Privacy Notice for using PebblePad
This privacy notice provides information about how your personal data is used when you use PebblePad and ATLAS.
Where we refer to PebblePad below, this should be understood to include PebblePad and ATLAS .
Information about you: how we use it and with whom we share it
The information you provide will be used by the University to provide a digital portfolio service to its staff and students. This service allows users to create, compile and present a purposeful collection of information and digitised artefacts that can demonstrate progress towards or achievement of learning outcomes, skills or competencies. PebblePad may also be used for preparing and submitting your assessments, and your work can be transferred from PebblePad to the Turnitin similarity detection and grading services.
The University uses an external company, Pebble Learning LTD, to provide the service on the University’s behalf.
The University holds information about everyone who is eligible to use the PebblePad Service at the University. This information is used to identify your level of access to the system, allow you to upload artefacts and assessments, report on your usage of the system, provide you with support, maintain our IT system, gather feedback, and for strategic planning purposes.
The University is processing your data on the basis of its legitimate interests in supporting its teaching, learning and academic engagement activities, or on the basis of contract in cases where your work is submitted and assessed through PebblePad in order to allow you to complete a course.
Sharing information
Information about you will be shared with Pebble Learning LTD and its sub-processors to facilitate the service. PebblePad’s sub-processors include Amazon Web Services (hosting), Rocket Science Group LLC (email notifications), Brightcove Inc (audio/video conversion) and Google (off-site back up).
A full list of processors is available on the PebblePad website [PDF].
We may sometimes need to contact Pebble Learning LTD through their helpdesk about specific problems you raise with us. Their support functions are provided by staff in the UK but use an incident management system where data are stored in the USA. When using PebblePad support we will endeavour only to share the minimum data we need to in order to get the issue fixed.
Currently, the data we store about you in PebblePad is deleted 18 months after an account is no longer active except assessment submissions (to Atlas) which are currently kept in perpetuity. This is an issue that we are working on addressing.
When students finish studying with us they have the option to transfer their PebblePad account to a personal Pebble+ account, for which Pebble Learning LTD is the data controller. There is more information about how to do this under ‘Access post-graduation' on the PebblePad Access page.
Transfers outside the United Kingdom
Use of PebblePad will include the routine transfer of personal data to data centres based in the UK or EEA.
Support calls may require the transfer of a limited set of your personal data to the USA. Where staff or student personal data are held in the USA, there is a possibility that Pebble Learning LTD may be required to disclose these to regulatory authorities in that country without your or your students' consent and without giving you any right to object to this disclosure.
Automated decision making
We do not use profiling or automated decision-making processes. Some processes are semi-automated (such as anti-fraud data matching) but a human decision maker will always be involved before any decision is reached in relation to you.