Markable — Privacy Policy

Version: 2.0 Effective date: 11 September 2026 Last reviewed: 11 September 2026 Previous versions: 1.9 (11 September 2026) · 1.8 (6 September 2026) · 1.7 (5 September 2026) · 1.6 (5 September 2026) · 1.5 (3 September 2026) · 1.4 (3 September 2026) · 1.3 (30 August 2026) · 1.2 (29 August 2026) · 1.1 (29 August 2026) · 1.0 (8 May 2026) Contact: support@markable.uk ICO Registration Number: C1917001

This policy explains how Markable handles personal data. It applies to teachers and schools using the Markable AI-assisted annotation and feedback platform. It is written to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003. It should be read alongside our Terms of Service, Cookie Policy, and (for schools) our Data Processing Agreement.

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1. Who we are

Markable is operated by Joanne Renwick (proprietor) as a sole trader. We are registered with the Information Commissioner's Office under registration number C1917001 and can be contacted at support@markable.uk.

ICO registration is required under the Data Protection (Charges and Information) Regulations 2018 and is a separate obligation from the lawful basis requirements under UK GDPR Article 6.

For the avoidance of doubt:

• When a school uses Markable to process scripts produced by its students, the school is the data controller and Markable is a data processor acting on the school's documented instructions under the Data Processing Agreement.
• When Markable processes information about teachers as account holders (registration, billing, support), Markable is a data controller for those purposes.

2. The personal data we process

Teacher account data (Markable as controller):

• Name and work email address
• School name
• Login credentials (passwords are stored as a salted hash)
• Authentication and access logs (IP address, device/browser identifier, timestamps)
• Multi-factor authentication metadata
• Billing information (processed by Stripe; Markable does not store full card details)
• Support correspondence

School data protection contact details (Markable as controller):

When a school accepts our Data Processing Agreement, its administrator gives us the name and email address of the person pupils should contact about their data. That person may not be a Markable user and may hold no account with us. We hold only their name and email address, and we obtained both from their school rather than from them.

We show these details to staff at their own school inside that school's Markable account. They are the contact a pupil is given for questions about their own data, so that a pupil does not have to go through the teacher who marked their work in order to raise something about it.

Lawful basis: legitimate interests, Article 6(1)(f). The interest is being able to give a pupil a route to raise a concern about their own data that does not run through their teacher. We cannot rely on contract here, because the person is not a party to any agreement with us.

Your right to object. You can object to this processing at any time under Article 21 — email support@markable.uk. We will pass your objection to your school and ask them to name a replacement contact. The appointment is the school's decision, not ours. We cannot simply remove the details: a school that has accepted the agreement must always have a named contact, so the school has to name someone else before the record can change. If your school does not act, tell us and we will raise it with them again; you can also complain to us under section 10 below, and to the Information Commissioner's Office.

Retention: for as long as the school holds an account with us and that person remains its named contact. If the school names someone else, the new details replace the old ones on the school's record. The change is recorded in our audit trail, which includes the previous name and email address, and which we keep for six years from the date of the record — see section 8.

Student-related data (school as controller, Markable as processor):

• Student reference codes or initials assigned by the teacher
• Pupils' full names, where a school records them
• The pupil's school email address, where the School enables pupil access to their own feedback
• The text content of student scripts uploaded for annotation
• The teacher's marks, comments, grades, and audit metadata associated with each script
• Any reply a pupil writes about their released feedback, and the class teacher's single reply to it

The Service is designed not to require, and the Terms of Service require teachers not to upload, full student names, addresses, dates of birth or other direct identifiers, or any special category data. There are two deliberate exceptions. Where a School enables pupil access it records each pupil's school email address, and where a School uploads a class roll it records each pupil's full name, which is how a teacher knows whose work is whose. That address is a direct identifier, and it is held because it is how a pupil proves which work is theirs when they sign in. Schools that do not enable pupil access hold no such address.

From 8 September 2026 a pupil may write a reply to the feedback on their own work and hand it in to their teacher, who may write one short reply back. A pupil's assessed work is their own writing too, and is described above; a reply differs in two ways that matter here. It is typed into Markable by the pupil rather than reaching us through a teacher's upload, and it is writing we invite — prompted, rather than incidental to a task set for the qualification. The box asks what a pupil makes of their feedback, not about the pupil, and a pupil who writes nothing is treated no differently. But because it is prompted, we do not claim to prevent a child writing something about themselves. Markable does not scan this text, does not analyse it, and does not act on its content. If what a pupil writes suggests that they or someone else is at risk, the School's own safeguarding procedure applies, as it does to anything else a pupil writes.

Individual teacher accounts operate differently. Teachers using Markable outside a school account identify pupils by initials or a reference code only, and no pupil name is held. Full names are held only where a School creates pupil records under a Data Processing Agreement. A pupil's own written work may nonetheless contain their name, and is treated as personal data accordingly.

Markable does not hold a pronoun for any pupil. Feedback refers to a pupil as they/them, so that it can be written without assuming gender, but nothing is collected from pupils, derived from any source, or stored.

3. Name detection at upload

When a script is uploaded, an automated scan runs in our processing environment and checks whether the work contains anything that looks like a real name — in the file name, in a heading, next to a label such as Name: or Candidate:, in the reference code entered by the teacher, or in the body of the work. It looks for name-shaped text only. It does not detect addresses, dates of birth, telephone numbers or any other kind of personal data, and it has no view on what the work says.

If it finds something, the teacher is shown where it was found and must open the work and check it before the analysis runs — either confirming the text is not a real name (a fictitious character or a party in a legal scenario, for example) or removing the script.

This scan runs in our processing environment and does not send script content to anyone else. What is sent for analysis, and to whom, is set out in sections 6 and 7.

4. Lawful bases for processing

ICO registration is not a lawful basis. Lawful basis is a separate UK GDPR Article 6 requirement, identified per processing activity below.

Markable as data controller (teacher account processing):

A Legitimate Interests Assessment is documented and available on request. Markable does not rely on legitimate interests for any processing of student data.

School as data controller (student script processing):

When a school uses Markable, the school determines its own lawful basis. Typical bases are:

• Public task (Article 6(1)(e)) — for state-funded schools and colleges;
• Legitimate interests (Article 6(1)(f)) — for independent schools.

Markable as processor follows the controller's documented instructions and does not select the lawful basis for the school.

5. Purposes of processing

We process personal data only:

1. To operate Markable and provide the Service;
2. To support teacher-led marking and feedback for assessment;
3. To produce student feedback reports authored or confirmed by teachers;
4. To record a pupil's response to the feedback on their work, and their teacher's reply to it;
5. To maintain the audit trail required for assessment integrity;
6. To meet our security, billing, tax, and statutory record-keeping obligations;
7. To respond to support enquiries and incident reports;
8. To improve the platform using aggregated, de-identified usage data only;
9. To comply with lawful requests from competent authorities.

Markable will not use student script content to train any AI model under any circumstances.

6. Recipients and sub-processors

Each sub-processor is bound by a written contract containing the obligations required by Article 28 UK GDPR.

Voice-to-text feature

The marking page includes an optional voice-to-text feature that allows teachers to dictate comments using their device microphone. This feature uses the Web Speech API built into your browser. Audio captured via this feature is transmitted to and processed by your browser provider — Google if you are using Chrome or Chromium-based browsers, or Apple if you are using Safari. Markable does not receive, store or have access to the audio recording at any point. Only the transcribed text is saved by Markable as part of your assessment record. Teachers who do not wish to use browser-based speech recognition may type their comments directly instead.

We will give schools at least 30 days' written notice before adding or replacing a sub-processor that processes student personal data.

7. International transfers

Where personal data is transferred outside the United Kingdom, Markable relies on:

• UK adequacy decisions where one applies;
• The UK International Data Transfer Agreement (IDTA);
• The European Commission Standard Contractual Clauses with the UK Addendum;
• The UK extension of the EU–US Data Privacy Framework where the recipient is certified.

A Transfer Risk Assessment is maintained and available to schools' DPOs on request. Teachers are required to identify pupils by initials or a reference code and to confirm before upload that scripts carry no direct identifiers. An automated scan alerts the teacher to text that looks like a real name, but it does not remove it and does not block the analysis. It detects name-shaped text only, not addresses, dates of birth or other identifiers. Where Markable holds a pupil's name, it replaces that name with their initials in the text before it is transmitted for analysis; where a script is a scanned or handwritten document analysed as an image, that replacement is not possible. Anthropic does not retain API-submitted content or use it to train its models. The safeguard relied on for this transfer is the contractual restriction on retention and training, not the removal of names.

8. Retention

Student script text and associated marks are retained until you delete them, or until your account has had no activity for 24 months. You can delete an individual script or an entire class's data at any time from your dashboard.

A pupil's reply to their feedback, and the teacher's reply to it, have no retention period of their own. They are deleted with the piece of work they belong to and cannot outlive it. Where a School asks for a single reply to be removed, it is removed together with the teacher's reply to it, leaving the work, the marks and the feedback untouched; what remains is a record that a removal occurred, holding no part of what was written.

If your account is inactive for 24 months, we archive the affected classes and email you three warnings before permanent deletion — 30 days, 14 days, and 1 day beforehand. Signing back in and reopening an archived class from your dashboard at any point before the deletion date stops it.

Cancelling your subscription does not itself trigger deletion of your account data — the 24-month inactivity policy above still applies to it. To request deletion sooner, email support@markable.uk and we will confirm once this has been completed.

The periods for the audit trail and for billing records are decided: six years from the date of the record, and seven years from the date of the transaction. Earlier versions of this policy gave periods that no mechanism carried out, which is why version 1.1 removed them rather than leave them standing. The audit trail is now deleted automatically at six years, by a job that runs weekly. The mechanism for billing records is being built and is not yet running, so until it does they are not automatically deleted. Every other row in this table describes what already happens.

Backups cover the application database (marks, feedback, annotations and account data); files you upload, including scripts, are stored separately and are not currently covered by these backups.

Teachers can delete individual scripts and entire class datasets at any time.

9. Security

Markable applies appropriate technical and organisational measures including:

• Encryption in transit (TLS 1.2+) and at rest (AES-256);
• Multi-factor authentication, available and strongly encouraged for all teacher accounts;
• Row-level security in the application database;
• Role-based, least-privilege access for staff;
• Logging of authentication and administrative actions;
• A documented patching cadence and dependency management programme;
• Daily backups with 7-day rolling retention (Point-in-Time Recovery not currently enabled);
• Vendor security review for all sub-processors;
• Documented incident response, including the 72-hour breach notification requirement under UK GDPR Article 33 and 24-hour notification to schools as Controllers.

10. Your rights

Under UK GDPR you have the rights to be informed; of access; to rectification; to erasure; to restrict processing; to data portability; to object; and rights related to automated decision-making (see section 11).

For data where the school is the controller (student-related data):

1. The data subject (or parent/guardian) sends the request to the school.
2. The school decides whether to comply and instructs Markable as processor.
3. Markable assists the school within 5 working days.

For data where Markable is the controller (teacher account data, and the school data protection contact details described in section 2):

Email support@markable.uk. We will acknowledge within 5 working days and respond substantively within 30 calendar days.

Complaining to us. Section 164A of the Data Protection Act 2018 gives you the right to complain to us directly if you believe we have infringed your data protection rights. Email support@markable.uk. Putting "Complaint" in the subject line helps us handle it quickly, but we will treat a complaint as a complaint however it reaches us. We will acknowledge it within 5 working days, look into it, and tell you the outcome within 30 calendar days — the same commitment we make for any other request about your data. Where the law allows us longer, we do not intend to take it. Teachers signed in to Markable can also use the Contact support form on the dashboard.

Complaining to the Commissioner. You can complain to the Information Commissioner's Office (ico.org.uk; 0303 123 1113). Complaining to us first is not required and does not affect that right.

11. Use of artificial intelligence and automated processing

This section provides the transparency disclosure required by UK GDPR Articles 13(2)(f), 14(2)(g), and 22.

What the AI does and does not do: The canonical description of Markable's AI analysis, developmental band references, the BTEC Applied Law Unit 2 coursework exception, teacher oversight and deterministic indicative exam grades is set out in the Compliance Statement.

Logic in plain English: A large language model is given the script text and the relevant mark scheme context. It generates annotations by predicting plausible commentary given that input. It is not a calculation. The same input may not always produce identical output.

Significance and consequences: AI annotations are not the determinative factor in any mark, comment, or grade. The teacher takes full responsibility. Markable does not engage in solely automated decision-making within the meaning of UK GDPR Article 22(1).

Limitations to be aware of:

• Large language models can produce confident-sounding output that is wrong;
• The same input can produce different output on different runs;
• Performance can vary across writing styles.

In-product transparency: A first-time-use disclosure is shown to teachers before their first upload, with a tick-box acknowledgement. A persistent indicator is shown on screens where AI is operating.

12. Children's data

Children hold accounts on Markable where a school has enabled pupil access. A pupil is invited by their teacher, claims an account using the school email address the school recorded — see section 2 — and signs in to read the feedback on their own work once their teacher has released it. A pupil sees only their own work.

Since 8 September 2026 a pupil may also write a reply to that feedback and hand it in to their teacher, who may write one short reply back. While a reply is unsubmitted, nobody at the pupil's school can read it — not their teacher — and no setting can change that. Once handed in it cannot be edited or withdrawn by the pupil, and after the teacher's single reply neither party can alter anything. The exchange is not marked, contributes to no grade, forms no part of any assessment of the pupil, and is never transmitted outside the United Kingdom or used for AI analysis. Where a teacher downloads or prints the finalised report on a piece of work, the exchange appears in it, in the same way the feedback does.

A pupil who has handed in a reply and wants it taken down can ask, through the data protection contact their school has named, without telling the teacher who read it. It will be removed, together with the teacher's reply to it, and without affecting their work or their marks. A copy that has already been downloaded or printed is outside our control, as with any document.

Where data we process concerns children, we apply the principles of the ICO Age Appropriate Design Code: data minimisation, no profiling for advertising, no nudge techniques, default to most protective settings, and age-appropriate transparency through the Student/Parent Privacy Notice template provided to schools.

13. How to raise a concern

This section is about the AI's behaviour, fairness or accuracy — a concern that our marking support has got something wrong. If your concern is about how we handle personal data, that is a data protection complaint: use section 10 above, not this route.

Email support@markable.uk. Putting "Compliance Concern" in the subject line helps us route it quickly, but we will treat a concern as a concern however it reaches us. We will acknowledge within 5 working days and respond substantively within 20 working days.

Why this is slower than a data protection complaint, deliberately. A concern about the AI's marking often needs your school's own assessment appeals process to run alongside it, and it carries no statutory clock. A data protection complaint does — section 164A of the Data Protection Act 2018 — which is why section 10 commits to a faster outcome. The two timescales differ because the two things differ, not because one has been overlooked.

Marking disputes are not handled by Markable; they are a matter for the school's normal assessment appeals procedure.

If you remain dissatisfied, escalation routes include the ICO (data protection), Ofqual (qualification regulation), the relevant Local Authority Designated Officer (safeguarding), and the relevant awarding organisation.

14. Cookies

Markable uses only strictly necessary cookies for authentication, session management, and security, and a privacy-preserving analytics product configured not to set tracking cookies. We do not use third-party advertising cookies. See our Cookie Policy for detail.

15. Changes to this policy

Material changes will be notified to teachers (and via the school's account contact, to the school) by email at least 14 days before they take effect. Continued use after a change takes effect constitutes acceptance.

16. Contact

Markable (sole trader, proprietor: Joanne Renwick) support@markable.uk