Data Processing Agreement

Last updated: September 2026

Summary: This agreement sets out how Sear Education handles personal data on your organisation's behalf when you use Mr Sear's Spelling. Your organisation remains in control of the data at all times. By using the Service, your organisation agrees to the terms of this Data Processing Agreement.


1. Parties

Data Controller ("the Organisation"): The school, tutoring practice, home educator, or other educational organisation or individual using the Service.

Data Processor ("we", "us", "Sear Education"): Daniel Sear trading as Sear Education, the operator of Mr Sear's Spelling and its sister product Mr Sear's MTC.


2. Scope and Purpose

This Data Processing Agreement ("DPA") applies to personal data processed by Sear Education on behalf of the Organisation through the Mr Sear's Spelling service ("the Service"). It supplements our Terms of Service and Privacy Policy.

The purpose of processing is to provide an online live spelling test tool for educational use.

The Service shares one account and pupil system with Mr Sear's MTC. Schools, classes, teachers, pupils, class logins and pupil PINs are the same records in both products. Learning information is kept separate: Spelling does not read or change MTC's maths results.


3. Data Processed

Pupil data:

Data typePurpose
First names only (no surnames)Identifying pupils within their class
Individual PIN codes (held in a teacher-only store, never on the pupil record)Secure login to the pupil's account
Display alias (e.g., "Star", "Moon")A friendly generic username, shared with Mr Sear's MTC
Seat position on the class seating planShowing each pupil in their place on the teacher's seating plan
Absent or present mark for the dayClassroom management
Display preferences (dyslexia-friendly font, larger text, higher contrast)Accessibility. Saved so the child's chosen settings stay on for them
Seat designs (a background colour and stickers from a fixed set)Personalisation. No uploads or free text; seen only within the child's own class
In-app rewards (tokens) and the sticker packs and colour sets bought with themMotivation; earned by taking part, also awarded by teachers
Spelling session information (words sent in the current test, each pupil's status, what the pupil typed for the current word, whether it was right, when they started typing, whether their screen is connected)Running the live spelling test. Cleared when the teacher ends or resets the test
Pupil group flags (optional): pupil premium, SEND, EALSet by the school's own teachers, never shown to pupils. Only group membership is held, no further detail.

Special category data: Where a school records SEND status, this may count as special category data under UK GDPR. The Organisation (the school) determines the lawful basis and condition for processing it. Sear Education processes it only on the Organisation's instructions, holds only group membership, and never exposes it to pupils.

Teacher/staff data:

Data typePurpose
Email addressAccount login and invitations
Display nameIdentification within the Service
Class and school membershipShowing each teacher the right classes

Teachers use one shared account across Mr Sear's Spelling and Mr Sear's MTC. The security records kept for that shared account are described in Mr Sear's MTC's privacy policy.

Categories of data subjects: Pupils (typically aged 5-11) and their teachers/staff.


4. Our Obligations as Data Processor

Sear Education shall:

  1. Process data only on the Organisation's instructions - We will only process personal data for the purposes described in this agreement and as necessary to provide the Service. We will not use the data for any other purpose.
  2. Ensure confidentiality - Only authorised Sear Education personnel have access to personal data, and only where necessary for operating or supporting the Service.
  3. Implement appropriate security measures - We use industry-standard security measures including:
    • Encrypted data transmission (HTTPS/TLS)
    • Secure cloud infrastructure (Google Firebase)
    • Individual pupil PIN codes for access control, kept in a teacher-only store
    • Pupil screens that show only the child's own name
    • Role-based access controls (teachers see their own classes; school leads see the classes in their school)
    • No scripts or fonts loaded from outside services while the Service is in use
  4. Not engage sub-processors without authorisation - We use Google Firebase services for data storage and processing (see Section 6). We will inform the Organisation of any changes to sub-processors.
  5. Assist the Organisation with data subject requests - We will help the Organisation respond to requests from individuals exercising their rights under UK GDPR (access, rectification, erasure, etc.).
  6. Notify the Organisation of data breaches - In the event of a personal data breach, we will notify the Organisation without undue delay (and in any event within 72 hours of becoming aware).
  7. Delete or return data on termination - When the Organisation stops using the Service, we will delete all personal data in accordance with our data retention schedule (see Section 8).

5. The Organisation's Obligations as Data Controller

The Organisation shall:

  1. Ensure there is a lawful basis for processing pupil data through the Service (typically "public task" under UK GDPR Article 6(1)(e) for schools, or "legitimate interests" under Article 6(1)(f) for tutors and other educational settings)
  2. Where applicable, inform parents/carers about the use of the Service (e.g., through the school's privacy notice or by other appropriate means)
  3. Ensure that only appropriate data is entered into the Service (first names only, no surnames or sensitive data)
  4. Keep class logins and pupil PINs confidential and only share them with authorised users
  5. Notify Sear Education promptly if a teacher leaves or should have their access revoked

6. Sub-processors

We use the following sub-processors to provide the Service:

Sub-processorPurposeLocation
Google Firebase FirestoreMain databaseLondon, UK
Google Firebase Realtime DatabaseChecking the connection is liveBelgium, EU
Google Firebase AuthenticationTeacher and pupil sign-inMay involve processing outside UK/EU with appropriate safeguards
Google Firebase HostingServing the websiteGoogle's hosting network
Google Cloud FunctionsChecking class logins and PINs, signing devices outMay involve processing outside UK/EU with appropriate safeguards
Zoho MailSending invitation emails to teachers, through the shared account systemTeacher email addresses only

7. International Transfers

The primary storage of pupil data is in the UK and EU (London and Belgium). Some processing may occur outside the UK/EU through Google's infrastructure. Where this happens, appropriate safeguards are in place.


8. Data Retention and Deletion

Retention periods:

Data typeRetention period
Spelling session informationCleared when the teacher ends or resets the test. No long-term history of spelling results is kept on the Service's servers
Downloaded test results (Excel file)Saved to the teacher's own computer, not kept by the Service
Pupil names and other shared pupil detailsDuration of school's active subscription
Teacher accountsUntil deleted by organisation lead or account holder

Soft deletion (30-day recovery period):

Schools, classes and pupils are shared with Mr Sear's MTC, so these steps apply to the shared records in both products. When an organisation lead deletes a class through the Service:

Teacher account deletion:

When an organisation lead removes a teacher, the teacher's account and access are deleted immediately and permanently.

On termination:

When an organisation's subscription ends or is not renewed, the school account is deleted by the service administrator. The school and all its classes are immediately hidden from view. Teachers are unassigned from the school but their accounts are retained. All associated data (classes and pupils) is retained securely for 30 days to allow recovery in case of error, after which it is permanently and irreversibly deleted by an automated process.


9. Data Breach Notification

In the event of a personal data breach affecting the Organisation's data:

  1. We will notify the Organisation's designated contact without undue delay and within 72 hours of becoming aware of the breach
  2. We will provide details of the nature of the breach, the categories and approximate number of data subjects affected, the likely consequences, and the measures taken to address it
  3. We will cooperate with the Organisation and the ICO (Information Commissioner's Office) as needed

10. Audit and Compliance

We will:


11. Duration and Termination

This DPA applies for as long as the Organisation uses the Service. It will automatically terminate when:

Sections relating to data deletion, confidentiality, and breach notification survive termination.


12. Governing Law

This DPA is governed by the laws of England and Wales and is subject to the jurisdiction of the courts of England and Wales.


13. Contact

For any questions about this Data Processing Agreement or to report a data concern:

Sear Education
Email: info@mrsearmtc.uk

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