Data processing agreement
Version 1.0 · Last updated: 3 August 2026
These terms form our Article 28 agreement with a school. A school does not need to sign a separate contract or negotiate: using ClassMind on behalf of your school means these terms apply.
1. Parties, roles and scope
In these terms, "we", "us" and "ClassMind" mean Revamp Automation of Corsham, Wiltshire, United Kingdom. "You" and "the School" mean the educational institution on whose behalf a member of staff uses ClassMind.
Where a teacher enters pupil-related data into ClassMind in the course of their employment, the School is the controller and we are the processor. These terms govern that processing.
We are a controller in our own right for the teacher's account data (name, work email, password, subscription and sign-in records). That processing is governed by our Privacy Policy, not by these terms.
"UK GDPR", "personal data", "processing", "controller", "processor", "data subject" and "personal data breach" have the meanings given in the UK GDPR and the Data Protection Act 2018.
2. Subject matter, duration, nature and purpose
| Item | Detail |
|---|---|
| Subject matter | Provision of an AI-assisted teaching resource authoring service |
| Duration | For as long as a member of the School's staff holds an active ClassMind account, plus the deletion periods in section 8 |
| Nature and purpose | Storing teacher-entered class and pupil records, and generating teaching resources from them via an AI provider |
| Types of personal data | Anonymous pupil codes chosen by the teacher; free-text attainment, progress and support notes; class context such as year group and class size; content of resources generated about a pupil |
| Categories of data subject | Pupils at the School. Indirectly, teaching staff named in resources |
| Special category data | Not requested and not intended. See section 10 |
3. Our obligations
We will:
- Process only on documented instructions. We process School personal data only to provide the service, on the instructions given through use of the product and these terms, unless required otherwise by law — in which case we will tell you first, unless the law prohibits it.
- Ensure confidentiality. Everyone we authorise to process School personal data is bound by a duty of confidentiality.
- Apply appropriate security under Article 32, as set out in section 6 and on our Data protection information page.
- Engage sub-processors only on the terms in section 4.
- Assist you with data subject rights, taking into account the nature of the processing, as set out in section 7.
- Assist you with Articles 32 to 36 — security, breach notification, impact assessments and prior consultation — taking into account the information available to us.
- Delete or return School personal data at the end of the service, as set out in section 8.
- Make available the information needed to demonstrate compliance with Article 28, and allow for audits as set out in section 9.
- Tell you if an instruction appears to infringe the UK GDPR or other data protection law.
4. Sub-processors
You give general written authorisation for us to engage sub-processors. The current list is published and maintained on our Data protection information page.
We will give at least 30 days' notice on that page before adding or replacing a sub-processor. If you object on reasonable data protection grounds within that period, tell us at privacy@classmind.co.uk and we will work with you to find a resolution. If none is available, you may stop using the service and we will delete the School's personal data under section 8.
We impose data protection obligations on each sub-processor that are no less protective than these terms, and we remain fully liable to you for their performance.
The principal sub-processor is Anthropic, which provides the AI generation. Anthropic's commercial API terms state that inputs and outputs submitted through the API are not used to train its models.
5. International transfers
School personal data is stored in the United Kingdom, on a dedicated server in Manchester. Storage involves no international transfer and therefore no transfer mechanism.
Prompt content is transferred to Anthropic in the United States when a resource is generated.
That transfer relies on the UK Addendum to the EU Standard Contractual Clauses — the Approved Addendum (version B.1.0) issued by the Information Commissioner under section 119A(1) of the Data Protection Act 2018 — incorporated into Anthropic's Data Processing Addendum, which forms part of the Commercial Terms under which we use the Claude API. We have completed a transfer risk assessment, available to schools on request.
We will not transfer School personal data outside the United Kingdom other than as described here without informing you first.
6. Security
We maintain technical and organisational measures appropriate to the risk, including: encryption in transit; hashed passwords; mandatory two-factor authentication on every account; single active session with idle and absolute timeouts; per-account data isolation enforced at the database layer; audit logging; reason-recorded, time-limited and logged administrative access; rate limiting; and removal of metadata and identifiers from exported files.
Our administrators cannot view AI prompt or output text, or assistant chat content. Prompt and output text is not retained at all.
The current measures are described in full, and kept up to date, on the Data protection information page. We may change specific measures provided the level of protection is not reduced.
7. Data subject rights
Teachers can access, correct, export and delete data in the application directly, which will resolve most requests without our involvement.
Where you need our help, contact privacy@classmind.co.uk and we will assist without undue delay and within your statutory timescales. If a data subject contacts us directly about School data, we will not respond substantively; we will refer them to you and tell you promptly.
Pupil records are stored against an anonymous code chosen by the teacher. You or the teacher will normally need to identify the relevant record, since we cannot link a code to a named pupil.
8. Deletion and return
On termination, or on your written request, we will delete School personal data within 30 days, unless UK law requires us to retain it. Teachers may delete individual pupil records and saved outputs at any time, taking effect immediately.
Because prompt and output text is never retained, no copy of that content exists in our logs to return or erase. Generated export files are purged automatically. Retention periods are listed on the Data protection information page.
9. Audit
We will make available the information necessary to demonstrate compliance with Article 28, normally by providing our Data protection information page, our security review summaries and written answers to your questions.
Where that is not sufficient, you may request an audit no more than once in any 12 months, on at least 30 days' written notice, at reasonable times, without unreasonable disruption, and subject to confidentiality. You bear your own costs. We will also cooperate with the ICO.
10. Special category data and School responsibilities
ClassMind is not designed to process special category data. We ask that safeguarding, medical, SEND diagnosis, attendance, behaviour and family information is not entered, and we have built in guidance and automated warnings to discourage it, as described on the Data protection information page.
The School is responsible for:
- Deciding whether staff may use ClassMind, and telling them what may and may not be entered.
- Its own lawful basis for processing pupil data, and its own DPIA.
- Transparency to pupils and parents about the tools it uses.
- Reviewing generated content before use. All outputs are drafts.
Because teachers usually sign up individually rather than through school procurement, we may not know which school a user belongs to. We encourage schools to send a data protection contact to privacy@classmind.co.uk so we have a route to reach you, particularly for breach notification under section 11.
11. Personal data breach
We will notify you without undue delay after becoming aware of a personal data breach affecting School personal data, and will provide the nature of the breach, the categories and approximate number of records affected, the likely consequences, the measures taken, and a contact point — so far as that information is available to us, supplementing it as we learn more.
We will not make a notification to the ICO on your behalf in respect of data for which you are the controller; that decision and the 72-hour Article 33 deadline are yours.
12. General
These terms are governed by the laws of England and Wales, and the courts of England and Wales have exclusive jurisdiction.
We may update these terms to reflect changes in law or in the service. Material changes will be notified on this page with a new version number and date, at least 30 days before taking effect. The version and date at the top of this page identify the terms currently in force.
If any provision here conflicts with our general terms of service in relation to the processing of School personal data, these terms take precedence.
Questions: privacy@classmind.co.uk.