Privacy notice

This notice explains what personal data we hold, where it comes from, why we hold it, who we share it with and the rights you have under UK data protection law (the UK GDPR and the Data Protection Act 2018). It sits alongside our terms of service, which describe the service the data is used to deliver, and our safeguarding page, which explains why we hold as much of it as we do.

1. Who we are

The data controller is Complete School Solutions Ltd, a company registered in England and Wales under company number 16984053, whose registered office is at Unit 16, Roundhouse Court, Barnes Wallis Way, Chorley, PR7 7JN, United Kingdom. We operate cts-edu.com under the trading name Complete Tutor Solutions. Our ICO registration number is [to be confirmed: ICO registration number].

For anything relating to personal data, including any of the rights in section 12, contact us at info@cts-edu.com.

2. The data we collect

2.1 What you give us

• Parents: name, email address, phone number, postcode, how you heard about us, your marketing and WhatsApp choices, and your consent to session recording.
• Students: first name only, year group, subjects, and any notes the parent writes for the tutor. We ask for no surname, no date of birth and no address, because we do not need them. Notes may mention a special educational need; where a parent chooses to tell us something about their child's health or disability, that is special category data and we rely on the parent's explicit consent in providing it.
• Tutors: name, email address, phone number, subjects and levels, qualifications and experience, availability, your hourly rate, profile text and photograph, an optional CV, your date of birth, your address history, and the declarations you sign about convictions, childcare disqualification and being barred from working with children.
• Tutor clearance documents, which you upload to us directly. These are photo ID, proof of address, a passport or birth certificate, National Insurance evidence, evidence of your right to work or a share code, your enhanced DBS certificate, an overseas police check where you have lived abroad, qualification certificates and a safeguarding training certificate. This is the most sensitive material we hold about any adult on the platform, and we hold it because somebody who teaches a child alone on video has to be checked by someone. It is held under our safeguarding obligations, not for marketing, and it is never shown to a family.
• Anyone: what you write to us in messages, enquiry forms or email.

2.2 What we create as you use the platform

• Booking records: session requests, confirmations, cancellations and who cancelled, and the rate that applied.
• Payment records: the amount, the card hold, when it was taken, refunds and cancellation fees. Card details themselves are held by our payment provider; we never see or store a full card number.
• Session recordings: video and audio of every session, which includes video and audio of a child. See section 4.
• Messages and notifications: what is sent through the platform, by email and by WhatsApp where you have opted in, and whether an email was delivered or opened.
• Reviews: the rating and comment a parent leaves for a tutor. Reviews appear publicly as "Verified parent"; the reviewer's name is never shown.
• Profile views: a count of how many times each tutor's profile has been opened, and, where you were signed in, which tutor profiles you opened and on which days. It is counted on our own servers from the account you are signed in to, and nothing is stored on your device to do it: no cookie, no tracking identifier and no fingerprint. Where nobody is signed in we keep a number and nothing else — no IP address, no browser information and no identifier of any kind — so a view by someone who is not signed in cannot be connected to a person. It is deduplicated to one view per person per tutor per day. It is seen by our staff only, and is never shown to a tutor or to another family.
• Records of agreement: which version of our terms an account holder accepted and when, recorded at registration and at each sign-in. For tutors we additionally keep the digital signature given at onboarding: the name typed, the time, the version of the terms signed, and the IP address and browser the signing came from. We keep the last two because a signature is only worth what can be proved about it, and the tutor terms now carry obligations with money attached. The record is never overwritten: signing a later version adds a row rather than erasing the earlier one.

2.3 What we receive from other people

• References from the referees a tutor names, including what a former employer or colleague writes about them. A referee is told what the reference is for, and a tutor does not see it.
• The safeguarding interview. Our sister company Complete Staffing Solutions, the school staffing business, interviews tutors as part of clearance, and we hold the notes and the outcome. The clearance record itself is ours and is held in one place only, here rather than there, and every change to it is recorded against the member of staff who made it. Corrections are made here. This notice previously said the opposite — that CSS held the record and that we did not receive identity documents at all — and that stopped being true when the two systems were separated.
• Payment outcomes from our payment provider, such as whether a hold succeeded or a card was declined. We do not receive your full card number.
• Delivery and recording events from our email and video providers, such as whether a message was delivered and whether a recording finished.

2.4 Technical data collected automatically

• Server logs generated when your browser requests a page, including IP address, the page requested, the time and basic browser information. These are the ordinary records a web server keeps, and we use them for security and fault finding.
• Page view counts from Vercel Web Analytics, which measures how many people visit which pages. It does not set cookies for that purpose and does not follow you to other websites.

For completeness, some things other tutoring sites collect that we do not: we have no mobile app, we do not collect location data, we run no advertising pixels or third-party advertising cookies, we do not build profiles for advertising, we run no referral scheme, and we hold no tutor bank details at all.

3. Cookies and similar technologies

• Essential cookies: set when you sign in, to keep you signed in and to protect your session. The site cannot work without them, so there is no way to turn them off and still have an account.
• Your browser's own storage: we store small preferences such as your light or dark theme choice on your own device. That never reaches us.
• An offline cache: if you install the site to your home screen, a service worker caches a small offline page so you see something useful when your connection drops. It caches no personal data.

We set no advertising or cross-site tracking cookies, so there is nothing for a "Do Not Track" signal to switch off. If we ever introduce non-essential cookies we will ask for your consent first.

4. Children's data

Students on CTS are under 18, so we treat their data with particular care:

• The parent is the account holder. Students use the service through their parent's account, hold no account of their own and never contract with us or with a tutor directly.
• Parental consent, including consent to session recording, is obtained at registration, before any session can be booked.
• We collect the least we can: first name, year group, subjects and the parent's notes. No surname, no date of birth, no address.
• A tutor can see a student's record only through a booking they are actually teaching.
• A parent can exercise any of the rights in section 11 on their child's behalf by contacting us at info@cts-edu.com.

5. Session recordings

Every session is recorded, video and audio of both the tutor and the student. Recording is central to how the service is built rather than an optional extra: it is one of the protections that makes online tuition with a stranger safe, alongside vetting and monitoring. There is no unrecorded version of the service. We record for six purposes only: safeguarding review, resolving disputes, letting the parent who booked a session watch their own child's lesson back, producing a written transcript of the session, an automated check of that transcript that flags passages for a member of our staff to read, and producing a short written summary of what the lesson covered. Both participants see a recording notice before joining.

• Access is limited to our safeguarding team and to the parent who booked the session, for their own child's sessions only. A parent opens a recording from their sessions page and we create the link at that moment; it stops working shortly afterwards, so it cannot be forwarded to anyone else. We log each time a parent opens one.
• Tutors cannot view recordings, including of sessions they taught, and no family can see another family's. Tutors have no right to a copy. Your rights in section 11 still apply to everyone.
• Recordings are held by our video provider on our instructions and are stored encrypted.
• Every recorded session is transcribed. Not a sample and not only where a concern has been raised: a written transcript is produced of every session. The audio is not downloaded by us. We give our speech-to-text provider a short-lived link and it fetches the audio itself, so the recording is transmitted to that provider but does not pass through our own servers on the way.
• An automated system reads every transcriptand flags two things for a person to look at: anything suggesting a child may be at risk, and personal contact details being exchanged or tuition being arranged off the platform. Only the text of the transcript is sent to the model that does this. No names, no account identifiers, no ages and no school are sent with it, and the speakers are labelled only as "Speaker 1" and "Speaker 2".
• The automated check makes no decision about anyone. It can only raise something for a member of our staff to review, and a person rules on every flag and records what they decided. Nothing is acted on, and no account is suspended or reported, because of what an automated system concluded. This is deliberate, so that the check is not automated decision-making producing legal or similarly significant effects within the meaning of Article 22.
• Where a flag is raised, we keep a record of it: what the automated system found, the passage from the transcript it was about, and what our staff decided. That record cannot be deleted, because a safeguarding record that can be removed is worth less than one that cannot. It is visible to our designated staff only.
• Transcripts are held to the same rule as recordings: our safeguarding team, and nobody else. A tutor cannot read a transcript, including of a lesson they taught, and a family cannot read one either. A transcript is kept for exactly as long as the recording it came from and is deleted with it, so neither one outlives the other.
• A short summary of the lesson is written from the transcript by an AI model, and it is not held to that rule. The transcript itself stays closed, but the summary is shown to our staff, to the tutor who taught the lesson, and to the parent who booked it. It says what was covered. It is written to say nothing about how your child performed, and nothing about their behaviour, ability, attitude or needs. Wherever it appears it is labelled as written by a machine from the recording and not checked by a person, and the tutor who taught the lesson can stop one reaching you. It is deleted with the transcript and the recording.
• Recordings are retained for two years and then deleted, except where a recording is relevant to a safeguarding concern, a complaint or a legal claim, in which case it is kept for as long as that matter requires. A concern about a lesson often arrives long after it: a child may say something months or years later, and if the recording has gone by then, so has the evidence of what happened. That protects a tutor who did nothing wrong as much as it protects a child. The 14-day window for reporting an ordinary problem with a session is a separate and much shorter thing, and no deadline at all applies to raising a concern about a child.
• Deletion is a scheduled job, not a promise. Once two yearshave passed, the recording and its transcript are deleted automatically, and each run records what it deleted and what it left alone. Where a member of our staff has marked a session as relating to a safeguarding concern, a complaint or a legal claim, or where the automated check has raised something nobody has yet ruled on, the recording is placed out of that job's reach until a named member of staff releases it and gives a reason.

The wider safeguarding context is explained on our safeguarding page.

6. How we use data, and our lawful bases

We only use personal data where the law gives us a basis for it. The table below sets out each purpose against that basis, and names the interest where we rely on legitimate interests.

Where we rely on consent, you can withdraw it at any time without affecting anything done before you withdrew it. Withdrawing consent to marketing simply stops the marketing. Consent to recording is different: you can withdraw it, but sessions cannot take place unrecorded, so withdrawing it means the service can no longer be provided.

7. Ranking, matching and automated decisions

Search results are ordered automatically, using profile information, ratings and hours taught. Our optional "Match me" flow goes a step further and uses an AI model to suggest which tutors fit a request. Where that runs, we send the request details the parent typed and a short summary of each candidate tutor's profile: subjects, headline, the tutor's own profile description and their rating. We do not send names, contact details, student details or anything about a child, and the provider does not use what we send to train its models.

The third is the transcript check in section 5.An AI model reads the transcript of every recorded session and flags passages for a member of our staff to read: anything suggesting a child may be at risk, and contact details being exchanged or tuition being arranged off the platform. Only the transcript text is sent, with no names and no identifiers, and the speakers are labelled only as "Speaker 1" and "Speaker 2".

The fourth is the lesson summary in section 5.An AI model writes a short account of what a lesson covered, from the transcript, and it is shown to our staff, to the tutor who taught the lesson and to the parent who booked it. Only the transcript text is sent, on the same terms as the check above: no names, no identifiers, and the speakers labelled only as "Speaker 1" and "Speaker 2". It is the one thing on this page where what a model wrote is read by a family rather than only by our staff, so it is worth being plain about what it is and is not.

The summary is information and not a decision. Nothing follows from it: no mark, no assessment, no report, and nothing about whether your child continues or who teaches them. It is written under an instruction not to judge your child at all — not how well they did, not what they find hard, not their behaviour or attitude, and never a grade or a prediction. Every place it appears says it was written by a machine from the recording and has not been checked by a person, and it says which model wrote it. The tutor who taught the lesson can stop one being sent to you, and their own write-up is the account to go by. If one says something that did not happen, tell us and a person will answer you.

The fifth applies to tutor applicants only, and to nobody else. When somebody applies to tutor, an AI model reads their CV to pre-fill the application form — which they then check and correct themselves, and nothing it drafts counts until they have. The only thing we send for it is that applicant's own CV. We do not send their name, contact details, address, date of birth, photograph or any equal opportunities answer, and the provider does not use what we send to train its models.

We never send identity, qualification or criminal record documents to an AI model. Photo ID, proof of address, a passport or birth certificate, National Insurance evidence, a right to work document or share code check, a visa, an overseas police check, qualification certificates and the DBS certificate itself are held by us and are not sent to any AI provider.

No AI model assesses a tutor application.We used to produce an AI "suitability guide" for our staff from an applicant's CV and qualification certificates. We stopped doing that in August 2026 and removed it. Nothing now reads an application to rate it, rank it or decide anything about it: a member of staff reads the CV and decides, with their name recorded against the decision.

Profile views are recorded, and they are not one of these. We count how many times each tutor's profile has been opened, and where you are signed in we record which tutor profiles you opened and on which days, so that our staff can see the interest a listing is getting and which tutors a family has already considered. No AI model receives it. It does not feed the ranking described above, it is not used by the Match me flow, it is not used to advertise to anybody, and nothing is sent to you or to a tutor because of it. Where nobody is signed in we hold a number and nothing else, and nothing is stored on your device either way.

None of these makes a decision with a legal or similarly significant effect on anyone. The transcript check in particular cannot decide anything: it raises a passage and a person rules on it, and nothing follows from a flag until they have. No account is suspended, no session is stopped and no report is made because of what the model concluded. Ordering results changes what a family sees first, and a family chooses their own tutor from that list. Nobody is accepted or rejected as a tutor by an automated process: clearance is a human decision made by our staffing team. You can object to automated ranking, or ask us to explain a result, by emailing info@cts-edu.com.

8. Who we share data with

We do not sell personal data and we do not share it for anyone else's marketing. We share it with the service providers who process it on our instructions, under a contract that requires them to protect it:

We also share personal data in these situations:

• With the other party to a booking.A tutor sees the student's first name, year group, subjects and the parent's notes, and the parent's first name, for sessions they are teaching. A family sees the tutor's profile, rate and trust badges. Neither sees the other's contact details, because contact stays on the platform.
• With CSS, our sister staffing company, in relation to a safeguarding matter, and where a tutor also works for them. CTS holds a tutor's clearance record itself: it is not a copy of one CSS keeps, and where the two companies both know a person, each holds its own record rather than one mirroring the other.
• With the authorities, including the police and local authority children's services, where a child may be at risk or the law requires it. We will always cooperate fully with an official investigation.
• With our professional advisers, such as accountants and solicitors, where they need it to advise us.
• On a sale or reorganisation of the business, in which case personal data may transfer to the buyer, who would be bound by this notice until they told you otherwise.

9. International transfers

Some of the providers above are based outside the UK, or process data outside it, including in the United States. Where data leaves the UK we rely on safeguards recognised under UK GDPR, such as UK adequacy regulations or the International Data Transfer Agreement, or the Addendum to the EU standard contractual clauses, so that it remains protected to UK standards. Which specific providers transfer data outside the UK, where they store it, and which safeguard applies to each is [to be confirmed: per-provider transfer detail and safeguard]. You can ask us for a copy of the relevant safeguard by emailing info@cts-edu.com.

10. How we protect data

• Data is encrypted in transit, and session recordings are stored encrypted.
• The database enforces access at row level, so an account can only reach its own records. The most sensitive columns, including payment fields, tutor clearance and signature records, cannot be written by any signed-in account at all: they are changed only by our own server-side processes.
• Staff access is limited to those who need it, and staff access to session recordings is limited to safeguarding team. A parent can watch their own child's sessions, as set out in section 5.
• We design for the data we do not hold as much as the data we do. There is no field anywhere in our systems for a tutor's bank details, a student's surname, a date of birth or a home address. A system that does not hold something cannot leak it.

No transmission over the internet is ever completely secure, so we cannot guarantee the security of data sent to us over the internet. Once it reaches us we protect it with the measures above.

11. How long we keep data

We keep personal data only for as long as we need it for the purposes in section 6, and then delete it. Specifically:

• Account and booking data: for the life of the account and then 6 years. That is how long a company must keep records for tax purposes, and it is also the period within which a claim in contract can be brought, so it is the point at which both reasons for holding it run out.
• Session recordings and transcripts: two years, as set out in section 5. A recording relating to a safeguarding concern, a complaint or a legal claim is kept beyond that, for as long as the matter requires.
• Payment, accounting and payroll records: for as long as tax and accounting law requires.
• Records of terms acceptance and tutor signatures: for as long as we keep the account data they belong to, and no longer. They are evidence of an agreement that can be relied on after the account has gone, so they follow the account data rather than having a period of their own.
• Anything relevant to a safeguarding concern, a complaint or a legal claim: for as long as that matter requires, which may be longer than the periods above.

12. Your rights

Under UK GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data rectified;
• have data erased, where the law allows;
• restrict how we process your data;
• receive your data in a portable format;
• object to processing based on legitimate interests, including the ranking described in section 7;
• withdraw consent at any time where we rely on it, such as for marketing;
• not be subject to a decision made solely by automated means that has a legal or similarly significant effect. We do not make decisions of that kind.

To exercise any of these rights, for yourself or on behalf of your child, email info@cts-edu.com. There is no charge, unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse it, and we will explain why. We may ask you to confirm your identity first, so that we do not disclose someone else's data to the wrong person. We will respond within one month, and will tell you if we need longer because a request is complex.

Some rights are qualified. We may need to keep data connected to a safeguarding matter, a legal claim or a legal obligation even if you ask us to erase it. A request about a tutor's clearance record is one we answer ourselves: we are the controller for it, it is held here and nowhere else, and you do not need to ask anybody else for it. This notice previously said that record's controller was CSS and that we would pass such a request on, which was left over from the arrangement described in section 2.3 and has not been true since the two systems were separated.

13. Questions and complaints

If you are unhappy with how we handle your data, please contact us first at info@cts-edu.comso we can put it right. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113. We would rather hear from you first, but you do not have to come to us before you go to them.

14. Changes to this notice

We may update this notice from time to time. If we make a material change, particularly one affecting children's data or session recordings, we will notify account holders by email before it takes effect, and the updated notice will be published on this page with a new date at the top.

See also our terms of service and safeguarding page.