TOK Wellbeing routinely receives both organisational and personal data in order to provide the products, services and reporting required by our clients and partners. It also receives similar data to underpin a range of research and development activity conducted for commercial and non-commercial purposes at TOK Wellbeing.
The Data Policy (“the Policy”) set out herein is intended to give reassurance to those providing data to TOK Wellbeing, by explicitly stating how such data is collected, stored and accessed via the strict industry standards on data security employed. Furthermore, it also specifies the ethical principles on which such data is used and the length of time that it remains accessible. As such, the Policy supports TOK Wellbeing staff as they carry out all activity, since it defines the attitudes expected of them and the strict approaches they must take when handling any data.
The Policy is an overarching policy and is provided in addition to other policies and/or statements for specific services that remain governed by the individual policies relevant to those services and the general information in this Policy is subject to those specific policies.
Examples of such policies include the Privacy Policies or Cookie Policies of our Websites and systems.
Furthermore, where relevant, the TOK Wellbeing activity will be subject to the provisions set out in all relevant legislation such as the Data Protection Act (1998), the General Data Protection Regulation (EU) 2016/679 (GDPR) and any subsequent UK data protection legislation (Data Protection Legislation), the Communications Act (2003).
TOK Wellbeing provides a resource through which schools can gain insight into overarching mental wellbeing of the pupils and staff population. We aim to build a picture of the current state of mental wellbeing of staff and pupils in Scotland’s schools. Schools and local authorities will be given the option to participate in research in which all staff and pupils in their schools will complete the Warwick-Edinburgh Mental Wellbeing Scale questionnaire once per term. Data will be collected and analysed each term to produce a mean score for the school, with year group, gender and status (pupil vs. staff) being explored. Each term’s data will be compared to identify any increases of decreases in wellbeing throughout the academic year. Participating schools’ data will be able to consent to their whole school data being analysed along with all other schools’ data to ascertain a mean score for all participant schools. This resource has been designed to give schools a clear picture of the current state of mental wellbeing in their school as well as providing a useful tool for schools to assess their current position and consider potential interventions.
Via an online survey TOK Wellbeing (the “Service” gathers whole school data and analyses it in order to identify trends across groups of staff and pupils, based on their year group and gender. Schools receive a report termly with an annual report being compiled at the end of the academic year.
The Service is provided for those using our published products as well as those who have given explicit permission to participate in any research and development TOK Wellbeing is undertaking. The latter is governed by our research code of practice (the “Code”).
As part of the Service, organisations and participants will choose and consent to the provision of organisational and some limited personal information (the “Data”) through the completion of the online survey. No identifying personal data is collected, only data relating to year group and sex of a pupil. Should the number of responses be so low that an individual can be identified then no analysis will take place. In doing so, the TOK Wellbeing acknowledges that the ownership of the data remains with the administrating organisation. All requests to share data with other non-fee-paying organisations will only be done on receipt of a certified permission form, for example where a school explicitly requests TOK Wellbeing to facilitate sharing of the school’s data with other schools or organisations.
The Service may include certain communications from the TOK Wellbeing such as service announcements and administrative messages, and these communications are considered part of the Service subscription and it will not be possible to opt out of receiving such notifications. TOK Wellbeing undertakes to limit such communications as much as possible.
Tree of Knowledge provides workshops and courses across the UK in businesses and schools to help motivate, engage and support staff and pupils.
Halbeath Interchange Business Park, 4, Kingseat Rd, Dunfermline KY11 8RY
TOK Wellbeing cares about how organisational and personal data is used and it is appreciative of the trust placed by organisations using the Service or participating in the Research to use such Data carefully and sensibly.
The information provided by organisations helps to personalise and continually improve the
Service offered. We use any organisational information provided to help administer accounts, and to continuously refine the reliability and ease of use of the Service. We also use this information to help develop new services. We use limited personal information provided to process an individual’s results which are combined with all responses to process reports for. No individual is ever identified through our reports or service. We also use this information to improve the platform, prevent or detect fraud or abuses of our website and enable third parties to securely carry out technical, logistical or other functions on our behalf.
• We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we will never disclose an individual’s personal data to anyone.
• Organisations have access only to the completed reports which uses whole school responses analysed by year group and sex. No one out with the TOK Wellbeing Team has access to any individual’s data, and the TOK Wellbeing Team cannot identify any individual via their data.
• Data will be accessible for the duration of the current academic year, or the past six months, whichever is longest, at which stage all data is archived from live access.
• Archived data will be deleted at regular intervals (typically 24 months) so it will only be held for the minimum time required.
Here are the types of information gathered:
• Information you give us: we receive and store any information you enter on our platform or give us in any other way. We ask only for sex, year group and whether participants are staff or a pupil.
• Automatic information: we receive and store certain types of information whenever you interact with us. We do not store IP addresses through our survey.
• Student information including sex and age – this data is collected to ensure our assessments are fair and to provide detailed analysis of mental wellbeing across the school.
Information about our users is an important part of our business and we maintain our business integrity by not selling information about our users to other parties.
• Only TOK Wellbeing have access your data and they must comply with our privacy policies at all times.
• Business transfers: as we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing arrangements. Also, in the event that TOK Wellbeing or substantially all of its assets are acquired, customer information will, of course, be one of the transferred assets.
We process and store anonymised data about participant. This data will, for example, spot trends in results. We may share the outcomes of any research carried out on this anonymised data with various third parties, for example, UK Government but never the underlying dataset and it is never the case that participants can be individually identified from such information.
TOK Wellbeing understands that through the use of the Service and acceptance of the relevant privacy policies, organisations will consent to the collection and use of the Data for storage, processing, and use by TOK Wellbeing. Copies of our privacy policies are available on our websites.
For the purposes of the Data Protection Legislation:
• Where we process personal data on behalf of a school, LEA, hospital or similar organisation (e.g. student or parent data), the relevant school, LEA, hospital or similar organisation is the data controller and TOK Wellbeing, 4 Halbeath Interchange Business Park, Dunfermline, Kingseat Road, Dunfermline, Fife, KY 11 8RY is the data processor.
• Where we process the personal data of someone who uses or orders our products or services for or on behalf of a school, LEA, hospital or similar organisation or for some other professional purposes (e.g. home based specialist teacher/tutor or clinical psychologist), TOK Wellbeing, 4 Halbeath Interchange Business Park, Dunfermline, Kingseat Road, Dunfermline, Fife, KY11 8RY is the data controller.
TOK Wellbeing complies fully with the ISO/IEC 270013 international standard regarding data security management, the highest standard in industry specifically for data security.
TOK Wellbeing operates on the Microsoft Windows™ operating system which can only be accessed by a small number of approved staff members of the TOK Wellbeing team. This number can change but is usually limited to a small core maintenance team responsible for monitoring and ensuring systems are online at all required times. Access is only possible using an account login and password and all access attempted is logged in real time. Access from any other location other than the TOK Wellbeing team is only possible once senior management permission has been granted (via an authorisation process) and only then is it implemented by the TOK Wellbeing team.
TOK Wellbeing uses SurveyMonkey where all data pertaining to participants is collected and stored. Like its operating system, the SurveyMonkey database can only be accessed by a very small number of approved staff members of the TOK Wellbeing team. Access is only possible using an account login and password and all attempted access is logged in real time. Access from any other location other than the TOK Wellbeing office is only possible once senior management permission has been granted.
Schools and organisation will be sent a SurveyMonkey link through which they will access the survey. This link does not store any personal information or IP addresses.
All TOK Wellbeing research and development activity will adhere to the best practice guidelines defined below. At all times these strict research principles will be followed and, in practice, respect will be given to all participants (individuals and organisations) and the manner in which their data is collected and used. Staff at TOK Wellbeing will conduct all research and development with the utmost professionalism, adopting appropriate industry standards in the areas of data security, project management and research methodologies.
All TOK Wellbeing research activity will be based on the following principles to ensure:
• Sensitive and helpful approaches are adopted towards those providing data.
• The confidentiality of data is protected.
• The planning, conducting and publication of research takes account of cultural, religious, racial, gender, age, socio-economic and other relevant differences amongst those participating in research.
• Rigorous and appropriate methodology is adopted to ensure the research data, findings and conclusions are fair, accurate, valid and reliable.
• Clear procedures are in place for the effective management of projects.
• Research findings are disseminated in keeping with the project brief and the conditions agreed as part of initial data supply.
• Staff conduct themselves at all times in a professional manner.
All TOK Wellbeing research activity will adhere to the following practices:
Respect for participants:
• Information will be given about the aims, purpose and outcomes of the research. All data gathering in institutions such as schools and businesses will take place only with the express agreement of authorised representatives of those institutions.
• Staff will respect participants’ views.
• Staff will be mindful of cultural, religious, race, gender, age, socio-economic, special needs and other relevant differences throughout the research process.
• Information about the Code will be given to participants and copies made available if requested.
Professional approach to data collection:
• Data gathering activities will be carried out fairly and openly.
• Data gathered will be used for the express purpose for which it was collected. Where an existing dataset could be used for another purpose, explicit permission will be sought again.
• Adequate notice will be negotiated and given for the timing of data collection and there will be sufficient liaison about the most effective collection and supply methods, to minimise disruption.
• Staff will ensure that any research instruments used (questionnaires, tests, etc.) will be as valid and reliable measures as possible, except where the purpose of the research is to obtain measures of these two features.
• Staff will adhere to the copyright laws regarding the use and acknowledgement of published and unpublished materials.
• Any use of digital recording devices during telephone interviews will be governed by the statutory requirements of the Communications Act (2003).
• OFCOM guidelines for the use of digital recording devices for telephone interviewing will be adhered to. For example, participants’ prior permission will be obtained for the use of such a device and they will be reminded of the recording at intervals during the interview.
• Staff will ensure that due regard has been taken of information available on TOK Wellbeing databases and via the Telephone Preference Registry before seeking to arrange telephone interviews as part of research activity.
• Information on and obtained from a participant in a market research survey will not be passed for follow up through sales and/or marketing activity, unless specifically requested by the participant.
Storing, analysing and reporting information:
• The legal rights of the individual or institution will always be observed, regardless of commercial considerations.
• TOK Wellbeing is registered under The Data Protection Act (1998) and staff will adhere to its provisions and those of the General Data Protection Regulation (GDPR) on the use of data.
• TOK Wellbeing will ensure that information storage in any area of the company is subject to appropriate levels of security and confidentiality. Access will be restricted to authorised project staff only.
• Information about the way data is stored and the security and confidentiality procedures in place will be made available to individuals and the authorised representatives of institutions upon request.
• Data that identifies individuals or institutions is held in confidence by TOK Wellbeing and will not be released to anyone unless the written consent of the relevant individuals or institutions is given. Where the data has been provided by a third party, such as a local authority or a business, the data will not be released to anyone other than that third party.
• TOK Wellbeing will take all reasonable steps to ensure that the results of educational research both at the individual and institutional level, will not cause substantial damage and distress.
• The purpose of educational research will not be such as to support decisions or other actions in respect of individuals.
• The researcher will destroy all original raw data provided if requested by the participants.
• Staff will base their findings and judgements on sound research evidence.
• Monitoring procedures will be used to ensure that all staff will not fabricate, falsify or misrepresent evidence, findings or conclusions.
• Dissemination of findings will be in appropriate, comprehensible forms for relevant audiences and subject to the principles and practice set out in the Code.
• TOK Wellbeing staff should ensure that appropriate branding is routinely placed on research instruments, reports and materials generated by them, unless a contract clause prevents this.
If you have any further queries regarding this data policy, please contact our Data Protection Officer at:
The Data Protection Officer
Tree of Knowledge
4 Halbeath Interchange Business Park,
Alternatively, you can email our Data Protection Officer at firstname.lastname@example.org