PRIVACY POLICY
Last updated: 01/06/2026
Introduction
This Privacy Policy is provided by Greg Sly trading as Propulsion Tutoring ("we," "us," or "our") and explains how we collect, use, share, and protect personal information/data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are committed to safeguarding the privacy and security of all personal information provided to us. We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you.
Who We Are (Data Controller)
Greg Sly is the data controller responsible for your personal information. This means we are legally responsible for deciding how and why your personal data is processed.
Contact Details:
Name: Greg Sly
Address: 49 Station Road, Polegate, East Sussex, BN26 6EA, UK
Email: gregsly@propulsiontutoring.com
Telephone: +447543803851
If you have any questions about how we use your personal data, please contact us using the details above.
What this Policy applies to
This policy applies to students, parents, legal guardians, and anyone who uses our tutoring services (“you”, “your”). This privacy policy relates to your use of the tutoring services only.
The tutoring services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information, see the section ‘Who we share your information with’ below.
Processing Children's Personal Data
We primarily provide tutoring services to children and young people aged 14-18 (GCSE, IGCSE, & A-Level students). We recognise that children deserve special protection when it comes to their personal information.
When processing children's data, we:
Communicate privacy information in clear, age-appropriate language
Obtain consent from parents or guardians where required by law
Collect only the minimum data necessary to provide effective tutoring
Implement enhanced security measures to protect children's information
Conduct Data Protection Impact Assessments (DPIAs) for high-risk processing, where required
Allow parents and guardians to exercise data protection rights on behalf of their children
What Information We Collect
We collect and process the following types of personal information:
Student Information:
Name, age, and school year
Contact details (email, phone number, address)
Academic performance and progress records
Information about learning needs, strengths, and areas for improvement
Attendance and session notes
Parent/Guardian Information:
Name and contact details (email, phone number, address)
Payment and billing information
Communication records and correspondence
Special Category Data (Sensitive Information):
In order to provide appropriate tutoring support tailored to individual needs, we may process information about:
Learning difficulties or disabilities (e.g., dyslexia, ADHD, autism spectrum conditions)
Relevant medical conditions that may affect learning (e.g., anxiety, attention difficulties)
We only collect this information when it is necessary to provide effective tutoring services, and we handle it with extra care and security. If you do not provide personal data we ask for where it is required, it may prevent us from providing the tutoring services to you. We collect and use this personal data for the purposes described in the section ‘How we use your information’ below.
Legal Basis for Processing Your Data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party (A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us).
We process personal data based on the following legal grounds:
Performance of a Contract: We need to process your information to deliver tutoring services as agreed in our tutoring contract.
Legitimate Interests: We process data for our legitimate business interests, such as maintaining accurate records, managing payments, and improving our services. We always balance these interests against your rights and freedoms.
Consent: For processing special category data (such as information about learning disabilities or health conditions), we rely on your explicit consent. You can withdraw this consent at any time.
Legal Obligations: We process data to comply with legal requirements, including tax obligations, safeguarding duties, and record-keeping requirements.
How We Use Your Information
We use your personal information for the following purposes:
To provide tutoring services and fulfil our contractual obligations
To communicate with students, parents and guardians about Sessions, scheduling, progress, and feedback
To monitor student progress and tailor lessons to individual learning needs
To process payments and maintain financial records
To comply with legal and regulatory requirements, including HMRC tax obligations and safeguarding duties
To improve our tutoring services and teaching methods
To maintain records for safeguarding and quality assurance purposes
To record online tutoring sessions for safeguarding, quality assurance, and training purposes (with your consent)
Who We Share Your Information With
We do not sell or rent your personal information to third parties. We may share your information only in the following limited circumstances:
Third-Party Service Providers:
We may use carefully selected third-party services to help us deliver tutoring services, such as:
Payment processors (e.g., Stripe, PayPal or HSBC) to process tuition fees
Video conferencing platforms (e.g., Zoom, Microsoft Teams) for online tutoring sessions
Cloud storage providers for secure storage of lesson materials and progress notes
All third-party providers are selected based on their GDPR compliance and security standards.
Legal Authorities:
We may disclose information to regulatory authorities, law enforcement, or safeguarding bodies where we are legally required to do so, or where necessary to protect the welfare of a child.
With Your Consent:
We will share information with schools or other educational professionals only with your explicit written consent.
Transferring your personal data out of the UK
At this point in time, we do not transfer your personal data outside of the UK. We comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, where we transfer your personal data from the UK to:
The EEA: we rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we rely on the adequacy regulation granted to the UK under the Adequacy Decision.
Any country located outside the UK/EEA: we rely on appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Data Retention (How Long We Keep Your Information)
We retain personal information only for as long as necessary for the purposes it was collected:
Contact details, correspondence, and financial records: 6 years after the last tutoring session (required by HMRC for tax purposes)
Student academic records, progress notes, and lesson materials: 12 months after the final tutoring Session
Session recordings (for safeguarding): 12 months after the final tutoring Session, then securely deleted
DBS check verification: Not retained; we verify and note the date and certificate number only
Special category data (health/learning needs information): Retained for 12 months after the final Session, then securely delete.
After these periods, we securely delete or anonymise your information so it can no longer identify you.
Your Data Protection Rights
Under UK GDPR, you have the following rights regarding your personal data:
Right of Access: You can request a copy of the personal data we hold about you and information about how we use it.
Right to Rectification: You can ask us to correct inaccurate or incomplete personal data.
Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal data in certain circumstances, such as when it is no longer necessary for the purposes it was collected.
Right to Restriction of Processing: You can ask us to restrict how we use your personal data in certain situations.
Right to Data Portability: You can request to receive your personal data in a structured, commonly-used format and transfer it to another organisation.
Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes.
Right to Withdraw Consent: If we are processing your data based on consent (such as special category data), you can withdraw that consent at any time.
Not to be subject to decisions without human involvement: You can request safeguards for individuals against the risk that a potentially damaging decision is taken by solely automated means, i.e. without human intervention.
To Exercise Your Rights:
To exercise any of these rights, please contact us by email at gregsly@propulsiontutoring.com or call +447543803851. We will respond to your request within one month.
Withdrawing Consent:
If you wish to withdraw consent for processing special category data (such as information about learning needs), please email us at gregsly@propulsiontutoring.com. Please note that withdrawing consent may affect our ability to provide tailored tutoring support, as we need certain information to address individual learning needs effectively.
Data Security
We take the security of your personal information seriously and implement appropriate technical and organisational measures to protect it, including:
Secure password protection and access controls
Encryption of sensitive data
Two-factor authentication where available
Regular security assessments and updates
Secure storage systems with restricted access
Staff training on data protection responsibilities
Special Protection for Sensitive Data:
Information about children and special category data (such as health or learning needs information) receives additional safeguards:
We review where sensitive data is stored every three months
Access to sensitive data is strictly controlled and limited to what is necessary for tutoring purposes
We maintain robust procedures governing who can access this data and how it can be used
Data Breach Procedures:
In the unlikely event of a data breach, we will:
Immediately assess and mitigate the extent of the breach
Identify what data has been or may have been compromised
Inform affected individuals promptly in clear, jargon-free language
Take necessary measures to prevent compromised data being misused (such as recommending password changes)
Keep you informed of any changes to the level of risk
While we implement strong security measures, please note that no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
Recording of Online Sessions
All online tutoring sessions may be recorded for safeguarding, quality assurance, and training purposes. Recordings help protect both students and tutors.
Recordings are stored securely in accordance with UK GDPR requirements
Recordings are retained for 12 months after the final tutoring Session and then securely deleted
Recordings are never shared or distributed externally
If you prefer, you may participate with audio only (camera off) while video recording continues for safeguarding purposes
By agreeing to our tutoring contract, you consent to the recording and storage of sessions in accordance with these terms. If you have concerns about recording, please discuss this with us before commencing tutoring.
Cookies
What are cookies?
Cookies are small text files that are placed on your device when you visit a website. They help the site remember your device and how you have used the site, which can make your experience smoother and more relevant.
How we use cookies
Propulsion Tutoring uses cookies and similar technologies to:
Help the website function properly (for example, to enable security features and basic navigation).
Understand how visitors use the site so we can improve our content and services (for example, which pages are visited and how long people spend on them).
Support our booking, payment, and contact processes, where relevant.
We do not use cookies to sell your personal data to third parties.
Types of cookies we use
Strictly necessary cookies
These cookies are essential for the website to work and cannot be switched off in our systems. They are usually set in response to actions you take, such as filling in forms, logging in, or navigating between pages. You can set your browser to block or alert you about these cookies, but parts of the site may not work properly if you do.Performance and analytics cookies
These cookies help us understand how visitors use our site (for example, which pages are most popular). The information they collect is aggregated and does not directly identify you. We use this data to improve how our website works and to make it more helpful for students and parents.Functional cookies
These cookies allow the website to remember choices you make (such as your preferences) to provide enhanced, more personal features. If you disable these cookies, some features may not work as intended.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any changes will be communicated to you directly via email.
The updated policy will show the "Last updated" date at the top of this document. We encourage you to review this policy periodically.
How to Complain
If you have concerns about how we handle your personal data and are not satisfied with our response, you have the right to complain to the Information Commissioner's Office (ICO):
Website:www.ico.org.uk
Helpline: 0303 123 1113
Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Contact Us
If you have any questions about this Privacy Policy, how we use your personal data, or wish to exercise your data protection rights, please contact us:
Greg Sly
Address: 49 Station Road, Polegate, East Sussex, BN26 6EA, UK
Telephone: +447543803851