This notice is for pupils who have applied to, are currently enrolled in, or have previously been enrolled in the Maths Coaching Pilot, and for their parents, carers, schools and teachers.
| Name | Axiom Maths (operating the Maths Coaching Pilot) |
| Address | 55-61 Brewery Road, Kings Cross, London, N7 9QH |
| Enquiries | hello@themathscoachingpilot.com |
| Registered Charity Number | 1199281 |
| Date of privacy notice review | 18/9/2026 |
Axiom Maths is a registered Data Controller with the Information Commissioner’s Office. Registration number: ZB345801.
To contact us about anything in this notice, or to exercise any of your rights under data protection law, please email hello@themathscoachingpilot.com.
Axiom Maths is committed to safeguarding your personal information. Whenever we process personal data, we do so in line with the Axiom Maths Data Protection Policy, this privacy notice, and all applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
The personal information we collect
Candidates
For pupils going through our application and selection process, we collect and process the following information:
- First name and surname
- Date of birth and school year
- Current school
- Gender
- Household income, and highest level of education in household (used to ensure the programme reaches disadvantaged pupils)
- Academic observations, including test scores and written feedback from coaches after in-person assessments
- SEND status and accommodations, where relevant, so that we can make appropriate arrangements for candidates at in-person discovery days
We also collect parent and carer contact details at the application stage — see the parents and carers section below.
If a candidate is offered and accepts a place on the programme, their record is carried forward and the fuller set of data described in the enrolled pupils section below is collected from that point. If a candidate is unsuccessful, their data is deleted within 60 days of notification of the outcome — see the retention section below.
Enrolled pupils
For each pupil enrolled on the programme, we collect and process the following information:
- First name and surname
- Date of birth
- Year of entry to the programme and cohort
- Participation status in the programme (e.g. active, left, alumni)
- Gender
- Home address, so that we can send you programme correspondence by post
- Pupil Premium eligibility
- Free School Meals eligibility
- Looked-after status
- SEND status and SEND detail (see special category data note below)
- Postcode deprivation score, derived separately from your address for programme evaluation (this is not a direct identifier)
- Household income and highest level of education in household, carried forward from the application stage
- School history — the school or schools attended, and the relevant dates
- Coaching session records — the date of each session, topics covered, and the coach’s professional notes on each session
- Session recordings — an audio and video recording of each coaching session (a separate stream for each participant), the whiteboard record of the session, any files uploaded during the session, and a transcript of what is said
- Assessment results from maths competitions and challenges
- External course enrolment and outcomes
- Event attendance
- Records of contacts with the programme
We may also collect and process the following information where provided:
- Ethnicity (optional; self-reported; collected for evaluation and demographic analysis only, and not used in any operational decisions about individual pupils; explicit consent is obtained at enrolment for this data — see lawful bases below)
The Maths Coaching Pilot processes two categories of special category data about pupils and candidates: SEND data, and, where provided, ethnicity. Both require an additional lawful condition under Article 9 of the UK GDPR. The Article 9 condition we rely on is ‘substantial public interest’ (Article 9(2)(g)) with the conditions of ‘safeguarding of children and of individuals at risk’ and ‘equality of opportunity or treatment’. We may also rely on ‘explicit consent’ (Article 9(2)(a)), obtained from parents and carers at enrolment.
Parents and carers
For each parent or carer, we collect and process the following information:
- Name and relationship to the pupil
- Contact details
- Preferred method of contact
- Preferred contact language (used to ensure we can communicate effectively; this is not collected as an indicator of ethnicity and is not used as such)
School contacts
Partner schools are schools with pupils enrolled in the programme, as well as schools who participate in the nomination process for their pupils. We hold the following information about partner schools:
- School name
- School URN
- Address and Post Code
- School profile data
- The name of our key contact at the school
- Contact details for our key contact
We use this information solely to manage our relationship with partner schools, to co-ordinate pupil enrolment, and to maintain school history records for pupils. The lawful basis for this processing is Legitimate Interests (Article 6(1)(f)). School profile data is retained as part of the pupil’s long-term record. The name and contact details of our key contact at each school are deleted when the relevant pupil leaves the school or completes the programme.
How we get this information and why we use it
We receive personal data from the following sources:
- Directly from pupils and families, during the application process and at enrolment and on an ongoing basis during the programme
- Partner schools, in relation to school contact information
- Partner schools nominating candidates for the programme — schools obtain consent from families before passing any data to us
- Assessment providers, in relation to competition results
- Coaches, who submit observations after coaching sessions and records of communication with schools and families
- External course providers, in relation to course enrolment and outcomes
We use this information to:
- assess applications and select pupils for the programme, including making appropriate accommodations for candidates at discovery days
- manage pupil enrolment and programme participation
- assign coaches to pupils and record coaching sessions
- track course enrolment and performance in external assessments
- provide appropriate support to individual pupils, including responding to SEND needs
- maintain contact with families, including by post, and support them in navigating educational choices
- monitor whether the programme is reaching and retaining underrepresented pupils
- evaluate the impact of the programme and improve our provision over time
- track long-term outcomes for alumni
- help coaches identify patterns in a pupil’s maths and session performance, using AI-assisted analysis — see below
AI-assisted analysis of maths performance
We use an AI system (provided by Anthropic) to help identify patterns in a pupil’s maths and session performance data, such as areas of difficulty or progress over time. Only maths and session performance data is used for this — never a pupil’s name or other identifying details, SEND information, or ethnicity, all of which are withheld from the AI system by design.
The AI system produces analysis for a pupil’s coach to review; a coach always reviews this analysis and decides what, if anything, to do as a result. The AI system does not itself make or affect any decision about a pupil. The Maths Coaching Pilot does not use profiling or automated decision-making as part of its processing of personal data.
Sharing data with third parties
Personal data is stored and processed in our pupil management system, which is operated on our behalf by a third-party provider (Airtable) acting as a data processor. This provider operates under a formal Data Processing Agreement with Axiom Maths, which sets out their obligations under UK GDPR.
Our pupil tracking system is operated by a company based in the United States. Personal data (including children’s data and special category data) is therefore transferred to the US. This data is only used by us, for the stated aims of the programme, and is not used by Airtable for any other purpose. It is never shared with third parties. Airtable stores data securely and applies appropriate technical and organisational measures to protect it, including access controls and encryption at rest and in transit.
As described above, we also use an AI provider (Anthropic) based in the United States to help analyse maths and session performance data. Only that performance data is transferred to Anthropic — never a pupil’s name or other identifying details, SEND information, or ethnicity. This data is used only to provide analysis back to us, is not used by Anthropic for any other purpose, and is never shared with further third parties.
Both transfers are made under the ICO International Data Transfer Addendum to the EU Commission Standard Contractual Clauses, which provides appropriate safeguards under Article 46 UK GDPR. Please contact us if you would like further information about either transfer.
Data may also be shared, without names, contact details, or precise geographical data, with external evaluators for the purpose of assessing the programme’s impact. Any such sharing will be on terms that prevent re-identification of individuals. Data may also be shared externally in case of safeguarding concerns (see lawful bases below).
Lawful bases
Under the UK GDPR, the lawful bases we rely on for processing personal data are as follows.
Article 6 basis (all personal data)
The primary lawful basis for processing personal data in connection with the Maths Coaching Pilot is:
Legitimate interests (Article 6(1)(f)) — processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Please see our Legitimate Interests Assessment for more information.
We may also rely on the following bases where specifically required:
- Legal obligation (Article 6(1)(c)) — where processing is necessary to comply with a legal requirement (for example, making a safeguarding disclosure to statutory authorities)
- Recognised legitimate interests (Article 6(1)(ea)) – where processing, including sharing information with others, is necessary to safeguard a child or another vulnerable individual.
- Vital interests (Article 6(1)(d)) — where processing is necessary to protect someone’s life (for example, sharing relevant information in a medical emergency)
Article 9 basis (special category data)
For the processing of SEND data, and where ethnicity data is provided (which is optional), we rely on substantial public interest (Article 9(2)(g)). For ethnicity data, we additionally obtain explicit consent (Article 9(2)(a)) as a supplementary safeguard.
You may withdraw your consent to the processing of your ethnicity data, or object to your SEND data being included in aggregate programme statistics, at any time by emailing hello@themathscoachingpilot.com. This will not affect your participation in the programme.
How long we keep your information
For unsuccessful candidates, personal data is deleted within 60 days of notification of the outcome of their application.
For enrolled pupils, records are retained until the end of the academic year in which the pupil turns 25 years of age. This retention period reflects the long-term nature of the programme and the importance of tracking outcomes through to and beyond university. It is actively reviewed and justified as part of our data protection obligations. Annex A below gives our justification for retaining data up to this point.
Audio and video recordings of sessions are kept for a shorter period than the rest of a pupil’s record, and are deleted automatically after 365 days. The whiteboard record, uploaded files and transcripts are kept up to the same point as other pupil records.
Family contact records are maintained only as long as they are a nominated contact for the programme, and deleted when the pupil leaves or completes the programme. School contact records are deleted when the pupil leaves the school or completes the programme. School profile data is retained as part of the pupil’s long-term record.
When data is no longer needed, it is securely deleted. A designated data owner within the programme team is responsible for carrying out regular deletion reviews in accordance with our Data Retention Policy.
Your data protection rights
Under UK data protection law, you have the following rights:
- Right of access — you have the right to ask us for copies of your (or your child’s) personal information. Where appropriate, consent from the child may be sought before release.
- Right to rectification — you have the right to ask us to correct information you think is inaccurate, or to complete information you think is incomplete.
- Right to erasure — you have the right to ask us to delete personal information in certain circumstances.
- Right to restriction of processing — you have the right to ask us to restrict the processing of personal information in certain circumstances.
- Right to object to processing — you have the right to object to the processing of personal information in certain circumstances.
- Right to data portability — you have the right to ask us to transfer personal information you have provided to us to another organisation, or to you, in certain circumstances.
- Right to withdraw consent — where we rely on consent as our lawful basis, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
We will respond to any request within one calendar month. We may extend this by a further two calendar months if the request is deemed to be complex.
To make a request, please contact us at hello@themathscoachingpilot.com.
Annex A: Retention Justification — Pupil Personal Data (Programme/Impact Tier)
This annex outlines the justification for retaining some pupil data until the end of the academic year in which the individual turns 25 years of age. It is adapted from the Retention Justification document used by Axiom Maths.
Purpose of Retention:
The Maths Coaching Pilot is a mathematics education programme whose core mission is to widen participation in mathematics at undergraduate and postgraduate level. To fulfil this mission, the Maths Coaching Pilot tracks long-term educational outcomes for programme participants from point of entry into the programme through to higher education.
The retention period reflects the organisation’s need to monitor and report on undergraduate and postgraduate outcomes as a measure of programme impact. An individual’s 25th birthday has been identified as the appropriate threshold at which longitudinal tracking concludes, on the basis that individuals entering postgraduate study at or after this age are classified as mature students. Outcomes for mature students are not counted within the Maths Coaching Pilot’s impact metrics, as the programme’s theory of change relates specifically to the pathway from secondary school mathematics into higher education pursued at the conventional age of entry.
Retention beyond the end of the programme is therefore necessary to evaluate whether participation in the Maths Coaching Pilot has contributed to undergraduate and postgraduate outcomes for each cohort, and to report on this to funders, the board of trustees, and the wider sector.
Lawful Basis: Legitimate Interests (Article 6(1)(f) UK GDPR)
Legitimate Interests Assessment Summary:
- Purpose test: The retention serves a clear and genuine organisational purpose — longitudinal impact evaluation — which is central to the Maths Coaching Pilot’s programme objectives, Axiom Maths’ charitable objects and funder accountability obligations.
- Necessity test: The retention period is limited to what is required to track outcomes to the point at which the individual’s participation is no longer attributable to the programme. Data is not retained beyond the end of the academic year in which the individual turns 25.
- Balancing test: The individuals concerned were enrolled as pupils in an educational programme and would reasonably expect their outcomes to be tracked by the organisation for programme evaluation purposes. This expectation is reinforced by the fact that individuals and their guardians are explicitly informed of this retention period in the Maths Coaching Pilot’s privacy notice. The data retained for impact purposes does not include special category data beyond what is necessary, and safeguarding-related fields are governed by a separate retention period under a distinct lawful basis.
Governance: This retention period and its underlying rationale have been reviewed and approved, in alignment with Axiom Maths data protection policy, by the Axiom Maths Board of Trustees.
Review Date: This justification should be reviewed annually or when there is a material change to the programme’s impact methodology or funder requirements.
How to complain
If you have concerns about how we use your personal information, please contact us in the first instance at hello@themathscoachingpilot.com.
If you are unhappy with our response to your complaint, you also have the right to complain to the Information Commissioner’s Office (ICO):
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Website: https://www.ico.org.uk
Any changes to this notice will appear on this page. The current version was last reviewed on 18/9/2026.