The OTTO Club Evaluation: Privacy Notice

In line with the UK General Data Protection Regulation (GDPR), we want to inform you how information will be processed in the evaluation of The OTTO Club. In this privacy notice, we explain who will have access to participants’ personal data, how data will be used, stored and deleted, the legal basis for data processing, and who you can contact with a query or a complaint.

Who’s who?

This evaluation is being carried out by independent evaluator, the National Centre for Social Research (NatCen), commissioned by the Education Endowment Foundation (EEF). The funding for this project and evaluation is from the Department for Education’s Accelerator Fund, which aims to expand the use of evidence-based programmes. The OTTO Club has developed and will deliver the programme.

You can find out more about NatCen at https://natcen.ac.uk/. 
You can find out more about the EEF at https://educationendowmentfoundation.org.uk.
You can find out more about The OTTO Club at https://ottoclub.co.uk/.

The legal basis for processing data

For the duration of the evaluation, NatCen is a data controller and data processer. This means we are responsible for deciding the purpose and legal basis for processing data. The legal basis is “legitimate interest”. This means we believe that there is a genuine reason for us to process this data (to evaluate The OTTO Club), the data are needed to fulfil this purpose (we could not evaluate The OTTO Club without this information) and using the data will not interfere with individuals’ interests, rights or freedoms.

After the evaluation ends, data from the impact evaluation will be stored in the EEF archive (as detailed below). At this point, the EEF will become the data controller. You can find the EEF data archive privacy notice here.

Who will access personal data?

NatCen are carrying out this evaluation and named individuals on the NatCen research team will have access to:

  • Sample files provided by schools containing School Unique Reference Numbers (URN) and the following details for participating Year 1 pupil classes:
  1. Unique Pupil Number (UPN)
  2. First name
  3. Surname
  4. Date of birth
  5. Free School Meal (FSM) status
  6. Pupil’s class
  7. Pupil’s teacher
  • Pupil assessment data from our impact evaluation (as detailed below)
  • School and teachers’/staff members’ names and contact details, provided by The OTTO Club (the delivery team)
  • Weekly delivery logs used to record how much handwriting practice is taking place each week
  • Attendance registers that capture individual teachers’ and teaching assistants’ attendance at the online teacher training and monthly additional support sessions, provided by the delivery team
  • Teacher survey responses
  • Audio recordings from teacher and Literacy Lead interviews
  • Logs of implementation issues (collected by the delivery team)

McGowan Transcriptions (www.mcgowantranscriptions.co.uk) is the transcription service NatCen use to transcribe our interview data. They will have access to recordings and transcripts from all interviews. McGowan Transcriptions is on NatCen’s approved supplier list and is compliant with all our information security policies.

Formara Print (https://www.formara.co.uk/) is the printing company NatCen use. They will print documents containing pupil names, UPNs and dates of birth.

Experienced NatCen researchers will visit schools to conduct interviews and lesson observations. They will have access to teacher details only for the classes in which they will be conducting interviews and lesson observations.

All researchers visiting schools will have Enhanced DBS clearance. 

After the evaluation ends, impact evaluation data (e.g., student data, attendance registers, weekly delivery logs) will be shared with the EEF and their archive manager, FFT Education, for the purpose of research and archiving (see below).

How will the data be used?

The data collected will be used for research purposes only. NatCen will store and handle all data securely and confidentially in line with the UK GDPR and the Data Protection Act 2018. Data will not be transferred outside the UK.

For the impact evaluation, we will a) collect pupils’ personal data (e.g., first name, surname, date of birth), b) collect pupil assessment data, c) ask teachers to share participating pupils' writing attainment data at endline, and d) use data from attendance registers and weekly delivery logs. We will compare results of children who do and do not take part in The OTTO Club, to see whether the programme makes a difference to their handwriting accuracy and writing more broadly. All assessment and attainment data will be pseudonymised before being analysed.

The process evaluation will gather information and opinions from teacher interviews, Literacy Lead interviews, lesson observations, teacher surveys, and weekly delivery logs to understand how the programme works in practice and what children and schools think of it. Only schools selected to be Case Study schools will participate in the teacher interviews, Literacy Lead interviews and the lesson observations. All responses will be pseudonymised before being analysed. 

All impact evaluation and process evaluation data will be treated with the strictest confidence – no schools, teachers, staff members or pupils will be identified in any report arising from the research. 

NatCen will securely delete personal information about participants no more than one year after the evaluation is finished (by December 2027 at the latest). 

Impact evaluation data collected as part of all EEF evaluations are archived for research purposes and the EEF will be the data controller of the archived data. The archived data will be managed by FFT Education on behalf of the EEF, making them the data processor. At the end of the evaluation, NatCen will share with FFT Education personal identifiable information (e.g., pupil first name, surname, date of birth, FSM status, UPN, URN) alongside the impact evaluation data. 

At regular intervals, FFT Education will use these identifiers to request Pupil Matching References (PMRs) from the DfE, who will transfer them directly to the Secure Research Service (SRS) by the Office for National Statistics (ONS). FFT Education will then upload the remaining impact evaluation data to the SRS and link the PMRs. The PMR-linked impact evaluation data will then be added to the EEF archive within the SRS. Once the PMR-linked impact evaluation is archived within the SRS, the impact evaluation data held by FFT Education will be securely deleted.

PMR is an identifier that contains no personal information. It will enable potential further matching to the National Pupil Database (NPD) and other administrative datasets without accessing direct identifiers of the pupils. Once this archiving process is completed, the archive will be open to the research community for analysis within the SRS. The archived data will potentially be shared with other parties, relinked to the National Pupil Database, or linked to other datasets. For further information, see the EEF’s archive privacy notice.

Who can I contact with a query or a complaint?

You have the right to raise any concerns with the Information Commissioner’s Office (ICO) via their website at https://ico.org.uk/concerns/.

Contact information

If you have any questions about the evaluation, including how personal information will be processed, please contact the NatCen research team at ottoevaluation@natcen.ac.uk.