Instructor data processing terms

These terms apply when you, a driving instructor or driving school (“you”), use LicencePath to keep records about your pupils: adding pupils, booking and recording lessons, assessing skills, recording payments and exporting or redacting records (“pupil records”).

They form part of the LicencePath terms of service. You accept them when you add your first pupil record or continue to keep pupil records after this version takes effect. If they conflict with the terms of service on how pupil personal data is handled, these terms win.

For pupil records, you are the controller. You decide why you keep the record and what goes in it. Rainfame Technologies Ltd (company number 16794641, registered in England and Wales), which operates LicencePath (“we”, “us”), is your processor under Article 28 of the UK GDPR.

These terms do not cover a learner’s own LicencePath account. When a pupil creates an account and uses theory practice, the AI coach or other learner features, we are the controller of that data under our privacy policy. When a pupil claims their record into their own account, the link between the two is handled as described in the pupil privacy notice.

• Subject matter and purpose: hosting, storing, organising, retrieving, exporting and redacting pupil records so you can run lessons for your business.
• Nature: storage in a hosted database, display in your instructor workspace, sending transactional emails you trigger, and producing exports you request. Lesson reminders require your recorded agreement and the pupil’s email confirmation. Pupils can stop these emails at any time. Reminder choice history is retained, redacted and purged with the pupil record; temporary request limits are removed after 30 days.
• Duration: while you keep pupil records on LicencePath, then until deletion under section 10.
• Data subjects: your pupils, including pupils under 18, and any parent, guardian or other contact you name for a pupil.
• Personal data: names, preferred names, optional phone and email, transmission type, lesson arrangements, pickup addresses, the email address used for a record-claim invitation, bookings, lesson dates and durations, lesson notes and focus, skill assessments, private teaching notes, charges, payments, refunds and receipts, and privacy notice records.
• Special category data: none is requested. Do not record health, medical or other special category details in free-text fields.

• Have a lawful basis for each record, and tell each pupil you use LicencePath. You can point them to the pupil privacy notice.
• Keep only what you need, keep it accurate, and decide how long you keep it. Archived records follow the default schedule in section 10 unless you keep them. Your tax record duties are yours.
• Answer your pupils’ information requests. A parent or guardian named as a contact does not get access to a pupil’s records automatically.
• Check whether you need to pay the ICO data protection fee. We cannot decide that for you.
• Keep your login secure and do not share it.

We process pupil records only on your documented instructions, including with regard to transfers outside the UK, unless UK law requires otherwise. If it does, we will tell you before processing unless the law forbids that. Your instructions are these terms and the actions you take in LicencePath, such as adding, editing, exporting, archiving or redacting a record, or asking us to send an email.

We will immediately tell you if we think an instruction breaks UK data protection law. We do not use pupil records for our own marketing, do not sell them, and do not use them to train AI models. The contents of pupil records are not sent to our AI provider or our analytics providers.

Only people who need access to run, support or secure the service can reach pupil records, and they are bound by confidentiality. We look at a pupil record only to provide the service, to answer your support request, to keep the service secure, or where the law requires it.

We take appropriate technical and organisational measures, including:

• Row-level access control in the database, so a record is reachable in the app only by the assigned instructor in a current business membership and, once claimed, by that pupil.
• Encryption in transit (HTTPS) and encryption at rest by our hosting providers.
• Private teaching notes visible only to the assigned instructor and kept out of pupil copies.
• Audited, irreversible redaction, and export files that guard against spreadsheet formula injection.
• Error monitoring, so failures are found and fixed quickly.
• Reviewing these measures as the service changes.

We do not claim any security certification. Our providers hold their own; you can ask us which.

You give us general authorisation to use the subprocessors below. Each is bound by written data protection terms that give at least the protection these terms require. We remain responsible to you for their performance.

We will update this page and email the account address at least 30 days before adding or replacing a subprocessor that handles pupil records. You can object by emailing us within that period with reasonable data protection grounds. If we cannot resolve the objection, you can export your records and stop using pupil records, and we will delete them under section 10.

Our main database, which holds pupil records, is hosted in London. Some subprocessors process pupil records outside the UK: for example, encrypted backups are held by GitHub in the United States. Where a subprocessor processes them outside the UK, we rely on a transfer mechanism recognised under UK data protection law, such as UK adequacy regulations, the UK Extension to the EU-US Data Privacy Framework for certified providers, or the UK International Data Transfer Addendum. You can ask us which applies to each provider.

Pupil requests: you can export a record (JSON or CSV), correct it, and redact an archived record from your workspace. If a pupil contacts us directly, we pass the request to you and do not answer it ourselves unless you instruct us to.

Your other duties: we give you reasonable help with security, breach notifications, data protection impact assessments and consulting the ICO, taking into account the information available to us.

Personal data breaches: we will tell you without undue delay after we become aware of a breach affecting your pupil records, with the information we have then and more as we learn it, so you can meet your own reporting duties.

Archived pupil records: unless you tick “Keep this record” on an archived pupil, we remove contact details and free-text teaching notes 2 years after you archive the pupil. We keep the pupil’s name, lesson dates and payment records until 6 years after the last lesson, or until 31 January 5 years after the end of the tax year of the last payment if that is later, and then delete the whole record. Restoring a pupil stops this, and archiving them again starts it again. Records you have not archived are not affected.

End of processing: before you stop, export the records you need. When you stop using pupil records and ask us in writing, or when you close your account, we will delete your pupil records within 30 days, unless UK law requires us to keep them. Copies in any backups held by our providers are removed as those backups are overwritten in their normal cycle, and are not restored except to recover from an incident. Redaction inside the app keeps names, dates and payment facts for your tax records, so it is not full deletion.

When your pupil records are deleted, a pupil who connected their record to their own LicencePath account keeps that account but no longer sees the lesson history you kept. Records you keep for a driving school are the school’s, so they are not deleted when only your account closes.

Audits: we will give you the information you reasonably need to show that these terms are met. If that is not enough, you can request an audit with reasonable notice, at your cost, no more than once a year unless a regulator requires it or after a breach, under confidentiality and without access to other customers’ data.

Liability under these terms follows the terms of service. Nothing limits liability that cannot be limited by law, or either party’s direct liability to pupils or the ICO under UK data protection law.

If we change these terms in a way that reduces protection for pupil records, we will give you at least 30 days’ notice by email. These terms are governed by the law of England and Wales.

Contact for data protection matters, breach reports, objections and deletion requests: founder@rainfame.tech.