Privacy policy.

Last updated: 23 May 2026

Who we are

ClearFrame Education ("ClearFrame", "we", "us") is an advisory consultancy based in South London. We provide advisory consultancy to international schools on AI strategy, governance, data, leadership, and inspection readiness.

For the purposes of UK GDPR and the Data Protection Act 2018, ClearFrame Education is the data controller for personal data collected through this website and our consultancy services.

The person responsible for data protection at ClearFrame is the founder, Rod Boswell. Queries about data protection can be sent to hello@clearframeeducation.com.

What personal data we collect

We collect only what we need to do our work. In practice, that means:

From this website

• Information you choose to send us by email — typically your name, school, role, and a description of what you're looking for.
• Basic technical information that any web server collects, such as the time of a visit and the page requested. This is held by our hosting provider (GoDaddy) and is not used for tracking or profiling.

During an engagement

• Names, roles, and contact details of people we work with at the client school.
• Documents, data, and other materials that the school shares with us for the purposes of the engagement.
• Notes, drafts, and analytical outputs that we produce in the course of the work.

Why we hold it and on what legal basis

We hold personal data for the following purposes, under the following lawful bases:

• To respond to enquiries. Legitimate interest — we cannot reply to a message without holding the message.
• To deliver consultancy work. Contract — performance of the engagement we have agreed with the school.
• To meet legal obligations. For example, retaining records required for tax purposes.

Who we share it with

We do not sell personal data, and we do not share it with third parties for marketing purposes. We do not use personal data for advertising. We do not transfer client materials to AI tools without explicit prior agreement on which tools, what data, and on what terms.

The only third parties who routinely process data on our behalf are our IT and hosting providers, professional advisers (such as accountants), and — only when a school instructs us to use them — specified AI tools or platforms in the course of consultancy work. Any such arrangements are governed by written agreements.

International transfers

Some of our work involves schools based outside the UK. Where personal data is transferred internationally, we rely on adequacy decisions, Standard Contractual Clauses, or other appropriate safeguards under UK GDPR. Specific arrangements are documented in each engagement contract.

How long we keep it

Enquiries that don't lead to engagement are kept for up to 12 months, then deleted. Records relating to an engagement are kept for seven years after the engagement ends, in line with standard professional and tax-record retention. Anonymised analytical work may be kept indefinitely for the purpose of refining our methods.

Your rights

Under UK GDPR you have the right to:

• Be informed about how your data is used (this policy).
• Access the personal data we hold about you.
• Have inaccurate data corrected.
• Request deletion of your data ("right to be forgotten"), subject to other legal obligations.
• Restrict or object to certain processing.
• Receive your data in a portable format.

To exercise any of these rights, email hello@clearframeeducation.com. We aim to respond within five working days and in any case within the statutory one month.

Complaints

If you are unhappy with how we have handled your personal data, please raise it with us first. You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority: ico.org.uk.

Changes to this policy

We will update this policy when our practices change. The "last updated" date at the top of this page indicates when the most recent revision was made.