Identity and contact details of the data controller and the data protection officer

Data controller: Clear Links Support Ltd, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, info@clear-links.co.uk

Data protection officer: Dexter Johnstone, The Portergate Building, Ecclesall Road, Sheffield, S11 8NX, 0114 278 6866, dexter.johnstone@clear-links.co.uk

Purpose of the processing and the lawful basis for the processing

We will process your personal data for the purposes of providing and monitoring AI Study Buddy.

AI Study Buddy is an AI-powered study support assistant designed to support academic study through guided assistance and educational support. The service is available through Crystal, Clear Links Support's online portal, and is intended to supplement existing human-delivered support services.

The lawful basis for processing personal data through AI Study Buddy is:

Article 6(1)(f) UK GDPR – Legitimate Interests

Clear Links has a legitimate interest in providing students with additional educational support tools that improve accessibility, enhance the student experience and supplement existing support services.

AI Study Buddy is not designed to collect special category personal data. However, where you voluntarily disclose information relating to your health, disability or other special category information, Clear Links will process that information only where an appropriate condition under Article 9 UK GDPR applies. This will normally be:

Article 9(2)(g) – where processing is necessary for reasons of substantial public interest, including safeguarding where required by law.

How AI Study Buddy works

AI Study Buddy generates responses using a large language model (LLM). Responses are produced automatically based on the information you provide and the educational resources available to the system. Responses are intended to support your learning and should not replace academic advice from your university or support worker.

Categories of personal data

AI Study Buddy is available via your Crystal account. No additional personal data is processed to enable you to access AI Study Buddy.

The system may process:

• Username and account information.
• Email address.
• IP address.
• Browser information.
• Usage information.
• Messages submitted by you.
• System-generated responses.

Personal data relating to safeguarding concerns may be shared, where necessary and proportionate, with your higher education provider or other appropriate agencies in accordance with our safeguarding procedures.

You should avoid sharing unnecessary personal information, particularly information about other identifiable individuals.

Special Category Personal Data

You may voluntarily disclose special category personal data including:

• Disability information.
• Health information.
• Mental health information.
• Neurodivergence information.
• Personal circumstances affecting study.

AI Study Buddy is not designed to collect special category data and you are encouraged not to share unnecessary personal information.

Where special category data is disclosed, processing is limited to providing the requested support and applying safeguarding protections where appropriate.

Any recipient or categories of recipients of the personal data

Clear Links Support acts as the Data Controller for personal data processed through AI Study Buddy.

OpenAI processes personal data solely on behalf of Clear Links Support under a written data processing agreement and only for the purpose of providing AI Study Buddy.

Any personal data relating to wellbeing or safeguarding concerns may be shared with appropriate services.

Information submitted through AI Study Buddy is not used to train publicly available AI models.

Details of transfers to third country and safeguards

Personal data processed by Clear Links through AI Study Buddy is hosted within the UK.

AI Study Buddy is an optional service. Users are advised not to enter personal data into the chatbot. The service is designed to be used without the need to provide personal information. However, if a user chooses to include personal data in their prompts or other content submitted to the service, that information will be processed by OpenAI on our behalf.

Where OpenAI processes personal data outside the UK, appropriate safeguards are in place in accordance with Chapter V of the UK GDPR. These safeguards consist of the European Commission's Standard Contractual Clauses, as supplemented by the UK International Data Transfer Addendum (where applicable), which are incorporated into OpenAI's Data Processing Addendum.

Retention period or criteria used to determine the retention period

We will retain personal data no longer than is necessary for the purpose it was obtained for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Some personal data will need to be retained for longer than others.

The type of data determines the retention period.

Conversation information is retained only for as long as necessary to provide the service, investigate technical issues, fulfil safeguarding obligations and maintain system security.

Following 30 days of inactivity:

• Message content is deleted.
• Safeguarding metadata is deleted.
• Conversation summaries are deleted.
• Stored facts are deleted.

The rights available to individuals in respect of the processing

We will process all personal data in line with your rights, which are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
• The right to withdraw consent at any time, where relevant

Further information about these rights can be seen here.

Please contact our Data Protection Officer if you wish to exercise any of these rights.

The right to lodge a complaint with a supervisory authority

You have the right to complain to the Information Commissioner's Office if you think there is a problem with the way we are processing your data.

You can contact them here.

The source the personal data originates from and whether it came from publicly accessible sources

Personal data is obtained from your Crystal account and from information that you choose to enter while using AI Study Buddy.

Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

We require your personal data to provide our services to you. Without this data we will not be able to do this.

The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences

AI Study Buddy automatically generates responses to questions that you submit. The system does not make decisions about your entitlement to support, funding, academic assessment or any other decisions that produce legal or similarly significant effects.