Privacy notice
Who we are
Spark is an attendance, enrichment and exams platform for UK colleges, operated by Velocity EU (“we”, “us”). You can contact us about anything in this notice at hello@velocity-eu.com.
We wear two hats under UK GDPR, and your rights depend on which one applies to you:
- We are the controller for this website, for enquiries you send us, and for our commercial relationship with the colleges we work with.
- We are a processor for the student and staff data held inside each college’s Spark tenant. Your college is the controller of that data; we process it only on the college’s documented instructions, under a data processing agreement — see our data processing terms.
If you are a student, parent or staff member at a Spark college
Your college decides what data goes into Spark, why, and for how long. Its own privacy notice is the authoritative description of that processing, and requests to access, correct or erase your data should go to the college. To help you understand what the platform does, in outline:
- What Spark holds for a college: roster data (names, college identifiers, cohort and timetable membership), attendance and check-in records (including the statutory attendance codes required by law), enrichment activity participation, exam seating and identity-check records, staff absence records, and a tamper-evident audit trail of who changed what.
- Why the college uses it: keeping the attendance registers colleges are legally required to keep, safeguarding, exam administration (including JCQ identity checks), and running enrichment programmes.
- Where it lives: each college has its own physically separate database, hosted in the United Kingdom (AWS London, eu-west-2). Data is not pooled across colleges, and our central control plane holds no student data — only college-level configuration.
- Who else touches it: only the sub-processors listed in our DPA (database hosting, application hosting, and email delivery). We do not sell data, use it for advertising, or use it to train AI models.
- How long it is kept: for as long as the college instructs; when a college leaves Spark its database is returned or deleted per the DPA.
If you visit this website or contact us
For visitors and business contacts, we collect and use:
- Enquiry and demo-request details (name, work email, college, message) — used to respond to you and manage our relationship with your college. Lawful basis: our legitimate interest in responding to enquiries and, where a contract follows, performance of that contract.
- Account data for college staff who sign in to the Spark console (name, work email, role, sign-in method) — processed on your college’s behalf to operate the service.
- Operational logs (IP address, requests, errors) — used to keep the service secure and reliable. Lawful basis: our legitimate interest in security. Kept for short, rolling periods.
- Cookies — essential sign-in cookies only; see the cookie notice.
We keep enquiry correspondence for a limited period after our last contact — currently up to 24 months, which we are reviewing — and contract records for the periods required by law.
International transfers
Spark tenant databases are hosted in the United Kingdom. Where a sub-processor’s support operations involve access from outside the UK, that access is covered by UK-approved safeguards (the UK Addendum to the EU Standard Contractual Clauses or an adequacy decision), as set out in the DPA.
Your rights
Under UK GDPR you can ask for access to your data, correction, erasure, restriction, portability, and to object to processing based on legitimate interests. For data inside a college’s Spark tenant, send your request to the college (we will assist it); for website and enquiry data, email hello@velocity-eu.com. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk. Our ICO registration is pending; we will publish the number here as soon as it is issued.
Changes
We will post any material change to this notice here and update the date at the top. Questions? Write to hello@velocity-eu.com.