Tutor Privacy Notice

1. Who this notice is for

This notice is for people who apply to tutor with us and for tutors we engage. If you are a parent, guardian or student, the notice that applies to you is our main privacy policy.

Tutors are self-employed. We do not employ tutors and this is not an employment notice: we enter into a mutual freelance agreement with you, you invoice us for the work you deliver, and you remain responsible for your own tax and social insurance in the country you work from.

We are Sophyra Limited, a company registered in Ireland under company number 817595, trading as Sophyra Tutors under registered business name number 790687, with registered office at First Floor, Penrose 2, Penrose Dock, Cork, T23 YY09, Ireland. We are the controller of the personal data described here, which means we decide why and how it is used.

For anything in this notice, contact privacy@sophyra.ie.

2. What we collect about you

3. Where we get it

Most of it comes from you, when you apply, when we agree terms with you, and as you work through the Portal. We also receive information from your referees, from vetting and identity-checking providers, from awarding bodies where we verify a qualification, and from public professional sources.

4. Why we use it, and our legal basis

Where we rely on legitimate interests you may ask us for information about the balancing we carried out.

5. Vetting and criminal-record information

We ask for a DBS check or the equivalent police clearance for your country because our students are children. This is information the law treats as needing extra protection, so we handle it under restricted procedures: access is limited to the people who need it for recruitment or safeguarding decisions, we record the fact, date and outcome of a check rather than retaining unnecessary detail, and we do not use it for any unrelated purpose.

You must tell us promptly if anything changes that could affect your suitability to work with children. That obligation is in your agreement with us, and it exists so that we can act quickly, not to catch you out.

6. Lesson recordings

Lessons are recorded automatically, and you appear in those recordings. This is a safeguarding measure and it protects you as much as the student: where an allegation is made, a recording is the evidence of what actually happened.

Recording exists for safeguarding and for nothing else. Recordings are not used to monitor or appraise your teaching, and they are not watched as a matter of course. Access is restricted to authorised personnel dealing with a safeguarding or welfare matter, or with a legal claim in which a recording is the evidence, and every viewing is logged. Routine recordings are kept for 90 days and then deleted, unless a particular recording is subject to a documented hold.

Lessons are not transcribed. Nothing said in a lesson is turned into text. Recordings are never sent to an artificial-intelligence system and are never used to produce progress reports.

7. Artificial intelligence

We use an AI assistant to draft parent progress reports and, in beta, tutor lesson plans. The draft is grounded in your uploaded lesson plan, your own lesson notes and the examination-board specification recorded for the student, and you review, edit and approve every progress report before a parent sees it.

Your personnel information is never sent to an AI model. Your address, vetting details, references, certificates and contract records are outside the parts of the system any AI feature can reach. The information the model sees is limited to the examination-board specification, your lesson plan and your teaching notes, with students identified by first name only. We do not use recordings or your materials to train AI models.

8. Who we share it with

We share your information only where we need to: with vetting, identity and reference providers; with payment, accounting, hosting, classroom and security providers acting under contract with us; with professional advisers, insurers and auditors bound by confidentiality; with safeguarding bodies, regulators, courts and law-enforcement authorities where the law requires or permits it; and, in a genuine corporate transaction, with a buyer or successor under confidentiality protections.

Students and parents are told your first name and your professional profile. They are not given your address, your personal contact details or your vetting records.

9. How long we keep it

10. If you work outside Ireland

Tutors work from a number of countries. Where you are inside the European Economic Area, the GDPR applies and no additional transfer mechanism is needed. Where you are in a country covered by an adequacy decision, we rely on that decision. Where you are in a country without one, we put the European Commission's standard contractual clauses in place, assess the transfer and apply additional safeguards before your access is enabled.

You must access student information only from the country we have approved in writing, and tell us before you travel or work from anywhere else. This is a data-protection requirement, not an administrative preference: working from an unapproved country can make the transfer unlawful.

11. Your rights

Subject to the conditions and exceptions in the law, you may ask us for a copy of your personal data, ask us to correct it, ask us to delete it, ask us to restrict how we use it, object to our use of it where we rely on legitimate interests, and ask for certain data in a portable format. Where we rely on your consent, you may withdraw it at any time without affecting what we did lawfully before.

We do not make decisions about you by automated means alone that produce legal or similarly significant effects.

To exercise a right, contact privacy@sophyra.ie. We may ask for proportionate information to verify who you are. There is normally no charge.

12. Complaints

Please contact us first at privacy@sophyra.ie so that we can try to resolve the matter. This does not affect your right to complain to a data-protection authority directly. Our lead authority is the Data Protection Commission in Ireland, at dataprotection.ie. You may also complain to the supervisory authority in the country where you live, where you work, or where you believe the issue arose.

For a safeguarding concern, use safeguarding@sophyratutors.com rather than the privacy address, so that it reaches the right people immediately.

13. Changes

We will update this notice when what we do changes. The version date is at the top. Where a change materially affects you, we will bring it to your attention through the Portal or by email.