name
  • Date of birth
  • Gender
  • The name and DfES number of your school
  • Year group, National Curriculum year group, registration group, class groups and subject groups
  • School admission number
  • Enrolment status e.g. if you are a current learner in the school or if you have left the school
  • Registration status e.g. if you attend one school or more than one school
  • A code based on your unique pupil number (i.e. encrypted UPN)
  • Your school role (i.e. learner or staff)

We use a contractor, SalamanderSoft Limited, to create your account and each time you log in we will check your details through a link made available by our contractor CDSM Interactive Solutions Limited. 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.

Providing a safe and secure website 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 website

Once we have created your Hwb account, you will be able to log in to the website to access the personalised assessments. This is the minimum level of access we allow without consent from you or your parent/carer. To access our other services e.g. Microsoft Office 365 (including Word, Excel, Outlook) and Google G Suite for Education, a consent form (available from your school) must be signed by you or your parent/carer (see point 5).

Whenever you use your Hwb account, we use your personal information (via Microsoft) to identify you and allow you to use the website. 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 website remains secure. This is essential and is carried out in the public interest.

3. Using the Hwb website

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

Depending on how you use the website, 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 contractor CDSM Interactive Solutions Limited.

Please note that data protection law recognises certain "special categories" of personal information, which are 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.

IMPORTANT: We do not recommend that you upload personal information which falls within these special categories. 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 website to see.

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

Please only upload personal information that you are content to share with other users of the Hwb website, the Welsh Government and our contractors. Our use of your personal information is essential and is carried out in the public interest.

The Welsh Government has developed Information Governance Guidance for schools. This document provides schools with advice and guidance in relation to storage of information within the Hwb platform and the associated external services.

4. Personalised Assessments

As part of our commitment to improving educational standards in Wales, the Welsh Government is phasing in the use of personalised assessments for all learners in maintained schools in Wales.

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

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

Details of the data processed by our supplier is as follows: AlphaPlus Consultancy Ltd – Online Personalised Assessments (statutory service)

  • Legal first name
  • Legal last name
  • Date of birth
  • Gender
  • The name and DfES number of your school
  • Year group, National Curriculum year group, registration group, class groups and subject groups
  • School admission number
  • A code based on your unique pupil number (i.e. encrypted UPN)
  • Your school role (i.e. learner or staff)

5. Hwb Additional Services

To access our additional services a consent form (available from your school) must be signed by you or your parent/carer. Learners will then be able to access and use the following additional services:

  • The Office 365 suite of online tools, which is provided by the Microsoft Corporation, e.g. Word, Excel and Outlook (email).
  • The Google G Suite for Education suite of online tools, which is provided by Google, Inc.
  • Just2easy toolsuite, which is provided via CDSM Interactive Solutions Ltd subcontractor Just2easy.
  • Encyclopaedia Britannica

Hwb Additional Services are made available by the Welsh Government for use by schools and learners who wish to receive them, but they are operated by the contractors listed above. 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 our contractors Microsoft Corporation, Google, Inc. and/or Just2easy.

As Hwb Additional 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 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.

We will only provide you with access to these additional services with your consent or the consent of your parent/carer. Your school will manage who has and who has not given their consent, and will provide access accordingly.

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

CDSM Interactive Solutions Ltd – Hwb platform
  • Legal first name
  • Legal last name
  • Hwb username
  • Hwb email
  • School DfES number and school name
  • Permission status (consent obtained or not)
Just2easy – J2e Tool suite
  • Legal first name
  • Legal last name
  • Hwb username
  • School DfES number
Microsoft Corporation – Office 365
  • Legal first name
  • Legal last name
  • Display name
  • Hwb username
  • Hwb email
  • Role
  • Registration groups
  • School DfES number
Google – G Suite for Education
  • Legal first name
  • Legal last name
  • Hwb username
  • Hwb email
  • School DfES number and school Name
  • Class Groups
6. 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 in order 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 II.

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Teacher

All teachers in maintained schools in Wales are provided with a Hwb account. 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.

In order to access all of the digital tools and resources on the website that are available to teachers and learners, you will need to log in.

For teachers, 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 give us the following personal information about you in order to create your unique Hwb account:

  • Legal first name
  • Middle name(s)
  • Legal last name
  • Preferred first name
  • Preferred last name
  • Title
  • School staff code
  • Staff member ID
  • The name and DfES number of your school
  • Year, registration and class groups
  • Role (i.e. learner or staff and teacher or non-teacher)

We use a contractor, SalamanderSoft Limited, to create your account and each time you decide to log in we will check your details through a link made available by our contractor CDSM Interactive Solutions Limited. 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 Welsh Government has a legal obligation to provide a unique and secure Hwb account for all teachers and learners in Wales, which can be used to access the personalised assessments (please see Section 4 below).

Providing a safe and secure website for use by teachers and learners 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 website

Once we have created your Hwb account, you will be able to log into the website and access the areas that are specifically made available to teachers. It is up to you and your school as to whether or not you wish to log into the website, however, you will need to log in to the website to access personalised assessments (please see Section 4 below).

When you first log in to the website, you will be shown our End User Licence Agreement (Important Notice). This provides links to the Hwb Terms & Conditions that will govern your use of the website and this Hwb Privacy Notice. You will be required to click to confirm that you accept the Terms & Conditions. If the Terms & Conditions and/or Privacy Notice change, you will be required to re-accept the End User Licence Agreement.

Whenever you use your Hwb account, we use your personal information (via Microsoft) to identify you and allow you to fully use the website. We keep a record of every time you log in for audit purposes and that record is retained for one year.

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

3. Using the Hwb website

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

Depending on how you use the website, 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 contractor CDSM Interactive Solutions Limited.

Please note that data protection law recognises certain "special categories" of personal information, which are 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.

IMPORTANT: We do not recommend that you upload personal information which falls within these special categories. 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 website to see.

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

Please only upload personal information that you are content to share with other users of the Hwb website, the Welsh Government and our contractors. Our use of your personal information is essential and is carried out in the public interest.

4. Personalised Assessments

As part of our commitment to improving educational standards in Wales, the Welsh Government is phasing in the use of personalised assessments for all learners in maintained schools in Wales.

The Welsh Government has a legal obligation to provide assessment arrangements for reading and numeracy for learners in Wales. The personalised assessments are provided by our contractor, AlphaPlus, and will be taken by learners via the Hwb website. Information derived from the assessments of individual learners, and information available for collation at a group/class, year and school level, can be seen by members of staff who have been given relevant access. The level of teacher access is determined by the school’s headteacher.

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


AlphaPlus – Online Personalised Assessments (statutory service)

  • First name
  • Last name
  • Hwb username
  • Hwb email
  • School DfES Number and school name
  • Year, National Curriculum Year, Registration, Class and Subject groups
  • Role
5. Hwb Additional Services

The website automatically enables you to access and use the following additional services:

  • The Office 365 suite of online tools, which is provided by the Microsoft Corporation, e.g. Word, Excel and Outlook (email).
  • The Google G Suite for Education suite of online tools, which is provided by Google, Inc.
  • Just2easy toolsuite, which is provided via CDSM Interactive Solutions Ltd subcontractor Just2easy.
  • Encyclopaedia Britannica

Hwb Additional Services are made available by the Welsh Government for use by users of the website, but they are operated by the contractors listed above. 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 our contractors Microsoft Corporation, Google, Inc. and/or Just2easy.

As Hwb Additional 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 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.

The Welsh Government believes that making available the Hwb Additional Services listed above to teachers 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 Additional 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 is as follows:


CDSM Interactive Solutions Ltd – Hwb platform
  • Legal first name
  • Legal last name
  • Hwb username
  • Hwb email
  • School DfES number and school name
Just2easy – J2e Tool suite
  • Legal first name
  • Legal last name
  • Hwb username
  • School DfES number and school name
Microsoft Corporation – Office 365
  • Legal first name
  • Legal last name
  • Display name
  • Hwb username
  • Hwb email
  • Role
  • Registration groups
  • School DfES number and school name
  • Local authority
Google – G Suite for Education
  • Legal first name
  • Legal last name
  • Hwb username
  • Hwb email
  • School DfES number school name
  • Class Groups
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.

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Governor

Governors for maintained schools in Wales may be provided with a Hwb account. These accounts are allocated and maintained directly by each school. If you want to access all of the digital tools and resources on the website 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 will provide us with the following personal information about you in order to create your unique Hwb account:

  • First name
  • Last name
  • Your role
  • Name of school

We use a contractor, SalamanderSoft Limited, to create your account. Each time you log in we will check your details through a link made available by our contractor CDSM Interactive Solutions Limited. 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 website 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 necessary for the performance of this task and is carried out in the public interest.

2. Logging into the Hwb website

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

When you first log in to the website, you will be shown our End User Licence Agreement (Important Notice). This provides links to the Hwb Terms & Conditions that will govern your use of the website and this Hwb Privacy Notice. You will be required to click to confirm that you accept the Terms & Conditions. If the Terms & Conditions and/or Privacy Notice change, you will be required to re-accept the End User Licence Agreement.

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

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

3. Using the Hwb website

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

Depending on how you use the website, 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 contractor CDSM Interactive Solutions Limited.

Please note that data protection law recognises certain "special categories" of personal information, which are 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.

IMPORTANT: We do not recommend that you upload personal information which falls within these special categories. 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 website to see.

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

Please only upload personal information that you are content to share with other users of the Hwb website, the Welsh Government and our contractors. Our use of your personal information is essential and is carried out in the public interest.

4. Hwb Additional Services

The website automatically enables you to access and use the following additional services:

  • The Office 365 suite of online tools, which is provided by the Microsoft Corporation, e.g. Word, Excel and Outlook (email).
  • Encyclopaedia Britannica

Hwb Additional Services are made available by the Welsh Government for use by users of the website, but they are operated by the contractors listed above. 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 our contractors Microsoft Corporation.

As Hwb Additional 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 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.

The Welsh Government believes that making available the Hwb Additional 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 Additional 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 is as follows:


CDSM Interactive Solutions Ltd – Hwb platform
  • First name
  • Last name
  • Hwb username
  • Hwb email
  • School DfES number and school name
  • Role (ie Governor)
Microsoft Corporation – Office 365
  • First name
  • Last name
  • Hwb username
  • Hwb email
  • School DfES number and school name
  • Role (ie Governor)
5. 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.

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Other Education Stakeholders

As well as learners, teachers and governors, the Welsh Government can provide a Hwb account to other non-school users. These accounts are allocated and maintained by the Welsh Government. If you want to access all of the digital tools and resources on the website, you will need to log in.

For non-school users, 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?

You will provide us with the following personal information about you in order to create your unique Hwb account:

  • First name
  • Last name
  • Your role
  • Name of organisation

We use a contractor, SalamanderSoft Limited, to create your account. Each time you log in we will check your details through a link made available by our contractor CDSM Interactive Solutions Limited. 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 website 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 individuals is necessary for the performance of this task and is carried out in the public interest.

2. Logging into the Hwb website

Once we have created your Hwb account, you will be able to log into the website and access the areas that are specifically made available to non-school users. It is entirely up to you whether or not you wish to log into the website.

When you first log in to the website, you will be shown our End User Licence Agreement (Important Notice). This provides links to the Hwb Terms & Conditions that will govern your use of the website and this Hwb Privacy Notice. You will be required to click to confirm that you accept the Terms & Conditions. If the Terms & Conditions and/or Privacy Notice change, you will be required to re-accept the End User Licence Agreement.

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

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

3. Using the Hwb website

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

Depending on how you use the website, 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 contractor CDSM Interactive Solutions Limited.

Please note that data protection law recognises certain "special categories" of personal information, which are 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.

IMPORTANT: We do not recommend that you upload personal information which falls within these special categories. 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 website to see.

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

Please only upload personal information that you are content to share with other users of the Hwb website, the Welsh Government and our contractors. Our use of your personal information is essential and is carried out in the public interest.

4. Hwb Additional Services

The website may enable you to access and use the following additional services:

  • The Office 365 suite of online tools, which is provided by the Microsoft Corporation, e.g. Word, Excel and Outlook (email).

Hwb Additional Services are made available by the Welsh Government for use by users of the website, but they are operated by the contractors listed above. 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 our contractors Microsoft Corporation.

As Hwb Additional 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 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.

The Welsh Government believes that making available the Hwb Additional Services listed above to those involved in education 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 Additional 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 is as follows:


CDSM Interactive Solutions Ltd – Hwb platform
  • First name
  • Last name
  • Hwb username
  • Hwb email
  • School DfES number and school name
  • Role (ie Governor)
Microsoft Corporation – Office 365
  • First name
  • Last name
  • Hwb username
  • Hwb email
  • School DfES number and school name
  • Role (ie Governor)
5. 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.

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Part 4: Additional information

Third Party Apps

If you chose to use your Hwb account to access Third Party apps, we accept no responsibility for their use. It is your responsibility to read and accept the Terms and Conditions and Privacy Notices of each Third Party app that you chose to use.

Events Booking Service

The website provides a booking service for events created and managed by either the Welsh Government or another organisation (for example South West Grid for Learning, Regional Arts Networks or IntoFilm Cymru). This booking service is operated on our behalf by CDSM Interactive Solutions Limited and SmartSurvey 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 in order for them to manage your registration. The event organiser will be responsible for handling your information in accordance with data protection requirements.]

Seren Network

The Welsh Government is the controller for the Seren Network. More information about the Seren Network can be found at https://beta.gov.wales/seren-network.

Information about all members of the Seren Network will be included on a database, which will be made available to all of the hubs within the Seren Network. Each hub is made up of schools, local authorities, further education colleges and regional education consortia.

The Seren Network database is managed by our contractors, CDSM Interactive Solutions Limited. Your information will also be accessible by Future First Alumni Limited, which provides expert support to Welsh Government and the hubs. More information about Future First can be found at http://futurefirst.org.uk/.

We will not disclose your information to any other third party unless we are required to do so in accordance with the 'Disclosure' section of this privacy notice.

Your information will be used for the purpose of inviting you to events, sending you details of how you can get involved, and keeping you up to date with the activities of the Seren Network.

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Appendix I

Hwb accounts and access associated with each type of user

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Appendix II

Are you a learner? Here’s a brief explanation of the Hwb Privacy Notice
  • Our Privacy Notice tells you how we use personal information about you and other users of the Hwb website.
  • 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 your personal information with the Welsh Government so that we can give you a Hwb account.
  • The Welsh Government is committed to keeping your personal information safe and secure.
  • Every learner and teacher in schools in Wales has a Hwb account. You can use it to access educational resources, as well as tests called Online Personalised Assessments which you may need to sit. These test your numeracy and literacy skills.
  • Your teachers will tell you when to use your Hwb account to sit the tests. The Welsh Government will use your personal information to let you log-in to take an assessment securely.
  • The Hwb website also allows you to log in to other educational services (for example, Microsoft Word, Excel, Outlook (email) or Google G Suite for Education). You will only be able to access these services if either you or your parent or carer agrees. The Welsh Government will then securely share some of your personal information with our suppliers so that you can use their services. Your school will give you or your parents or your carer a consent form which will need to be completed.
  • The Welsh Government will keep your personal information while your Hwb account is active and for one year once 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 at https://ico.org.uk/your-data-matters has everything you need to know.

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