Why is Sparx a data processor and not a data controller?

Your school is a data controller because you collect and control the personal data used in the Sparx system.

You determine:

• Why it is collected
• What it is used for(the purpose), and
• How it is processed(the means)

Sparx is your processor (for the purposes of our data relationship) because we will process personal information on your behalf. 

Our assessment of roles is based on:

• You having a direct relationship with the data subjects, i.e. your teachers and other school staff, students and their parents, and
• That the data subjects will consider you to be using Sparx Reader as a tool to improve reading at your school

Sparx applies our expertise to use personal data in the best way to provide a high-quality bespoke learning experience for your students. The only ways we use school data to provide you with our services is listed in our Terms and Conditions > Section C: Data handling agreement > Processes undertaken. 

Whilst we determine the questions being provided to students and how student data is used (means), we never determine the purpose, which comes solely from your instruction to provide Sparx products (as noted in Terms and Conditions > Section C: Data handling agreement > School data being processed).