Academic Intelligence

Breach Notification Process

Version: 1.0
Effective date: 12 May 2026
Website: checkitquick.academicintelligence.co.uk
Service provider: Academic Intelligence Ltd
Registered office: 60 Viceroy Court, 36 Dingwall Road, Croydon, England, CR0 2NG
Company number: 17204358 (Companies House)
Contact email: [email protected]
Privacy contact: [email protected]
Security and incident contact: [email protected] (include Security incident in the subject for urgent incidents)
Emergency contact: use the address above with a clear subject line; schools with a contractual out-of-hours path should follow that arrangement
Hosting location: London, United Kingdom

1. Purpose

This Breach Notification Process explains how Academic Intelligence Ltd, referred to as we, us or our, identifies, investigates, manages and notifies security incidents and personal data breaches relating to checkitquick.academicintelligence.co.uk, referred to as the Service.

The purpose of this process is to:

1.1 How to report a suspected incident to us

Email [email protected] and include Security incident at the beginning of the subject line so we can prioritise triage.

We monitor this mailbox during normal UK business hours (Monday to Friday, excluding English public holidays, unless we agree otherwise with you in writing). We aim to send an initial acknowledgement within one UK business day for schools with a current paid subscription, and within two UK business days for other correspondents. Complex investigations take longer; acknowledgement does not confirm that a breach has occurred.

Schools with a separate contractual emergency or out-of-hours escalation path should follow that route in parallel where appropriate.

Please include, where it is safe and lawful to do so:

Do not include API secrets, passwords, unnecessary copies of pupil records, or other highly sensitive material in ordinary email. If we need secure transfer, we will agree an appropriate method.

2. Scope

This process applies to actual or suspected incidents affecting:

This process covers both:

3. Roles and Responsibilities

3.1 Schools as Controllers

For parent, pupil and school personal data processed through the Service, the school, academy trust, college or other educational organisation is normally the controller.

The school is normally responsible for deciding:

3.2 Our Role as Processor

For parent, pupil and school personal data processed through the Service, we are normally the processor.

Where we become aware of a personal data breach affecting personal data processed on behalf of a school, we will notify the affected school without undue delay.

Our role is to:

3.3 Our Role as Controller

We may act as controller for our own business, security, support, billing, website, administrator and customer relationship data.

Where a breach affects personal data for which we are controller, we will assess whether we need to notify the ICO and/or affected individuals.

4. Definitions

4.1 Security Incident

A security incident is any actual or suspected event that may affect the confidentiality, integrity or availability of the Service, systems, credentials or data.

Examples include:

A security incident is not always a personal data breach.

4.2 Personal Data Breach

A personal data breach is a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

Examples include:

5. Breach Notification Principles

We follow these principles:

The ICO advises organisations to start a breach log as soon as a possible breach is discovered, even if it may not ultimately be reportable.

6. Breach Reporting Contact

Actual or suspected security incidents or personal data breaches should be reported to:

Reports should include, where available:

Do not send API secrets, passwords, unnecessary personal data or large datasets by ordinary email.

7. Incident Detection Sources

Incidents may be detected through:

8. Immediate Response Steps

When an incident is reported or detected, we will take the following steps.

8.1 Log the Incident

We will create an internal incident record containing:

8.2 Triage the Incident

We will assess:

8.3 Contain the Incident

Containment steps may include:

8.4 Preserve Evidence

We will preserve relevant evidence where reasonably possible, including:

Evidence will be protected and access will be limited to authorised personnel.

9. Severity Classification

Incidents will be classified using the following guide. Severity may change as more information becomes available.

Severity Description Examples
Critical Confirmed or highly likely serious compromise affecting personal data, API secrets, cross-school access or system integrity Cross-school data exposure; stolen API secrets; unauthorised access to parent/pupil records; unauthorised writes to iSAMS
High Significant suspected compromise or serious vulnerability with realistic risk to personal data or credentials Suspected admin account takeover; exposed logs containing personal data; vulnerable endpoint allowing data access
Medium Limited incident with possible but unconfirmed data impact Misconfiguration; limited support disclosure; suspicious activity requiring investigation
Low Security issue with no apparent personal data impact Minor vulnerability; failed login spike; harmless misconfiguration

10. Assessment of Personal Data Impact

We will assess whether the incident involved:

We will also assess whether the incident caused or may have caused:

11. Notification to Schools

11.1 When We Notify Schools

Where we become aware of a personal data breach affecting personal data processed on behalf of a school, we will notify the affected school without undue delay.

We may also notify a school where:

11.2 How We Notify Schools

Notification may be made by:

For serious incidents, we will use reasonable efforts to contact the school promptly using available contact details.

11.3 What We Include in the Initial Notification

The initial notification may include:

11.4 Phased Updates

Not all facts may be available immediately.

We may provide information in phases as the investigation progresses.

Updates may include:

The ICO recognises that full details may not be available within the initial reporting period and that further information can be provided as soon as possible.

12. Notification to the ICO

12.1 Where We Are Processor

Where we are processor for school-controlled personal data, the school is normally responsible for deciding whether to notify the ICO.

We will provide reasonable assistance to the school by supplying available information about the incident.

12.2 Where We Are Controller

Where we are controller for affected personal data, we will assess whether the breach is notifiable to the ICO.

A breach is generally notifiable to the ICO if it is likely to result in a risk to the rights and freedoms of individuals.

If notification is required, we will notify the ICO without undue delay and, where feasible, within 72 hours of becoming aware of the breach. The ICO says that if notification is later than 72 hours, reasons for the delay must be given.

12.3 Information for ICO Notification

Where we notify the ICO, or assist a school with notification, relevant information may include:

13. Notification to Affected Individuals

13.1 Where the School Is Controller

Where a breach affects school-controlled parent, pupil or school personal data, the school is normally responsible for deciding whether affected individuals must be told.

Affected individuals may include:

We will assist the school by providing available information about:

13.2 Where We Are Controller

Where we are controller and the breach is likely to result in a high risk to individuals, we will communicate the breach to affected individuals without undue delay, unless an exemption or alternative measure applies.

The communication may include:

14. Special Considerations for Schools and Children’s Data

Because the Service may process children’s data, incidents involving pupil data must be treated with particular care.

Risk assessment should consider:

Where safeguarding concerns may exist, the school should follow its own safeguarding procedures.

15. API Credential Breach Procedure

Because the Service stores API keys, secrets and integration credentials, suspected credential compromise is treated seriously.

15.1 Examples of Credential Incidents

Credential incidents include:

15.2 Immediate Actions

Where API credential compromise is suspected, we may:

15.3 School Actions

The affected school may need to:

16. iSAMS Record Integrity Incident Procedure

Where an incident may have caused incorrect, unauthorised or unintended updates to iSAMS, we will:

The school remains responsible for checking and correcting its own iSAMS records unless otherwise agreed.

17. Cross-School Access Incident Procedure

A suspected cross-school access incident is treated as Critical unless clearly shown otherwise.

Examples include:

Immediate actions may include:

18. Subprocessor Breach Procedure

If a subprocessor informs us of a security incident or personal data breach, we will:

Where the subprocessor breach affects personal data for which a school is controller, the school will normally decide whether ICO or individual notification is required.

19. Internal Escalation

The following incidents must be escalated immediately to the Director, Security Lead or Data Protection Lead (or the person covering that role):

20. Internal Incident Team

For significant incidents, we may form an incident team including:

The incident lead is responsible for coordinating investigation, containment, communication, documentation and closure.

21. Breach Timeline

The following timeline should be followed where practicable.

21.1 First Hour After Discovery

21.2 First 24 Hours

21.3 24 to 72 Hours

21.4 After 72 Hours

22. Risk Assessment Factors

When assessing risk, we consider:

23. Breach Record Keeping

We will keep an internal record of incidents and personal data breaches.

Records may include:

Records will be kept for six years unless a longer or shorter period is required by law, contract or legitimate business need.

24. Communications Rules

During an incident:

25. Notification Template to School

Use this template for initial school notification.

Subject: Security incident notification — checkitquick.academicintelligence.co.uk

Dear [School contact name],

We are contacting you about a security incident affecting checkitquick.academicintelligence.co.uk.

What happened

[Brief factual summary. Say what is known and what is still being investigated.]

Data or systems potentially affected

The incident may involve:

Actions we have taken

Recommended actions for the school

We recommend that you:

Next update

We will provide further information [when available / by date/time if known].

Please contact us at [email protected] if you need further information.

Kind regards,
[Name]
[Role]
Academic Intelligence Ltd

26. Notification Template to ICO Where We Are Controller

Use this only where we are controller for the affected personal data.

27. Notification Template to Affected Individuals Where We Are Controller

Use this only where we are controller and individual notification is required.

Subject: Important information about your personal data

Dear [Name],

We are contacting you because of a personal data breach affecting checkitquick.academicintelligence.co.uk.

What happened

[Brief explanation in clear language.]

What information was involved

The information may have included:

What we have done

We have:

What you should do

We recommend that you:

Contact

If you have questions, contact us at [email protected] or [email protected].

You also have the right to complain to the Information Commissioner’s Office at ico.org.uk.

Kind regards,
[Name]
[Role]
Academic Intelligence Ltd

28. Closure Report

A closure report should be completed for High and Critical incidents and may be completed for Medium incidents.

The closure report should include:

29. Post-Incident Review

After significant incidents, we will conduct a review to identify improvements.

The review may consider:

30. Testing and Review of this Process

This process should be reviewed at least annually and after any significant incident.

The review should confirm:

Tabletop exercises or test scenarios may be used to check readiness.

Schedule 1 — Incident Log Template

Field Entry
Incident reference[Insert]
Date/time reported[Insert]
Date/time discovered[Insert]
Reported by[Insert]
Incident owner[Insert]
Initial severity[Low / Medium / High / Critical]
Current severity[Low / Medium / High / Critical]
Affected school(s)[Insert]
Affected systems[Insert]
Personal data involved?[Yes / No / Unknown]
API credentials involved?[Yes / No / Unknown]
Children’s data involved?[Yes / No / Unknown]
Special category data involved?[Yes / No / Unknown]
Summary[Insert]
Immediate containment[Insert]
Evidence preserved[Insert]
School notified?[Yes / No / Not required / Pending]
ICO notified by us?[Yes / No / Not required / Pending]
Individuals notified by us?[Yes / No / Not required / Pending]
Next action[Insert]
Closure date[Insert]

Schedule 2 — School Action Checklist

When notified of a breach, a school may need to consider:

Schedule 3 — Examples of Reportable and Non-Reportable Scenarios

These examples are illustrative only. The school remains responsible for its own legal assessment where it is controller.

Example 1 — API secret exposed

An iSAMS API secret is accidentally exposed in a support message or log.

Likely action:

Example 2 — Parent sees another family’s data

A parent logs in and sees another pupil or family’s information.

Likely action:

Example 3 — Failed login spike

There is a spike in failed login attempts but no evidence of unauthorised access or personal data compromise.

Likely action:

Example 4 — Unauthorised iSAMS update

An error causes incorrect updates to be written to iSAMS.

Likely action:

Example 5 — Email sent to wrong school

A support email containing school-specific configuration or personal data is sent to the wrong school.

Likely action:

Schedule 4 — Public Website Summary

You can publish this short version on your security or legal page:

If we become aware of a personal data breach affecting personal data processed on behalf of a school through checkitquick.academicintelligence.co.uk, we will notify the affected school without undue delay. The school is normally the controller for parent, pupil and school data and is responsible for deciding whether ICO or individual notification is required. We will support the school by providing available information about the incident, affected data, containment steps and recommended actions. Where a breach affects personal data for which we are controller, we will assess our own notification obligations and, where required, notify the ICO without undue delay and, where feasible, within 72 hours of becoming aware of the breach.

Last updated: 12 May 2026.