Privacy Notice for Parents and Families
Divergent Learning Community CIC
Last Updated: January 2026
Introduction
Divergent Learning Community (“DLC,” “we,” “us,” or “our”) is committed to protecting the privacy and personal data of the children and families we support. This Privacy Notice explains how we collect, use, store, and protect your information in compliance with UK GDPR and the Data Protection Act 2018.
Who We Are
Data Controller: Claudia Celi, Founder
Organisation: Divergent Learning Community CIC
Contact Email: DivergentLearningCommunity@outlook.com
What Information We Collect
Information About Your Child
We collect and process the following types of information:
Basic Information:
- Full name, date of birth, current year group
- Current school (if applicable)
Educational Information:
- School reports and teacher assessments
- Educational psychologist reports
- Special educational needs assessments (EHC plans, IEPs)
- Learning profiles and progress reports
- Health and Support Information (special category data):
- Diagnosed conditions affecting learning (e.g., ADHD, dyslexia, autism)
- Speech and language therapy assessments
- Occupational therapy reports
- Medical reports relevant to education
- Information About Parents/Carers
- Full name and contact details
- Relationship to child
- Address, phone number, email
- Why We Collect This Information (Legal Basis)
- We process your child’s data on the following legal bases:
Consent: You give us explicit permission to process educational documents and create cognitive profiles
Legitimate Interests: To provide educational support services you’ve requested
Special Category Data: We process health and educational needs data with your explicit consent and because it’s necessary for educational purposes
How We Use Your Information
We use your child’s information to:
- Create Cognitive Profiles – Analyse educational documents to identify your child’s unique learning strengths and challenges
- Deliver Educational Support – Tailor learning programs to your child’s cognitive profile
- Monitor Progress – Track your child’s development and adjust support as needed
- Research (with separate consent) – Improve our understanding of neurodivergent learning patterns
- Document Processing and AI Use
What Happens to Documents you Provide:
Receipt – We receive and securely store your documents
Redaction – We remove all personal identifying information (names, addresses, dates of birth, etc.)
AI Analysis – Redacted documents are analysed using Claude AI to identify cognitive patterns
Profile Creation – A human analyst reviews the AI analysis and creates your child’s strengths-based profile
Destruction – Original documents are securely destroyed within 30 days
Important: Only redacted (anonymised) versions of documents are processed by AI. Personal information is never shared with AI systems.
How We Protect Your Information
We take data security seriously:
Technical Measures:
- Encrypted storage of all data
- Secure file transfer protocols
- Password-protected systems
- Regular security updates
Organisational Measures:
- Staff training on data protection
- Access controls (staff only see data they need)
- Secure physical storage
- Regular audits and reviews
How Long We Keep Information:
- Original Documents: Destroyed within 30 days of profile completion
- Redacted Documents: Retained until your child turns 25 (education sector standard)
- Cognitive Profiles: Kept whilst your child is enrolled + 2 years
- Destruction Logs: Retained for 7 years for audit purposes
You can request earlier deletion at any time by withdrawing consent.
Special Protections for Children
Children are entitled to enhanced data protection:
- All processing requires parental consent
- Age-appropriate privacy information provided to children
- Enhanced security for children’s data
- Regular reviews of data necessity
Safeguarding
Your child’s safety is our highest priority.
If we identify safeguarding concerns whilst reviewing documents, we have a legal duty to report these to our Designated Safeguarding Lead and potentially to children’s social care or police.
In cases of risk to a child, safeguarding obligations override data protection requirements. We may share information without consent where necessary to protect a child from harm.
Your Rights Under UK GDPR
You and your child have the following rights:
Right of Access – Request to see what data we hold about your child
Right to Rectification – Request correction of inaccurate information
Right to Erasure – Request deletion of your child’s data (subject to legal retention requirements)
Right to Restrict Processing – Request we limit how we use data
Right to Data Portability – Receive your child’s data in a portable format
Right to Object – Object to certain types of processing
Right to Withdraw Consent – Withdraw consent at any time
To exercise any of these rights, contact us at DivergentLearningCommunity@outlook.com. We will respond within 30 days.
Data Sharing
We do not sell or share your child’s data with third parties for marketing purposes.
We may share information only in these limited circumstances:
With Your Consent:
With educational professionals involved in your child’s support (with explicit permission)
Legal Obligations:
- Safeguarding concerns (children’s social care, police)
- Court orders or legal proceedings
- ICO investigations
Service Providers:
- Claude AI (only processes redacted, anonymised documents)
- Secure cloud storage providers (all UK-based, GDPR-compliant)
- Cookies and Website Data
- Our website uses essential cookies only to ensure the site functions properly. We do not use tracking or marketing cookies. You can disable cookies in your browser settings.
Changes to This Privacy Notice
We review this Privacy Notice annually. If we make significant changes, we will notify you by email and post the updated notice on our website.
Version History
Version 1.0 – January 2026 – Initial publication
Your Right to Complain
If you’re unhappy with how we’ve handled your data, you can:
Contact us directly at: DivergentLearningCommunity@outlook.com
Complain to the ICO:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk
Questions?
If you have any questions about this Privacy Notice or how we handle your data, please contact:
Claudia Celi, Data Controller
Email: DivergentLearningCommunity@outlook.com
Post (Registered Office):
DIVERGENT LEARNING COMMUNITY CIC
71-75 Shelton Street
Covent Garden
London
WC2H 9JQ
We’re committed to transparency and protecting your family’s privacy. Thank you for trusting DLC with your child’s learning journey.