Privacy Policy
Last updated: 1 September 2026
School Compliance Documents
For Principals, DPOs, and school procurement reviews, the following supporting documents are available:
Where this page summarises those documents, the documents themselves govern.
1. Who We Are
SENScribe Limited is a company registered in Ireland that develops and operates the SENScribe service.
| Legal Entity | SENScribe Limited (CRO 813862) |
| Registered Address | ARKINS & COMPANY LIMITED, BLOCK 15, Galway Technology Park, Parkmore, Galway, GALWAY, Ireland, H91 AY0Y |
| Data Protection Contact | hello@senscribe.ie |
Our role depends on the data involved:
- Student personal data: When a school, ETB, or board of management uses SENScribe, that educational body is the data controller for student personal data, and SENScribe Limited acts as its data processor. This allocation is set out in Clause 2.4 of our Data Processing Agreement.
- Teacher accounts, teacher-access applications, school licence enquiries, subscription payments, and consent-based marketing and analytics: SENScribe Limited is the data controller.
2. Data We Collect
We collect the following categories of personal data:
2.1 Account Information
- Email address: used for authentication and communication
- Name: for personalisation (if provided)
- School affiliation: to review your application for teacher access
2.2 Teacher Access Applications
When you apply for teacher access, we collect your full name, school or work email, role, and selected school (or manual school name if unlisted). Application details are stored by SENScribe and shared with Zoho CRM to support manual application review. Please do not include pupil or student information in an application.
2.3 School Enquiry Information
If you enquire about a school licence, we collect your name, school or work email, optional phone number, role, selected school details (including directory-derived roll number, county, and type when listed) or manual school name/type, estimated staff requiring access, optional referral code, and optional message. Please do not include pupil or student information in an enquiry.
2.4 Usage Data
- Session tokens: to keep you logged in
- Usage count: to enforce fair use limits
- Timestamps: when you access the service
2.5 Student Support Data
When using SENScribe, you may input information about students and save Student Support Files. This data is encrypted on your device before being stored on our servers. Saved files use keys held by the teacher. For secure review links, the decryption key is split: the SENScribe application stores one half and a separate, database-free email service receives the other half only long enough to place it in the link. Neither service alone can decrypt the shared file. Our servers hold ciphertext and wrapped keys only; during normal operation we have no technical means to decrypt stored files, and decryption depends on teacher-held credentials such as the data password or recovery key. Details and exceptions are described in our Privacy Whitepaper. See Section 5: AI Processing & Data Storage for details.
3. How We Use Your Data
We use your personal data for the following specific purposes:
| Purpose | Data Used |
|---|---|
| Account creation & authentication | Email, name, hashed password |
| Sending password reset and account-related service emails | |
| Reviewing and processing teacher access applications | Teacher access application information listed in Section 2.2 |
| Generating Student Support Plan drafts | Redacted and generalised AI text (see the automated-detection limitation below) |
| Enforcing fair use limits | Usage count |
| Responding to and managing school licence enquiries | School enquiry information listed in Section 2.3 |
| Service and account-related email (password reset, security, account support) | |
| Product updates | Email - where we hold your valid marketing consent, or on the soft opt-in basis available to existing customers for similar products under the ePrivacy Regulations (with a clear unsubscribe in every message) |
| Website analytics & improvement | Pseudonymous usage data via Google Analytics (consent required) |
4. Legal Basis for Processing
Under GDPR, we must have a lawful basis for processing your personal data. We rely on the following:
| Legal Basis | Applies To |
|---|---|
| Contract (GDPR Art. 6(1)(b)) | Account creation, authentication, reviewing teacher-access applications (steps requested before entering a contract), providing the SENScribe service, and steps requested before entering a contract with you, where applicable |
| Consent (GDPR Art. 6(1)(a)) | Marketing where you have given affirmative consent, and analytics cookies where you have accepted them |
| Contract and legitimate interest (GDPR Art. 6(1)(b)/(f)) | Service and account-related email, and product updates to existing customers for similar services under the ePrivacy soft opt-in |
| Legitimate Interest (GDPR Art. 6(1)(f)) | Service security, fraud prevention, service improvement, manual review of teacher access applications, and proportionate business-to-business enquiry follow-up where the contract basis does not apply |
5. AI Processing & Student Data
✓ Encryption for Student Support Files
SENScribe encrypts all Student Support Files on your device. Your data is encrypted on your device before being stored on our Azure-hosted servers in the EU, which hold ciphertext and wrapped encryption keys only. During normal operation we have no technical means to decrypt stored files: decryption depends on teacher-held credentials such as your data password or recovery key. Documented exceptions are described in our Privacy Whitepaper. This claim covers Student Support Files; account information such as your email address is handled as described in this policy. For AI generation, a final browser-side check redacts likely names and common direct identifiers and generalises recognised diagnoses before transmission. Every official AI request is blocked if that privacy check cannot complete; automated detection is not infallible.
How AI Processing Works
- You enter student information into SENScribe
- Your browser detects and replaces likely names and common direct identifiers with anonymous placeholders (e.g., "Seán" → [PERSON_1])
- Your browser generalises specific diagnoses to functional descriptions (e.g., "ADHD" → "attention regulation needs")
- The complete request is checked again immediately before sending; if redaction cannot complete, nothing is sent
- The resulting redacted and generalised text is sent to our server and Azure OpenAI within the European Union data zone
- The AI generates a draft using the anonymous placeholders and generalised needs
- Your browser restores the real names when displaying the result
How Data Storage Works
- You set a data password (separate from your login password) when you first save a student
- A unique encryption key is generated on your device and wrapped using your data password
- All Student Support Files (plans, reviews, logs, checklists) are encrypted on your device using AES-256-GCM before being sent to our servers
- Our servers hold only ciphertext and wrapped keys - during normal operation we have no technical means to decrypt stored files
- When you log in on a new device, you enter your data password to unlock your data
- A recovery key is provided at setup in case you forget your data password
GDPR & Special Category Data
Educational data linked to identifiable students may be considered Special Category Dataunder GDPR Article 9. SENScribe addresses this through two layers of protection:
- AI generation: Likely student names, diagnoses, and common direct identifiers are redacted or generalised in your browser before transmission; automated detection reduces risk but cannot guarantee that every identifier in free text will be recognised
- Data storage: All stored data is encrypted on the teacher's device with AES-256-GCM - our servers hold only ciphertext and wrapped keys, with no technical means to decrypt during normal operation
- These measures satisfy GDPR Article 32 security requirements; breach notification obligations under Articles 33 and 34 apply without prejudice
- Customer database hosting is in an Azure EU/EEA region. AI processing uses an Azure OpenAI EU Data Zone deployment.
- These controls support GDPR Article 5(1)(c) data minimisation
Your Responsibilities as a Teacher
As the user entering student data, you are responsible for ensuring you have appropriate authorisation from your school to use SENScribe for this purpose. We recommend:
- Obtaining approval from your school's Data Protection Lead
- Using only the minimum necessary student information
- Not sharing generated drafts inappropriately
6. Who We Share Data With
We use the following service providers. Depending on the service, they act as our processor or as an independent controller under their own terms:
| Provider | Purpose | Data Shared |
|---|---|---|
| Microsoft Azure (Cosmos DB) | Database hosting | Account data, sessions, encrypted Student Support Files (encrypted on the teacher's device) |
| Microsoft Azure OpenAI | AI generation | Redacted and generalised prompts (likely names and common direct identifiers replaced with placeholders in your browser before transmission) |
| Microsoft Azure Communication Services | Email delivery (primary) | Recipient, subject, HTML and plain-text message content, optional reply-to address, and for secure review invitations only, the email-link half of the split decryption key |
| Resend | Email delivery (fallback) | Recipient, subject, HTML and plain-text message content, and optional reply-to address for supported fallback emails |
| Revolut | Payment processing for subscriptions | Billing contact and payment details (no Student Support File content) |
| Zoho CRM (Zoho Corporation B.V.) | Managing teacher access applications and school licence enquiries | Teacher access application details and school enquiry information listed in Section 2.2 and Section 2.3; no pupil or student information is requested |
| Zoho (Zoho Corporation B.V.) | Invoicing | Billing contact details needed to issue invoices; no Student Support File content |
| Google Analytics | Website analytics | Pseudonymous usage data (consent required) |
We do not sell your personal data to third parties.
Our current provider register, including regions and transfer safeguards, is published on our Providers & Sub-processors page.
Record of processing (GDPR Article 30 summary)
To help your school complete its own record of processing activities, this table shows how our role maps to each category of data. Full detail is in the Data Processing Agreement (Annexes) and the Trust Center.
| Data Category | SENScribe Role | Purpose | Lawful Basis | Retention (general terms) |
|---|---|---|---|---|
| Encrypted Student Support Files | Processor for the school | Secure storage, sync, and sharing of student support records | Determined by the school as controller | Until deleted by the school or handled per offboarding instructions (DPA Clause 12) |
| Browser-redacted AI prompts | Processor for the school | Generating draft support-plan text from teacher input | Determined by the school as controller | Not stored by SENScribe (in-memory processing); flagged prompts may be retained by Microsoft under Azure abuse-monitoring terms |
| Account and service email | Controller (Microsoft primary; Resend fallback) | Delivering password reset and account service emails | Contract (Art. 6(1)(b)) | Kept only as long as needed to deliver and troubleshoot email |
| School-related email (secure review invitations) | Processor for the school | Delivering secure review invitations on documented school instructions | Determined by the school as controller | Deleted or returned under Clause 12 of the DPA; invitation key split so neither service holds both halves |
| Teacher account data | Controller | Account creation, authentication, fair-use limits | Contract (Art. 6(1)(b)) | Personal accounts deleted after 12 months of inactivity; school-controlled records excluded |
| Teacher access applications | Controller | Managing and reviewing teacher access applications | Steps toward a contract / legitimate interests (Art. 6(1)(b)/(f)) | Kept while needed to review and manage the application, then reviewed or deleted unless an approved user account is created or a longer period is required by law |
| School licence enquiries | Controller | Managing prospective school relationships | Legitimate interests / steps toward a contract | Kept while needed to manage the enquiry, then reviewed or deleted |
| Subscription payments | Controller (billing via Revolut under its own terms) | Processing subscription payments | Contract (Art. 6(1)(b)) | Retained for the life of the subscription and as needed for billing records |
| Product updates & service email | Controller | Account-related service email; product updates to existing customers (soft opt-in) or with affirmative consent | Contract / legitimate interests (Art. 6(1)(b)/(f)); consent where given (Art. 6(1)(a)); ePrivacy soft opt-in for existing customers | Marketing contact data held while consent stands or the soft-opt-in conditions are met; service email records kept as needed for service |
| Consent-dated analytics | Controller | Site analytics cookies | Consent (Art. 6(1)(a) / ePrivacy) | Until consent is withdrawn |
7. International Data Transfers
We use EU-region hosting for the following services:
- Azure Cosmos DB: Azure EU/EEA region
- Azure OpenAI: European Union data zone deployment
- Azure Communication Services: Europe (primary email provider)
- Zoho CRM: EU data centre for application and enquiry records
Some providers may process data outside the EEA for support or through their sub-processors. Google and Resend may process data in the United States; Resend is used only as a fallback email provider if our primary provider (Azure Communication Services) is temporarily unavailable. Zoho may allow limited support access or use approved sub-processors outside the EEA. Where restricted transfers occur, safeguards include:
- EU-US Data Privacy Framework (for certified companies)
- Standard Contractual Clauses (SCCs)
8. Data Retention
We retain your data for the following periods:
| Data Type | Retention Period |
|---|---|
| User account data | Eligible personal accounts and their personal data are automatically deleted after 12 months of inactivity. Organisation-controlled school and student records are excluded and follow the school's offboarding or deletion instructions. |
| Teacher access application information | Kept while needed to review and manage access requests, then reviewed or deleted when no longer needed, unless an approved user account is created or a longer period is required by law |
| Session tokens | 7 days of inactivity (expiry refreshed every 24 hours while you remain active), then automatically expire |
| School enquiry information | Kept while needed to respond to and manage the prospective school relationship, then reviewed or deleted when no longer needed, unless a longer period is required for a customer relationship or by law |
| Encrypted Student Support Files | Personal files are stored until manually deleted, deletion is requested, or the eligible personal account is automatically deleted after 12 months of inactivity. Organisation-controlled school and student records are excluded and follow the school's offboarding or deletion instructions. Encrypted on the teacher's device - decryption depends on teacher-held credentials such as the data password or recovery key. |
| Student names (during AI generation) | Redacted in your browser immediately before sending to AI; the request is blocked if that check cannot complete |
| Redacted and generalised AI prompts | Not stored by SENScribe (processed in-memory only) |
| Redacted and generalised prompts (Azure abuse monitoring) | Flagged content may be stored by Microsoft for human abuse-monitoring review under the applicable Azure terms (see Azure documentation) |
Note:Microsoft states that prompts flagged for potential abuse may enter additional review. Automated review does not store prompts, while content selected for human review may be stored within the Azure service boundary. For European deployments, authorised human reviewers are based in the EEA. Microsoft states that prompts are not used to train foundation models without customer permission or instruction; SENScribe has given neither. SENScribe's automated redaction reduces risk but cannot guarantee recognition of every identifier in free text.
9. Your Rights
Under GDPR, you have the following rights regarding your personal data:
- Right of Access: Request a copy of the personal data we hold about you
- Right to Rectification: Request correction of inaccurate data
- Right to Erasure:Request deletion of your data ("right to be forgotten")
- Right to Restrict Processing: Request we limit how we use your data
- Right to Object: Object to processing based on legitimate interests
- Right to Data Portability: Receive your data in a portable format
- Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
To exercise any of these rights, email us at hello@senscribe.ie. We will respond within one month as required by GDPR.
11. Security Measures
We protect your data using industry-standard security measures:
- Encryption in transit: All data is transmitted over HTTPS/TLS
- Encryption at rest: Database encryption provided by Azure (AES-256)
- Secure password storage: Passwords are hashed using an industry-standard password hashing approach and are never stored in plaintext
- Access controls: Limited access to production systems
- EU data residency: Customer database hosting is in an Azure EU/EEA region and AI processing uses the European Union data zone
12. Children's Data
SENScribe is designed for use by teachers aged 18 and over only. We do not knowingly collect personal data directly from children.
When teachers use SENScribe to generate Student Support Plan drafts, they may enter information about students. As described in Section 5, this information is encrypted on the teacher's device before being stored on our servers. During normal operation we have no technical means to decrypt this data; decryption depends on teacher-held credentials such as the data password or recovery key.
Teachers are responsible for ensuring they have appropriate authorisation to process student data through SENScribe.
13. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Update the "Last updated" date at the top of this page
- Notify registered users by email for significant changes
We encourage you to review this page periodically for the latest information.
14. Contact Us
If you have any questions about this Privacy Policy or how we handle your data, please contact us:
SENScribe Limited
Email: hello@senscribe.ie
Address: ARKINS & COMPANY LIMITED, BLOCK 15, Galway Technology Park, Parkmore, Galway, GALWAY, Ireland, H91 AY0Y
15. Complaints
If you are not satisfied with our response to a data protection concern, you have the right to lodge a complaint with the Irish Data Protection Commission:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2, D02 RD28
Ireland
Website: www.dataprotection.ie
Email: info@dataprotection.ie