Exam Candidate Privacy Notice

Intuition Exam Centres is the trading name of SK Education Services Ltd.

For the purposes of applicable UK data protection legislation, SK Education Services Ltd is the Data Controller responsible for the personal information described in this Privacy Notice.

This Privacy Notice explains how Intuition Exam Centres collects, receives, uses, stores, protects and shares personal information relating to candidates who enquire about, book, enter for or sit examinations or assessments through us.

We process personal information in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and subsequent amendments to UK data protection law.

As an examination centre, we must also comply with applicable rules, regulations, procedures and administrative requirements issued by awarding organisations, examination boards, qualification regulators and the Joint Council for Qualifications (“JCQ”).

This Privacy Notice applies to candidates who:

• enquire about examinations or assessments;
• purchase or book examinations;
• make examination entries through Intuition Exam Centres;
• sit examinations or assessments at one of our venues;
• request access arrangements or reasonable adjustments;
• request special consideration;
• request post-results services;
• communicate with us regarding examination services; or
• otherwise provide personal information to us in connection with examination or assessment services.

It may also apply to information supplied to us on behalf of candidates by parents, guardians, schools, colleges, tutors, SENCos, assessors, medical professionals or other authorised persons.

This Privacy Notice forms part of the information provided to candidates when booking or purchasing examinations through Intuition Exam Centres.

By submitting an examination booking or purchasing an examination or examination-related service from Intuition Exam Centres, you confirm that you have been given the opportunity to read this Privacy Notice and acknowledge that your personal information will be processed as described in it.

Depending upon the purpose for which personal information is being processed, our lawful basis may include:

• taking steps at your request before entering into a contract;
• performance of our contract with you;
• compliance with a legal obligation;
• our legitimate interests or the legitimate interests of another organisation;
• consent or explicit consent where appropriate;
• protection of vital interests where applicable; or
• another lawful basis permitted by UK data protection legislation.

Where separate consent or explicit consent is required for a particular purpose, this will be obtained separately where appropriate.

The information we collect depends upon the examinations, assessments and services required.

We may collect and process the following categories of personal information.

4.1 Identity and Contact Information

This may include:

• full legal name;
• previous names where relevant;
• date of birth;
• gender where required for examination administration;
• postal or residential address;
• email address;
• telephone number;
• parent or guardian details where applicable;
• emergency contact details;
• signatures;
• photographic identification;
• passport, driving licence or other identification document details;
• photographs used for identification, administration or security; and
• other information reasonably required to confirm a candidate’s identity.

We may collect and process information including:

• candidate number;
• Unique Candidate Identifier (“UCI”);
• Unique Learner Number (“ULN”);
• previous examination centre details;
• previous centre number;
• previous examination entries;
• previous examination results;
• qualification information;
• awarding organisation or examination board;
• examination subjects;
• specification or syllabus details;
• examination entry codes;
• unit, component and option information;
• examination series;
• examination dates and times;
• examination timetable information;
• examination venue information;
• seating and examination room information;
• attendance records;
• absence information;
• late-arrival information;
• examination incident records;
• candidate work;
• examination scripts where applicable;
• coursework or non-examination assessment information where applicable;
• results;
• certificates;
• post-results service requests;
• access to scripts requests;
• reviews of marking;
• appeals;
• complaints;
• special consideration information; and
• information concerning suspected or confirmed examination malpractice.

We may process information relating to:

• examination fees;
• booking payments;
• invoices;
• receipts;
• transaction references;
• refunds;
• administration charges;
• late entry fees;
• awarding organisation fees;
• outstanding balances;
• disputed transactions;
• payment reversals;
• chargebacks; and
• correspondence relating to payments.

Where card payments are processed through an external payment provider, Intuition Exam Centres may not receive or retain your complete card details.

The payment provider may process your information in accordance with its own privacy terms.

Where a candidate requests an access arrangement, reasonable adjustment, modified examination paper, special consideration or other examination support, we may need to collect and process additional information.

This may include:

• medical information;
• physical or mental health information;
• medical conditions;
• disabilities;
• special educational needs and disabilities (“SEND”);
• learning difficulties;
• neurodevelopmental conditions;
• temporary illnesses or injuries;
• medication information where relevant;
• medical letters;
• medical reports;
• diagnostic reports;
• educational psychologist reports;
• specialist teacher reports;
• specialist assessor reports;
• evidence of need;
• evidence relating to a candidate’s normal way of working;
• school or college evidence;
• SENCo information;
• previous access arrangements;
• access arrangement assessment information;
• JCQ documentation;
• access arrangement applications;
• access arrangement decisions;
• reasonable adjustment information; and
• evidence supporting special consideration applications.

Where we process special category personal data, we will identify both:

1. an appropriate lawful basis under Article 6 of UK GDPR; and
2. an appropriate condition for processing special category personal data under Article 9 of UK GDPR and, where applicable, the Data Protection Act 2018.

Depending upon the circumstances, this may include the candidate’s explicit consent or another condition permitted by law.

Candidates requesting an access arrangement, reasonable adjustment or related examination support will be required to complete a separate Intuition Exam Centres Access Arrangement Application and Consent Form as part of the application process.

The separate application and consent process may require the candidate and, where appropriate, their parent or guardian to:

• provide information about the candidate’s disability, medical condition, SEND or other needs;
• provide relevant medical, educational, diagnostic or specialist evidence;
• provide evidence of need or normal way of working;
• confirm that information and evidence supplied is accurate and genuine;
• authorise Intuition Exam Centres to review and process the information for the purposes of the application;
• provide any explicit consent required for relevant special category personal data;
• acknowledge that relevant information may be shared with the appropriate awarding organisation or examination board;
• acknowledge that applications may be processed through Access Arrangements Online where applicable;
• permit appropriately authorised SENCos, assessors or other professionals to review information where reasonably necessary; and
• complete any consent or declaration required by JCQ, an awarding organisation or Intuition Exam Centres.

Where applicable JCQ or awarding organisation requirements require a signed candidate data personal consent form, this will form part of the separate access arrangement process and will be retained as required.

The candidate’s general examination booking is therefore separate from the specific access arrangement application and consent process.

Where a candidate requests an access arrangement or reasonable adjustment, relevant information may be processed by authorised individuals involved in assessing, determining, applying for and administering the arrangement.

This may include:

• the Intuition Exam Centres SENCo or equivalent responsible person;
• authorised members of our SEND or access arrangements team;
• our examinations officer;
• appropriately qualified access arrangements assessors;
• specialist assessors;
• relevant Centre managers;
• authorised examination staff;
• authorised invigilators where they need to know about an approved arrangement;
• readers;
• scribes;
• practical assistants;
• communication professionals;
• prompters;
• other authorised examination support personnel;
• the relevant awarding organisation or examination board;
• JCQ where applicable;
• authorised JCQ Centre Inspectors;
• qualification regulators where required; and
• relevant medical, educational or other professionals where appropriate and lawful.

Only information that is reasonably necessary for the relevant purpose will be accessed or shared.

Where applicable, an access arrangement application may be submitted and processed through Access Arrangements Online or another relevant awarding organisation system.

Candidates will be informed of this through the access arrangement application and consent process.

Relevant supporting information may be retained in accordance with applicable JCQ and awarding organisation requirements and may be made available to an authorised JCQ Centre Inspector or awarding organisation representative where required.

Not all personal information that we process is necessarily provided directly by the candidate.

We may receive relevant information from:

• parents or guardians;
• schools;
• colleges;
• tutors;
• tuition providers;
• previous examination centres;
• SENCos;
• access arrangements assessors;
• specialist teachers;
• educational psychologists;
• medical professionals;
• other appropriately qualified professionals;
• awarding organisations;
• examination boards;
• JCQ;
• qualification regulators;
• the Learning Records Service;
• educational or government bodies;
• payment providers; and
• other organisations legitimately involved in examination or assessment administration.

For example, an awarding organisation may provide us with information concerning:

• examination entries;
• candidate identifiers;
• examination timetables;
• access arrangements;
• examination attendance;
• examination incidents;
• examination results;
• certificates;
• post-results services;
• appeals;
• special consideration;
• malpractice investigations; and
• other examination administration matters.

We process candidate information for a number of purposes.

12.1 Examination Enquiries and Bookings

We may process information to:

• respond to enquiries;
• provide examination information;
• determine whether we can offer a requested examination;
• process examination bookings;
• administer candidate accounts;
• process payments;
• issue invoices and receipts;
• administer refunds where applicable;
• communicate with candidates;
• communicate with parents or guardians where appropriate; and
• provide examination-related customer service.

12.2 Examination Entries and Administration

We may process information to:

• verify candidate information;
• verify candidate identity;
• create and maintain candidate records;
• establish or maintain UCI and ULN information;
• register candidates with awarding organisations;
• make examination entries;
• amend examination entries;
• communicate examination dates, times and venues;
• administer examination timetables;
• manage timetable clashes;
• allocate examination rooms and seating;
• administer examinations and assessments;
• record attendance;
• manage absences and late arrivals;
• manage examination incidents;
• process candidate work;
• receive examination results;
• communicate results;
• receive and distribute certificates;
• provide post-results services;
• process reviews of marking;
• process access to scripts requests;
• administer appeals; and
• maintain appropriate examination records.

12.3 Access Arrangements and Reasonable Adjustments

We may process relevant information to:

• understand a candidate’s needs;
• assess supporting evidence;
• establish evidence of need;
• establish normal way of working where required;
• arrange assessments;
• process access arrangement applications;
• make reasonable adjustments;
• arrange examination support;
• request modified examination papers;
• arrange readers, scribes or other approved support;
• arrange separate or alternative examination accommodation where appropriate; and
• make special consideration applications where applicable.

12.4 Examination Security and Integrity

We may process information to:

• verify candidate identity;
• prevent impersonation;
• protect examination materials;
• maintain examination security;
• investigate examination incidents;
• investigate suspected malpractice;
• report suspected or confirmed malpractice;
• investigate potentially fraudulent documents;
• prevent and investigate fraud;
• support JCQ or awarding organisation inspections;
• comply with awarding organisation requirements; and
• maintain appropriate audit trails.

12.5 Protecting Intuition Exam Centres

We may process information where reasonably necessary to:

• enforce our Terms and Conditions;
• maintain appropriate business records;
• respond to complaints;
• investigate disputed payments;
• defend payment chargebacks;
• recover sums properly owed to us;
• investigate fraudulent bookings;
• establish, exercise or defend legal claims;
• obtain professional or legal advice;
• protect staff and candidates;
• protect our premises and property;
• maintain IT and information security; and
• demonstrate compliance with examination, contractual, regulatory and legal requirements.

The lawful basis used will depend upon the particular processing activity.

Contract

We may process information because processing is necessary:

• to take steps at your request before entering into a contract; or
• to perform our examination services contract with you.

This includes information necessary to accept a booking, make an examination entry, collect fees, administer an examination and provide examination-related services.

Legal Obligation

We may process information where necessary to comply with a legal obligation that applies to us.

This may include obligations relating to:

• data protection;
• equality and reasonable adjustments;
• taxation;
• accounting;
• safeguarding; and
• other applicable legislation.

Legitimate Interests

We may process personal information where necessary for our legitimate interests or those of another organisation, provided that those interests are not overridden by the rights and interests of the individual concerned.

Our legitimate interests may include:

• operating an effective examination centre;
• administering examinations and assessments efficiently;
• maintaining accurate candidate and examination records;
• complying with appropriate awarding organisation requirements;
• protecting examination integrity;
• preventing impersonation and fraud;
• maintaining IT and information security;
• resolving complaints;
• managing financial disputes and chargebacks;
• recovering legitimate debts;
• protecting candidates, staff and property;
• preventing misuse of our services; and
• establishing, exercising or defending legal claims.

Consent

We may rely upon consent where this is appropriate.

Where we rely on consent, the individual may normally withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing that took place before consent was withdrawn.

Special Category Personal Data

Where special category personal data is processed, including relevant medical, health or disability information, we will also rely upon an appropriate condition under Article 9 of UK GDPR and, where applicable, the Data Protection Act 2018.

Where explicit consent is the condition being relied upon, this will be obtained separately and appropriately recorded.

In order to provide examination and assessment services, Intuition Exam Centres must share relevant candidate information with the awarding organisation or examination board responsible for the relevant examination or qualification.

Information shared may include:

• candidate name;
• date of birth;
• gender where required;
• candidate number;
• UCI;
• ULN;
• examination entry information;
• previous examination information;
• candidate work;
• examination scripts or assessment material where applicable;
• access arrangement information;
• medical, disability or health information where required for a relevant application;
• special consideration information;
• attendance information;
• late-arrival information;
• examination incident information;
• malpractice information;
• results-related information; and
• other information reasonably required to administer, assess or award the qualification.

Candidates cannot normally require Intuition Exam Centres to withhold information that an awarding organisation reasonably requires to make or administer an examination entry or award a qualification.

Where necessary information is not provided, is materially incomplete or is inaccurate, we may be unable to:

• accept or complete an examination booking;
• make an examination entry;
• administer an examination;
• provide an access arrangement;
• obtain a modified examination paper;
• make a special consideration application;
• obtain examination results or certificates; or
• provide another examination-related service.

Any applicable examination fees, amendment fees, additional costs or refunds will be dealt with in accordance with our Terms and Conditions.

Awarding organisations and examination boards may independently process candidate personal information and may act as separate data controllers.

They have their own legal obligations and privacy notices.

Awarding organisations may retain long-term records relating to:

• examination entries;
• examination results;
• qualifications;
• candidate identifiers;
• certificates; and
• other examination information.

Awarding organisations may also be permitted or required to provide candidate information to organisations including:

• government education departments;
• qualification regulators;
• the Learning Records Service;
• UCAS;
• local authorities;
• educational agencies;
• funding organisations; and
• other authorised bodies.

Candidates should therefore also read the privacy notice issued by the relevant awarding organisation.

Intuition Exam Centres will distribute or make available relevant awarding organisation privacy notices where required.

Where examinations or assessments are subject to JCQ regulations, Intuition Exam Centres must comply with applicable JCQ requirements.

Personal information may therefore be processed or disclosed where necessary in connection with:

• examination entries;
• candidate identification;
• examination administration;
• access arrangements;
• reasonable adjustments;
• special consideration;
• Centre inspections;
• examination security;
• examination incidents;
• suspected malpractice;
• appeals;
• post-results services; and
• other applicable JCQ requirements.

Candidates must also read the applicable JCQ Information for Candidates documents, examination notices and regulations made available by Intuition Exam Centres.

Relevant JCQ Information for Candidates documents and awarding organisation privacy notices will be provided or made available before applicable examinations or assessments.

Candidate work submitted for assessment may include:

• written work;
• coursework;
• non-examination assessments;
• audio recordings;
• visual material;
• computer files;
• programs;
• data;
• examination scripts; and
• other assessment materials.

Such materials may be provided to or processed by the relevant awarding organisation for the purposes of assessment, moderation, quality assurance, awarding qualifications and other purposes explained in the awarding organisation’s own privacy notice and terms.

Where Intuition Exam Centres holds candidate assessment material on behalf of an awarding organisation, it will be handled in accordance with applicable examination requirements.

Candidates may be required to provide acceptable photographic identification or other evidence of identity.

We may:

• inspect identification documents;
• record that identification has been checked;
• record relevant identification details;
• retain appropriate evidence of identity where reasonably necessary; and
• obtain or take a candidate photograph where reasonably necessary for identification or examination administration.

Candidate photographs and identification information may be used for purposes including:

• verifying identity;
• preventing impersonation;
• protecting examination security;
• candidate administration;
• investigation of incidents;
• investigation of suspected malpractice or fraud; and
• maintaining appropriate examination records.

Identification information will only be retained for as long as reasonably necessary for the relevant examination, security, regulatory or legal purpose.

Intuition Exam Centres may from time to time take photographs or video recordings at its premises, events or activities.

Photographs or video may potentially be used for:

• the Intuition Exam Centres website;
• social media;
• brochures;
• leaflets;
• presentations;
• advertising;
• promotional videos;
• publicity materials;
• press or media activity; and
• other legitimate promotional purposes relating to Intuition Exam Centres.

Where an identifiable candidate is deliberately featured in promotional or marketing material, Intuition Exam Centres will consider the appropriate lawful basis for that use and will obtain separate permission or consent where appropriate.

A candidate will not be refused an examination booking, examination entry or access arrangement simply because they do not agree to be deliberately featured in promotional photography or video.

Where relevant promotional use is based upon consent, that consent may be withdrawn for future use by contacting:

examsofficer@intuitioncentres.com

Where appropriate and reasonably practicable, we will stop future use under our control.

However, it may not always be possible to retrieve or remove material that has already been:

• printed and distributed;
• lawfully published;
• reproduced or shared by third parties;
• incorporated into previously produced material; or
• otherwise placed beyond our reasonable control.

Intuition Exam Centres provides examination services to both adults and children.

Children have data protection rights in their own right and we take particular care when processing children’s personal information.

Where a parent or guardian books or pays for an examination on behalf of a candidate under the age of 18, we may communicate with that parent or guardian where reasonably necessary concerning:

• examination bookings;
• payments;
• examination arrangements;
• examination timetables;
• access arrangements;
• attendance;
• examination administration; and
• other legitimate matters connected with the examination service.

However, the fact that a parent or guardian has booked or paid for an examination does not automatically mean that all personal information concerning the candidate can be disclosed to that person in every circumstance.

We will take account of:

• the candidate’s age;
• their understanding and maturity;
• the nature of the information;
• confidentiality;
• safeguarding considerations;
• the circumstances of the request; and
• applicable legal requirements.

Particular care will be taken with:

• health information;
• medical information;
• disability information;
• SEND information;
• access arrangement records;
• identity documents; and
• photographs.

Candidates, parents, guardians and other individuals supplying information to Intuition Exam Centres are responsible for ensuring that information provided is accurate, complete and up to date.

This is particularly important for:

• the candidate’s legal name;
• date of birth;
• UCI;
• ULN;
• previous examination details;
• awarding organisation;
• examination specification;
• syllabus;
• examination entry codes;
• access arrangement information;
• medical information; and
• supporting evidence.

Incorrect, incomplete or late information may result in:

• an incorrect examination entry;
• delays;
• additional administration;
• additional awarding organisation charges;
• late entry charges;
• an inability to make an examination entry;
• an inability to provide an access arrangement;
• an inability to obtain a modified examination paper;
• problems with results;
• errors on examination records or certificates; or
• an inability to provide the requested service.

Where information appears inaccurate, inconsistent or potentially fraudulent, Intuition Exam Centres may request further information or documentation before processing or continuing the examination booking or application.

Where candidates provide documentation including:

• photographic identification;
• medical evidence;
• medical letters;
• diagnostic reports;
• assessor reports;
• SENCo evidence;
• access arrangement documentation;
• previous examination records; or
• other supporting evidence,

Intuition Exam Centres may take reasonable and lawful steps to verify the authenticity, accuracy and relevance of that information.

Where appropriate, this may include contacting:

• the professional who produced the evidence;
• a school or college;
• a previous examination centre;
• a SENCo;
• an assessor;
• a medical professional; or
• another relevant organisation.

Where we reasonably suspect that information or documentation is fraudulent, misleading or has been improperly altered, we may investigate the matter.

Where appropriate, relevant information may be disclosed to:

• the relevant awarding organisation;
• JCQ;
• qualification regulators;
• professional or regulatory bodies;
• law enforcement;
• our professional advisers; or
• another appropriate authority where lawful.

Where examination malpractice, attempted malpractice, impersonation or another examination irregularity is suspected, Intuition Exam Centres may collect, retain, investigate and disclose relevant information.

This may include:

• candidate details;
• examination records;
• invigilator reports;
• witness statements;
• seating plans;
• candidate communications;
• examination scripts or candidate work;
• identification information;
• photographs;
• relevant CCTV footage;
• digital information;
• evidence collected during an investigation; and
• information supplied by an awarding organisation or another examination centre.

Relevant information may be disclosed to awarding organisations, JCQ, qualification regulators, law enforcement or other appropriate bodies where required or permitted.

Where a payment is disputed or a chargeback is raised, Intuition Exam Centres may use relevant personal information to investigate and respond to the matter.

This may include:

• booking records;
• payment records;
• invoices;
• correspondence;
• examination entry records;
• attendance records;
• examination timetable information;
• evidence of services supplied;
• cancellation or refund communications; and
• other information relevant to the dispute.

This information may be provided to:

• payment processors;
• banks;
• card providers;
• chargeback services;
• professional advisers;
• debt recovery providers; or
• courts and tribunals where necessary.

This processing may be undertaken to protect our legitimate financial and legal interests and to establish, exercise or defend legal claims.

Where lawful and reasonably necessary, candidate information may also be shared with:

• awarding organisations;
• examination boards;
• JCQ;
• qualification regulators;
• government education bodies;
• the Learning Records Service;
• authorised SENCos;
• SEND personnel;
• access arrangement assessors;
• specialist assessors;
• examination officers;
• examination venue staff;
• authorised invigilators;
• readers;
• scribes;
• practical assistants;
• communication professionals;
• other authorised access arrangement personnel;
• examination venues;
• IT and cloud service providers;
• examination administration system providers;
• website providers;
• online booking providers;
• communications providers;
• payment processors;
• banks;
• accountants;
• auditors;
• insurers;
• legal advisers;
• professional advisers;
• debt recovery providers;
• fraud prevention providers;
• safeguarding authorities;
• law enforcement agencies;
• courts and tribunals; and
• other organisations where disclosure is required or permitted by law.

When you use our website or online booking systems, we may automatically collect certain technical information.

This may include:

• IP address;
• browser information;
• device information;
• operating system;
• website activity;
• pages visited;
• dates and times of access;
• security information;
• cookie identifiers; and
• information relating to online transactions.

Our website may use cookies and similar technologies to:

• provide essential website functionality;
• maintain website security;
• operate booking functions;
• maintain shopping basket functionality;
• remember user preferences;
• understand how our website is used;
• analyse website performance; and
• improve our website and services.

Where applicable law requires consent before non-essential cookies are placed or accessed, appropriate choices will be provided.

Further information may be provided in our separate Cookie Policy.

Where permitted by law, Intuition Exam Centres may contact individuals about examination services or other Intuition Exam Centres services which may be relevant to them.

Where consent is required for a particular form of electronic marketing, appropriate consent will be obtained.

You may ask us to stop sending direct marketing communications at any time by:

• using an unsubscribe facility where provided; or
• contacting examsofficer@intuitioncentres.com.

Your Right to Object to Direct Marketing

Where you object to direct marketing, we will stop using your information for that purpose.

An objection to marketing will not prevent us from sending necessary service communications relating to:

• an existing examination booking;
• examination payments;
• examination entries;
• examination timetables;
• changes to examination arrangements;
• access arrangements;
• results;
• certificates;
• post-results services; or
• another examination-related matter.

Where CCTV operates at an Intuition Exam Centres venue, appropriate signage will be displayed.

CCTV may be used for purposes including:

• candidate and staff safety;
• premises security;
• prevention and investigation of crime;
• protection of property;
• investigation of incidents;
• investigation of suspected impersonation or fraud;
• safeguarding; and
• protection of our legitimate interests.

CCTV footage will normally only be retained for an appropriate limited period unless it is required in connection with:

• an incident;
• complaint;
• safeguarding matter;
• examination investigation;
• malpractice investigation;
• insurance matter;
• criminal investigation; or
• legal claim.

We do not keep personal information for longer than is reasonably necessary for the purposes for which it was collected.

Different categories of information may be retained for different periods.

In determining appropriate retention periods, we take account of:

• JCQ requirements;
• awarding organisation requirements;
• examination administration requirements;
• access arrangement requirements;
• taxation and accounting obligations;
• applicable legal limitation periods;
• insurance requirements;
• complaints and appeals;
• safeguarding requirements;
• malpractice investigations;
• payment disputes and chargebacks;
• regulatory requirements; and
• the need to establish, exercise or defend legal claims.

Examination Administration Records

These will be retained for the period required by applicable examination regulations, awarding organisation requirements, JCQ requirements and our internal retention arrangements.

Access Arrangement and SEND Records

These will be retained for the period necessary to administer the relevant access arrangement and to comply with applicable JCQ, awarding organisation, inspection and legal requirements.

Financial and Transaction Records

These may be retained for the period necessary to comply with accounting, taxation, audit, fraud prevention and legal requirements.

Identification Information and Photographs

These will be retained only for as long as reasonably necessary for the relevant identity, examination, security, regulatory or legal purpose.

Complaints, Malpractice, Chargebacks and Legal Disputes

Relevant information may be retained until the matter is finally resolved and for an appropriate period afterwards, taking account of applicable legal limitation periods and our legitimate interests.

Marketing Photographs and Promotional Material

These may be retained while reasonably required for legitimate promotional purposes, subject to applicable data protection rights and withdrawal of consent where consent is the lawful basis.

Intuition Exam Centres takes appropriate technical and organisational measures to protect personal information against:

• unauthorised access;
• accidental loss;
• destruction;
• alteration;
• misuse; and
• unauthorised disclosure.

Measures may include:

• access controls;
• password-protected systems;
• secure online services;
• restricted access to sensitive information;
• staff confidentiality requirements;
• secure storage;
• appropriate backups;
• cybersecurity measures;
• staff training; and
• appropriate contractual arrangements with service providers.

Access to medical, disability, SEND and access arrangement information is restricted to authorised individuals who reasonably require access for their role.

No electronic or internet-based system can be guaranteed to be completely secure, but we take reasonable measures appropriate to the nature and sensitivity of the personal information we process.

Intuition Exam Centres maintains procedures for identifying, assessing and responding to personal data breaches.

Where a personal data breach occurs, we will take appropriate steps to:

• contain and investigate the incident;
• assess the potential risk to individuals;
• take reasonable measures to reduce possible harm;
• maintain appropriate records; and
• notify the Information Commissioner’s Office and/or affected individuals where required by applicable data protection law.

Some technology, cloud, communications, examination administration, payment or other service providers may process personal information outside the United Kingdom.

Where Intuition Exam Centres is responsible for a restricted international transfer, we will take appropriate steps to ensure that the transfer is made in accordance with applicable UK data protection legislation.

Depending upon the circumstances, this may include:

• transferring information to a country or territory covered by applicable UK adequacy regulations;
• using the UK International Data Transfer Agreement (“IDTA”);
• using the UK International Data Transfer Addendum (“UK Addendum”);
• using another legally recognised safeguard; or
• relying upon another transfer mechanism permitted under UK data protection law.

Where required, appropriate assessments and safeguards will be put in place.

Awarding organisations and other independent data controllers are responsible for international transfers undertaken by them.

Depending upon the circumstances and the lawful basis being relied upon, you may have rights including:

• the right to be informed about how your personal information is used;
• the right to request access to your personal information;
• the right to request correction of inaccurate personal information;
• the right to request completion of incomplete personal information;
• the right to request deletion of personal information in certain circumstances;
• the right to request restriction of processing in certain circumstances;
• the right to object to certain processing;
• the right to object to direct marketing;
• the right to data portability in certain circumstances;
• rights relating to certain forms of automated decision-making; and
• the right to withdraw consent where processing is based upon consent.

For example, Intuition Exam Centres may be unable to delete information that it is required or entitled to retain for purposes including:

• examination administration;
• awarding organisation requirements;
• JCQ requirements;
• financial and taxation obligations;
• malpractice investigations;
• safeguarding;
• complaints;
• payment disputes;
• legal claims; or
• another lawful purpose.

To exercise a data protection right, please contact:

examsofficer@intuitioncentres.com

We may request appropriate evidence of identity before responding to a request.

Requests relating to information held independently by an awarding organisation may need to be submitted directly to the relevant awarding organisation.

Where Intuition Exam Centres relies specifically upon consent or explicit consent as the lawful basis for a particular processing activity, you may normally withdraw that consent at any time.

Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.

Where consent relates to an access arrangement application, withdrawal may mean that Intuition Exam Centres is unable to submit, continue, support or administer the relevant application if the information concerned is necessary for that purpose.

Some information may continue to be retained or processed where another lawful basis applies.

Intuition Exam Centres does not ordinarily make decisions about candidates that produce legal or similarly significant effects solely through automated processing.

Examination marking, grading, qualification awards and other awarding decisions may be undertaken or controlled by the relevant awarding organisation.

Candidates should refer to the relevant awarding organisation’s privacy notice for information about how it processes candidate information.

If you believe that SK Education Services Ltd, trading as Intuition Exam Centres, has not handled your personal information correctly, you may make a data protection complaint directly to us.

Please contact:

We will acknowledge receipt of a data protection complaint within the applicable statutory period, currently 30 days.

We will take appropriate steps to investigate the complaint, make appropriate enquiries, keep you appropriately informed and communicate the outcome without undue delay.

You also have the right to raise a data protection complaint with the Information Commissioner’s Office (“ICO”), the UK’s independent data protection regulator.

We may update this Privacy Notice from time to time.

Updates may be necessary because of:

• changes in UK data protection legislation;
• changes to JCQ regulations;
• changes to awarding organisation requirements;
• regulatory guidance;
• changes to our examination services;
• changes to our systems;
• changes to service providers; or
• changes to our business operations.

The current version of this Privacy Notice will be published on the Intuition Exam Centres website.

Candidates should review the current Privacy Notice when making a new examination booking.

For questions about this Privacy Notice, our use of personal information, your data protection rights or a data protection complaint, please contact: