Privacy notice
Version 0.14. Last updated 4 November 2026.
Who we are and how to contact us
SENguru CIC is the controller of the personal information you give us. This means we decide how it is used and we are responsible for protecting it. We follow the UK GDPR and the Data Protection Act 2018.
| Organisation | SENguru CIC, a community interest company limited by guarantee |
|---|---|
| Company number | 17213028 (England and Wales) |
| Registered office | 82A James Carter Road, Mildenhall, Bury St Edmunds, IP28 7DE |
| ICO registration number | ZC201166 |
| Privacy contact | info@senguru.co.uk |
| Person responsible for data protection | Chris Gilbert, Director |
What information we collect
We collect only what you choose to give us and what we need to run the service.
| Type | Examples | Where it comes from |
|---|---|---|
| Your account | Name, email address, sign-in details, the local authority you deal with | You |
| Your child's profile | Child's name, date of birth, school or setting, local authority, postcode | You |
| Your child's needs | Diagnoses, disabilities, health information, special educational needs, therapies, support received | You, and documents you upload |
| Documents and correspondence | Letters, emails, reports, draft and final EHC plans, meeting notes | You |
| Logs | Behaviour and communication entries, dates, notes | You |
| Feedback and support | Bug reports, feedback, messages to us | You |
| Help assistant conversations | The questions you ask the help assistant, and its answers | You |
| Technical information | IP address, browser and device type, pages used, error reports | Your device, automatically |
| Payments (paid features only) | Card details are handled by our payment provider; we never see or store your full card number | Our payment provider |
Information about your child's health, disability and needs is special category data. The law gives it extra protection, and so do we.
The help assistant answers questions about using SENguru. It is kept separate from the chat about your case, and it cannot see your case or documents. Your conversations with it are not passed to our team unless you choose to include one with a support report.
If you sign in with Google, we receive your name and email address from Google. Google processes your sign-in under its own privacy policy; it is not our processor.
We use only strictly necessary cookies: a session cookie (senguru_session) to keep you signed in, and a short-lived sign-in cookie (senguru_oauth_state) that protects the sign-in with Google. We do not use tracking, analytics or advertising cookies.
We use school and postcode reference data from the Department for Education (Get Information About Schools) and the Office for National Statistics (postcode directory) to identify your school and local authority. This is public data, not information about you.
Why we use it and our lawful bases
The law requires a lawful basis for each use of personal information (UK GDPR Article 6). For special category data we also need an extra condition (Article 9).
| Purpose | Lawful basis (Article 6) | Extra condition for special category data (Article 9) |
|---|---|---|
| Providing your account and the tools you use | Contract (6(1)(b)) | Explicit consent (9(2)(a)) |
| Optional AI-assisted features | Contract (6(1)(b)) | Explicit consent (9(2)(a)) |
| Keeping the service secure and preventing misuse | Legitimate interests (6(1)(f)) | Not applicable: our security logs and monitoring do not contain your child's health or SEND information. Measures such as encryption and backups protect that information under the explicit consent you gave (9(2)(a)). |
| Fixing errors and improving the service, using technical data | Legitimate interests (6(1)(f)) | Not applicable: we do not use your child's information for this |
| Responding to feedback and support requests | Legitimate interests (6(1)(f)) | Explicit consent (9(2)(a)) where you share health information with us |
| Answering questions about using SENguru | Legitimate interests (6(1)(f)) | Explicit consent (9(2)(a)) where you share health information with us |
| Taking payments for paid features | Contract (6(1)(b)) | Not applicable |
| Meeting legal duties (for example, tax records) | Legal obligation (6(1)(c)) | Not applicable |
You can delete your account at any time in Settings → Data & Privacy, which withdraws your consent. You can also withdraw consent by contacting us. Withdrawing consent does not affect processing that happened before.
We do not sell your information. We do not use it for advertising. We do not use your child's information to train AI models.
Information about other people
The records you keep will often name other people, such as teachers, SENCOs, local authority officers, therapists, doctors and family members. We store this information only as part of your record, so that you can manage your child's case.
We do not contact these people, and we do not use their information for any other purpose.
Please only upload information you have a right to hold, such as correspondence sent to you and reports about your child.
AI-assisted features
Some optional features use an AI language model, for example to answer questions about a document you have uploaded or to check a draft EHC plan. These features are on by default. You can turn them off at any time in Settings → AI features.
- Where it runs: the AI model is run by a cloud provider we have a contract with, in the UK or the European Economic Area (EEA). The provider may use your information only on our instructions. We may change the model or provider; any we use must meet the commitments in this section. See How we use AI securely.
- What is sent: only the documents and questions involved in the task you have asked for.
- No training: neither we nor our provider use your information to train AI models.
- No decisions about you: the AI produces suggestions for you to read and check. It does not make decisions about you or your child, and no one else acts on its output.
- It can be wrong: AI output can contain mistakes. Always check it against the original documents and get advice from IPSEA, SOS!SEN or your local SENDIASS before relying on it.
Who we share it with
We share your information only with companies that help us run SENguru (our processors). They may use it only on our instructions, under a written contract.
| Type of processor | What they do |
|---|---|
| Cloud hosting provider | Hosting, database, file storage and AI model hosting |
| Email provider | Sending account and notification emails |
| Error monitoring provider | Helping us find and fix technical problems |
| Payment provider | Taking payments for paid features |
The processors we use today are:
- Amazon Web Services (AWS): hosting, database, file storage and email, in London (eu-west-2)
- AWS Bedrock: AI processing, including the help assistant, called from London (eu-west-2). For some models AWS processes the request in another data centre in the UK or the EEA
- Zeffy: taking membership payments, when you buy the supporter plan
- Sentry: error monitoring, in the EU (Frankfurt), with personal information removed before error reports are sent
When you choose Get the supporter plan, we send you to Zeffy's payment form and fill in your SENguru email address for you. Zeffy tells us when a payment is made, and we read the payment details back from Zeffy to match them to your account. We store the payment's amount, date and Zeffy reference, the email on it, and when your supporter plan year ends.
People you invite to your case can see everything on it, including information about other people in your records. You control who is invited, and you can remove them at any time.
We will not share your information with your local authority, your child's school or anyone else unless you ask us to.
We may disclose information without your consent only where the law requires it, for example a court order, or where we believe a child or adult is at serious risk of harm.
Where it is stored and how we protect it
Your account, your child's records, your documents and their backups are stored in the UK, in London.
AI processing may take place in the UK or the European Economic Area (EEA). We send information there only to process the task you asked for, and we do not store it there. UK law recognises EEA countries as protecting personal information to the UK standard (UK adequacy regulations).
We never send your information outside the UK and the EEA for AI processing. If we ever need to process it anywhere else, we will tell you first and use approved safeguards such as the UK International Data Transfer Agreement.
We protect it by:
- encrypting it in transit and at rest
- keeping live data separate from our test systems, which use only made-up data
- limiting staff access to what is needed for support and maintenance, and logging that access
If a breach puts your rights at risk, we will tell you and the ICO as the law requires.
How long we keep it
We keep your records for as long as your account is open, because EHC cases can last many years. You can delete a document, your child's profile or your whole account at any time.
| Information | How long we keep it |
|---|---|
| Account, child profiles, documents, logs | Until you delete them or close your account |
| Inactive accounts | Deleted after three years without any activity (signing in, or an email arriving at your SENguru address). We send three warning emails first |
| Backups | Kept for up to 366 days, then deleted. Information you delete may remain in a backup for that long. We do not restore deleted records from backups, except to recover the whole service from a failure |
| Technical and security logs | Only as long as needed to keep the service secure and fix problems |
| Support messages | Only as long as needed to resolve your issue and any follow-up |
| Help assistant conversations | Deleted after 90 days, or sooner if you clear them or delete your account |
| Screenshots attached to a support report | Deleted 90 days after upload |
| Waitlist and register-interest details (without an account) | Up to 24 months from your last submission, then deleted |
| Payment and accounting records | As long as tax law requires (currently 6 years) |
What you add to a case someone else owns stays on that case if you delete your account. It is kept without your name and shown as "Former member".
You can download a copy of your records at any time in Settings → Data & Privacy.
Your rights
You have the right to:
- see a copy of the information we hold about you
- have inaccurate information corrected
- have your information deleted
- restrict or object to how we use it
- receive your information in a format you can take elsewhere
- withdraw consent at any time
To use any of these rights, contact us at info@senguru.co.uk. It is free. We will reply within one month, and we may need to confirm your identity first.
Young people and children
SENguru accounts are for parents and carers with parental responsibility, and for young people aged 16 to 25 managing their own EHC process. Children under 16 cannot create an account.
Your child has their own data protection rights. As their parent, you can use those rights on their behalf while they are too young to do so. As children grow older and understand more, their own views about their information matter more.
Under the Children and Families Act 2014, rights in the EHC process pass from parents to the young person once they are over compulsory school age (SEND Code of Practice 0 to 25, chapter 8). If you manage the records of a young person aged 16 to 25, you confirm that you have their consent, or appropriate authority to act on their behalf if they lack the mental capacity to decide.
Complaints and changes to this notice
If you are unhappy with how we have handled your information, please contact us first at info@senguru.co.uk so we can try to put it right.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator for data protection, at ico.org.uk/make-a-complaint or on 0303 123 1113.
If we make a significant change to how we use your information, such as a new purpose, we will tell you before it takes effect, by email or in the app, and ask for your consent again where the law requires it. Other updates, such as changes to our list of processors, take effect when we publish them here.