School documents · Pack 2026-08-29

Data processing terms (Article 28)

Standard processor terms schools can attach to a purchase order or countersign.

Who it is for: SBMs, clerks, DPOs, MAT procurement
How to access it: Public standard terms. A countersigned copy with the school’s legal name is school-specific and should be stored by the school (email or e-sign), not published.

This pack describes how Five Wells Education designs and operates the platform so schools can complete their own due diligence. It is not legal advice. The school remains the data controller for pupil and staff data it places in the product. A solicitor or DPO should review processing before go-live.

Status of this document

These are Five Wells Education’s standard data processing terms for the platform, version 2026-08-29. They apply when a school uses the service. They do not replace a bespoke contract if the parties sign one.

Subject matter and duration

Processing is the hosting and operation of the Five Wells Platform and any enabled modules (including SEND Tracker, Wonde sync, AI planner, and photo memories) for the school’s tenant. Duration is the subscription / academic-year licence plus a short wind-down for export and deletion.

Nature and purpose

Provide staff, pupil, and parent access to the school’s tenant.
Store recognition, analytics, and optional SEND records the school creates.
Send transactional email the school triggers (for example staff invites).
Provide optional AI drafting the school chooses to run, and the optional pupil Well helper if the school enables it.

Types of personal data and data subjects

Pupils, staff, and parents/carers as enrolled by the school. Data types are those listed in the privacy notice and roster notice. Special category data may include SEND/EHCP-related information if the school uses those fields or the SEND Tracker.

Processor obligations

Process only on documented instructions (this product, school settings, and written support requests).
Ensure persons authorised to process are under confidentiality.
Implement appropriate technical and organisational measures (see Security measures).
Use sub-processors listed in the sub-processor register; tell schools of intended changes to that list via this public page.
Assist the school with data-subject requests, DPIAs, and consultations, within the product’s design (exports, deletion tools, tenant isolation).
Notify the school without undue delay after becoming aware of a personal data breach affecting that school’s tenant.
Delete or return tenant data at the end of the service, except where UK law requires storage.
Make available information necessary to demonstrate compliance and allow audits on reasonable notice, without exposing other schools’ data.

School (controller) instructions

Do not upload safeguarding casework, medical records, or data the product is not designed to hold.
Configure MFA, passkeys, and staff access in line with the school’s policy.
Use Data export before offboarding if local copies are required.
Keep parent-facing privacy notices up to date.

International transfers

Hosting is provided by named sub-processors. Some optional AI processing (Google Gemini) may occur outside the UK. Where a restricted transfer occurs, it relies on the sub-processor’s transfer tools (for example UK extensions to standard contractual clauses) as described in that vendor’s terms. Schools should record this in their DPIA if they enable AI or SEND AI drafting.

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