This policy explains how personal information is handled when Total Track is used. Total Track is provided by Malachi Burnett trading as Wiizard Software. Contact: [email protected] or wiizardsoftware.uk.
Total Track is available through total-track.uk and organisation subdomains such as organisation_name.total-track.uk.
Who Is Responsible For The Data
Each organisation or provision using Total Track is the controller for the records it creates and manages. The organisation decides why information is recorded, who has access, how long it is kept, and how it fits with its own safeguarding, education, consent and data protection duties.
Wiizard Software provides, hosts, maintains and supports the platform, and acts as the organisation's processor for those records. It processes them only on the organisation's documented instructions and does not use them for its own purposes.
Wiizard Software is a separate controller for limited business and operational information: enquiries, onboarding correspondence, support requests, invoices, account administration, and the security and system logs needed to run the service safely.
Data Protection Contact
The data protection contact at Wiizard Software is Malachi Burnett, [email protected].
Each organisation should give its own users the contact details of its own data protection lead, which will usually be its data protection officer.
Information Total Track Handles
- Young person profile details, including name, nickname, date of birth and pronouns.
- Celebration, session note, milestone, termly target and EHCP outcome records.
- Medical and accident logs, including injury descriptions, first aid given, and medication name, dose, who administered it and who witnessed it.
- Consent records, including photo consent level and consent alert tags such as allergies or first aid consent.
- Staff notes about a young person, such as interests, regulation strategies and known triggers.
- Photographs and other media uploaded by authorised staff.
- Parent/carer names, contact details, account details, and links to young people.
- Staff and admin names, contact details, account details, roles and permissions.
- Account setup, password reset, email verification, login email code and protected admin action records.
- System logs and security events needed to protect and operate the service.
- Data export files created when an organisation exports its records.
- Business contact, onboarding, support, pricing and invoicing information.
Special category data
Medical and accident logs, medication records, allergy and other health-related consent tags, and information about a young person's SEND or EHCP status are special category data under Article 9 of the UK GDPR. They are treated as the most sensitive information in the platform.
Why Information Is Used
Information is used to provide the platform, enforce permissions, share appropriate records with linked parent/carers, manage accounts and security checks, provide exports, support organisations, handle onboarding and invoicing, protect the service, and meet legal, safeguarding and contractual duties.
Wiizard Software does not sell personal information, does not use Total Track to send advertising to young people, parent/carers or staff, and includes no third-party advertising or analytics trackers.
Total Track does not carry out automated decision-making or profiling that produces legal or similarly significant effects.
Lawful Basis
For records held by an organisation, the organisation decides and records its own lawful basis as controller. In an education or alternative provision setting this is usually Article 6(1)(e) public task for maintained schools, academies and local authority provision, or Article 6(1)(f) legitimate interests for independent providers; Article 6(1)(c) legal obligation for safeguarding and statutory reporting; and Article 6(1)(a) consent for optional activities, most notably sharing photographs.
For special category data — medical logs, medication, allergies and SEND or EHCP information — an Article 9 condition is also needed. The conditions most likely to apply are Article 9(2)(g) substantial public interest read with Schedule 1 Part 2 paragraph 18 of the Data Protection Act 2018 (safeguarding of children and individuals at risk) or paragraph 6 (statutory and government purposes); Article 9(2)(c) vital interests in an emergency; or Article 9(2)(h) health or social care purposes.
Most Schedule 1 conditions, including paragraph 18, require the controller to have an Appropriate Policy Document in place. Each organisation using Total Track must have one covering its use of the platform. Wiizard Software provides a template as part of onboarding.
Consent for photographs must be freely given, specific, informed, and as easy to withdraw as it was to give. An organisation must not make access to provision conditional on photo consent, and must act on a withdrawal. Photo sharing is off by default and has to be positively turned on.
For Wiizard Software's own business records, the lawful basis is contract, legitimate interests in running and securing the service, or legal obligation for accounting records.
Who Consents For The Young Person
Who can give consent, and who can exercise rights, depends on the young person's age and understanding, not only on who their parent or carer is.
- For a young person not yet old enough to decide for themselves, a person with parental responsibility exercises their rights on their behalf.
- A young person who is old enough and has sufficient understanding can exercise their own rights. In an education context this is commonly treated as around age 12, but it is a question of the individual's understanding, not a fixed age.
- From the end of compulsory school age, a young person with an EHCP holds the rights in the SEND system themselves, including the right to their own information, unless they lack capacity. Where Total Track is used for post-16 provision, the organisation must confirm who holds those rights before giving a parent/carer account access, and must be able to remove that access if the young person asks.
Each organisation decides this for each young person and configures parent/carer links accordingly.
Access And Sharing
Access is controlled by account role, and every permission decision is enforced by the server.
- Staff can access young person records needed for their work.
- Admins can manage platform settings, users and high-risk administrative actions.
- Parent/carers can only access young people linked to their account, and cannot see draft records.
- Photographs are checked against stored photo consent on every request. A parent/carer sees a photo only where the entry belongs to their linked young person and every young person in that photo has photo consent.
- Media files are served only to an authenticated session and only after that visibility check.
The organisation decides which staff and parent/carer accounts are created and linked.
What Total Track Sends By Email
Email is used only as a prompt to sign in. Record content is deliberately kept out of it.
- Parent/carer notifications name the young person, the type of entry and the date, and link to Total Track. They do not contain the wording of a celebration or session note, and they do not contain photographs.
- Medical and accident notifications to parent/carers and to named staff give the young person's name, the type of record and when it happened. They do not contain the injury description, the medication or the dose.
- Account, security and approval emails contain only what that action needs, such as a one-time link or a login code.
Health information is therefore not transmitted to the email provider.
External Providers And International Transfers
| Provider | Purpose | Data involved |
|---|---|---|
| Resend | Sending transactional email | Recipient name and email address, subject line, and the limited email content described above |
| Cloudflare | Tunnel, domain routing and network protection | IP addresses, connection metadata and requested URLs |
Both providers involve transfers of personal data outside the United Kingdom. Those transfers are made under the transfer safeguards set out in each provider's data processing terms, and Wiizard Software keeps a transfer risk assessment for each one. The safeguards relied on are listed in the Data Processing Agreement and are available to organisations on request.
Wiizard Software will tell organisations before adding or replacing a provider that processes their data, and organisations may object. Total Track does not use third-party advertising or analytics trackers.
Security
Total Track is built so that permission decisions cannot be bypassed from the browser, and so that the most sensitive information stays inside the platform.
- Every permission decision is enforced by the server. Checks in the browser are treated as convenience only.
- Photo visibility is recalculated against stored consent on every request, including for direct media requests.
- Passwords are salted and hashed. Plain-text passwords are not stored.
- Traffic between users and the platform is encrypted in transit.
- Login attempts are rate-limited and accounts lock temporarily after repeated failures.
- Organisations can require an email login code at sign-in for admins, all staff or all users.
- High-risk administrative actions require confirmation by the person requesting them and, where another admin account is active, approval from a second admin. All admins are told the outcome.
- Exports never contain password hashes or single-use security tokens.
- Off-site backups are kept under the same access controls. Up to 30 daily backups are retained; older backups are deleted.
A fuller description of the technical and organisational measures is available to organisations on request, under a confidentiality agreement.
Retention And Deletion
| Record | Retention |
|---|---|
| Young person records while the young person is active | Kept until the young person is archived by the organisation |
| Archived young person records | Deleted after the organisation's configured archive retention period, from one term up to five years |
| Parent/carer and staff accounts | Kept while the account is active; removed on the organisation's instruction |
| Data export files | Deleted when the download link expires |
| Record that a deletion happened | Kept indefinitely for accountability, holding dates only — not the young person's name or any contact details |
| Business, support and invoicing records | Six years for accounting records; otherwise only as long as needed |
| Backups | Up to 30 daily copies |
How deletion of an archived young person works
- When an archived young person reaches the configured retention point, the organisation's admins are emailed to review the deletion. They can confirm it, restore the young person, or wait one more week.
- Once an admin confirms, the records are deleted.
- Deletion removes the young person's profile, celebrations, session notes, medical and accident logs, targets, outcomes, consent record, notifications and photographs from the live system.
Total Track does not send copies of a young person's record to anyone as part of deletion. If a copy is needed, the organisation exports it before confirming, and the organisation decides who may receive it. This is deliberate: the organisation knows the young person's circumstances, whether contact details are current, and whether the young person now holds their own rights.
A record that the deletion happened is kept for accountability. It holds the dates of the request, review and deletion, but not the young person's name or any contact details.
Deleted information may remain in backups until the backup retention period has passed, which is up to 30 days.
A photograph that also features another young person, and is attached to that other young person's entry, is not deleted by this process, because it forms part of that other young person's record.
Cookies And Local Storage
Total Track sets one strictly necessary cookie to keep you signed in. It is not used for tracking or advertising, and blocking it stops the platform from working. The platform also stores small amounts of information in your browser for convenience, such as remembering an upload in progress.
No cookie banner is used because Total Track uses no non-essential cookies. This is consistent with regulation 6(4) of PECR, which exempts cookies strictly necessary to provide a service the user has requested.
Your Rights
Under UK data protection law you have the right to be told how your information is used; to get a copy of it; to have inaccurate information corrected; to ask for it to be deleted; to ask for processing to be restricted; to object to certain uses; to receive your information in a portable format where the processing is based on consent or contract and is automated; and to complain to the Information Commissioner's Office.
How to exercise them. Because the organisation is the controller for its Total Track records, requests about a young person, staff member or parent/carer should go to the organisation first. The organisation must respond within one month. That can be extended by two further months for complex requests, and the organisation must tell you within the first month if it is extending. There is normally no charge.
Wiizard Software will support an organisation with any request that needs platform action, such as an export, a correction or a deletion. For information Wiizard Software controls directly, contact [email protected].
Complaints. If you are unhappy with how a request has been handled you can complain to the organisation, to Wiizard Software, or to the Information Commissioner's Office: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Helpline 0303 123 1113. ico.org.uk/make-a-complaint. Complaining to the ICO does not affect any other legal remedy available to you.
Children And Young People
Total Track is designed for use by staff and by parent/carers. Young people do not have accounts.
Wiizard Software takes account of the ICO's Age Appropriate Design Code in how the platform handles children's data, including data minimisation, no profiling, no advertising, and photo sharing that is off by default.
Each organisation should complete a data protection impact assessment before using Total Track, because the platform processes children's data and special category data. Wiizard Software provides a template and will assist with it.
Safeguarding, Legal Requests And Emergencies
Information may be disclosed where required by law, court order, safeguarding duty, emergency need, or a valid instruction from the organisation controlling the record.
Total Track is not an emergency reporting system. Urgent safeguarding, welfare or medical concerns must be handled through the organisation's normal urgent procedures.
Changes To This Policy
This policy may be updated as Total Track changes. The version number and effective date at the top will change, superseded versions are kept available on request, and organisations will be told about material changes before they take effect.
Contact
Malachi Burnett trading as Wiizard Software
Email: [email protected]
Website: wiizardsoftware.uk
For records controlled by an organisation, contact that organisation first.