Privacy notice · Version v1 · Last updated 26 October 2026

Graduate Success Benchmark - Privacy Notice

Operated by GROW

Last updated: 26 October 2026

1. About this privacy notice

The Graduate Success Benchmark is a research and benchmarking initiative developed by GROW to help training providers understand and improve how they prepare graduates for sustainable professional careers.

The initiative includes:

Institutional self-assessments and benchmarking.
Comparisons between participating training programmes.
Surveys exploring incoming students' expectations.
Research into graduates' professional and financial experiences.
Optional study updates, collaborative learning events and ranking notifications.

We take privacy seriously and aim to collect only the information necessary to operate the Benchmark and conduct meaningful research.

This notice explains what information we collect, how we use it, who can access it, and the choices and rights available to you.

It applies to training provider representatives, students, graduates and other individuals using the Graduate Success Benchmark platform.

2. Who is responsible for your information?

The Graduate Success Benchmark is operated by:

Sole Trader Courses Ltd, trading as GROW Formula

Company number: 16406138

Registered in England and Wales

Registered office: 12 Charmind Walk, Swindon, SN25 1QA

Email: support@growformula.org

Website: https://growformula.org/

For information submitted directly to the Benchmark, GROW is responsible for determining how that information is used for the research and benchmarking purposes described in this notice.

Participating training institutions remain responsible for their own student and graduate contact records and for how they distribute invitations to participate. They should provide their own privacy information about those activities where required.

3. What information do we collect?

A. Information about participating institutions

When an institution registers, we may collect:

Institution name and website.
Name, role and work email address of its representative.
Country or region.
Training programmes, modalities and qualification levels.
Programme duration, delivery method and approximate graduate numbers.
Answers to the institutional benchmarking assessment.
Benchmark scores, rankings and historical changes.
Participation and identity-sharing preferences.
Optional email communication preferences.

Where an institution's details identify an individual, such as a sole trader, those details may also constitute personal data.

B. Information from incoming students

Our optional student survey explores expectations about future professional practice.

This may include:

Intended career pathway and working pattern.
Expected time to financial sustainability.
Anticipated client numbers and earnings.
Understanding of business costs and responsibilities.
Expectations about finding clients.
Financial preparedness.
Interest in business education and preferred timing.

We do not require students to provide their names, postal addresses or email addresses to complete the standard survey.

C. Information from graduates

Our optional graduate survey explores experiences after qualification.

This may include:

Approximate time since qualification.
Whether the respondent is practising.
Working patterns and employment arrangements.
Approximate client numbers.
Practice income and financial sustainability, using appropriate ranges.
Challenges encountered in establishing a practice.
Business training and support received.
Perceived readiness for self-employment.
Career satisfaction and reflections on training.

We do not require graduates to provide their names or contact details to complete the standard survey.

D. Technical information

When people use the platform, we may process limited technical information necessary for security and operation, including IP addresses, browser information, login events, timestamps and security logs.

We may also record survey response identifiers to help prevent duplicate submissions and administer privacy requests.

Important: Although our surveys do not routinely ask for names, some responses or technical information may still make a person indirectly identifiable. We therefore protect survey records as personal data unless they have been effectively anonymised.

We do not intentionally seek information about health conditions, disability, ethnicity, religion or other sensitive personal characteristics through the standard research surveys. Participants should not include patient details or other identifiable third-party information in their answers.

4. Why do we use this information?

We use information to:

Register and administer institutional accounts.
Produce Graduate Readiness Scores and domain assessments.
Calculate and display appropriate benchmark rankings.
Provide personalised feedback and improvement recommendations.
Investigate students' expectations about professional practice.
Understand graduates' experiences and professional outcomes.
Investigate relationships between educational approaches, business development and graduate outcomes.
Prepare aggregated research findings, reports and publications.
Maintain the security, accuracy and reliability of the platform.
Send optional study communications and ranking alerts where requested.

The research is intended to improve understanding of how training providers can support graduates in establishing sustainable professional careers.

We do not use student or graduate survey responses to market GROW products or services to respondents.

We do not sell personal information or provide individual survey responses to advertisers.

5. Our lawful bases for processing

Under UK data protection law, we must have a lawful basis for using personal data.

Depending on the purpose, we rely on the following:

Purpose	Lawful basis
Administering institutional accounts and delivering the benchmarking service	Legitimate interests, or contract where applicable
Conducting benchmarking and research	Legitimate interests
Maintaining security, preventing misuse and ensuring data quality	Legitimate interests and, where applicable, legal obligations
Optional disclosure of an identifiable institution or individual participant's details to named benchmarking peers	Consent where personal data is involved
Sending optional study updates and collaborative event invitations	Consent
Sending optional ranking-change notifications	Consent
Meeting applicable legal obligations	Legal obligation

Our legitimate interests include conducting proportionate research into graduate preparation and professional sustainability, providing useful benchmarking information to participating institutions, and maintaining a reliable and secure research platform.

We balance these interests against the privacy rights of the people whose information we process, using data minimisation, access controls and aggregation.

Participation in student and graduate surveys is voluntary. Choosing to participate in research is distinct from the lawful basis we use to process information.

6. Confidential and named benchmarking

Participating institutions can choose how their identity is shared with other institutions.

Confidential participation

If an institution chooses confidential participation:

Its identity will not be displayed to other participating institutions.
It will receive its own score and improvement recommendations.
It may see its own numerical ranking and the number of comparable participating programmes, subject to privacy safeguards.
It will not see the identities or individual scores of other institutions.
Its results may contribute to aggregate benchmarking and research findings.

Reciprocal named participation

If an institution actively chooses named participation:

Its institution and programme names and relevant benchmark scores may be visible to other institutions that have also opted into named participation.
It may see the corresponding details of other named participants.
Confidential institutions will not be identified.
Its participation does not authorise public disclosure outside the permitted benchmarking community.

Named participation is entirely optional.

Institutions can change their preference through their account settings.

Switching from named to confidential participation will prevent further disclosure through the platform. It cannot undo information legitimately viewed by other participants before the preference changed.

We apply safeguards to reduce the risk of identifying confidential institutions through small comparison groups, filters or ranking changes.

We do not publish a public leaderboard identifying participating institutions.

7. How student and graduate responses are protected

Student and graduate surveys are designed to collect information without requiring personal identification.

Individual survey responses are accessible only to authorised study personnel and service providers acting on our instructions.

Participating institutions may receive aggregated findings relating to their programmes, but not identifiable individual student or graduate responses.

We use safeguards including:

Reporting results in groups rather than individually.
Suppressing small groups where identification could be possible.
Limiting combinations of filters that could reveal individual responses.
Restricting access to underlying research records.
Removing identifying details from published findings.

Where possible, data will be anonymised for research reporting.

We will not claim that data is anonymous merely because names have been removed. Information that could still be linked to an individual will continue to be protected as personal data.

If we introduce optional individual follow-up research, we will explain any additional information required and give participants a separate, informed choice before collecting it.

8. Study updates and ranking notifications

Institutional representatives can independently choose to receive two types of optional email.

Study updates

These may include research findings, study progress, methodological developments and invitations to online events where participating institutions share experiences and best practice.

These communications will not contain promotions for GROW courses, products or paid services.

Ranking notifications

Institutions may separately request automatic emails when the numerical ranking of one of their programmes changes within its defined comparison group.

These emails may show the previous and current rank, comparison-group size and current readiness score.

A change in ranking does not necessarily mean that the quality of an institution's provision has changed; it may reflect changes among other participating programmes.

Both notification preferences are optional and switched off by default.

Participants can change their preferences or unsubscribe at any time.

Essential account and security communications may still be sent where necessary to administer the service.

Consent to receive study communications is not consent to receive commercial marketing from GROW.

9. Who can access your information?

Information may be accessed by:

Authorised GROW personnel responsible for administering the study.
Technology providers hosting and maintaining the platform.
Providers supporting authentication, secure data storage and email delivery.
Authorised research collaborators, where necessary and subject to appropriate confidentiality and data protection arrangements.

Participating institutions receive only the information permitted by their participation mode and the platform's privacy safeguards.

Researchers and collaborators may receive anonymised or appropriately protected data relevant to approved research activities.

Identifiable research information will not be disclosed to external collaborators without an appropriate lawful basis and safeguards.

We do not provide identifiable student or graduate research data to institutions for marketing or recruitment purposes.

We may disclose information where required by law.

10. Where information is stored and international data transfers

The platform is provided through Lovable Cloud. The database that stores institutional accounts, sign-in details, assessments, communication preferences and, in future, student and graduate survey responses is hosted in the European Union (Ireland).

Storing data in Europe does not mean that all processing takes place in Europe. In particular:

Web pages are delivered through a global content delivery network, so requests may be handled by servers outside the United Kingdom and European Economic Area.
The platform and database providers are part of groups based in the United States, and their personnel may access systems for support and security purposes.
If you choose to sign in with Google, Google receives and processes your sign-in information.
Account emails, such as sign-in confirmation and password reset messages, are sent through the platform's email service.

We do not use artificial intelligence services to process identifiable research data, and research data is not used to train AI models.

Where a restricted international transfer takes place, we rely on an applicable lawful transfer mechanism, such as UK adequacy regulations or the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, as provided in our providers' data processing terms.

Further information about our providers and transfer safeguards is available by contacting support@growformula.org.

11. How long do we keep information?

We retain personal data only for as long as needed for the purposes described in this notice.

Information	Retention and action
Institutional accounts, assessments and identifiable score history	While the institution participates, plus 24 months after account closure; then deleted
Student and graduate survey responses that remain identifiable	Up to five years after collection; then deleted or effectively anonymised
Communication preferences and opt-in records	While relevant, plus 24 months after withdrawal or account closure, subject to any justified compliance requirement
Security and application access logs	Normally up to 90 days, unless needed to investigate an incident or meet a legal requirement
Effectively anonymised research findings and statistics	May be retained indefinitely for research and reporting
Database backups	Taken daily and automatically expire after approximately 14 days

When an institution closes its account, access ends immediately for all of its users and any named benchmarking visibility stops at once.

Effective anonymisation means removing or transforming information so that no individual or institution can reasonably be identified, directly or indirectly. Removing names alone is not treated as anonymisation.

At the end of the applicable retention period, personal information is securely deleted or effectively anonymised, unless continued retention is required by law or otherwise justified under applicable data protection rules. Deleted information may remain in backups until those backups expire.

These periods will be reviewed as the study develops.

12. Your rights

Depending on the circumstances and applicable lawful basis, you may have the right to:

Ask what personal information we hold about you.
Request a copy of your personal information.
Correct inaccurate or incomplete information.
Request deletion of information.
Restrict certain processing.
Object to processing based on legitimate interests.
Withdraw consent where processing relies on consent.
Request data portability where applicable.

Your right to object: Where we rely on legitimate interests, you have the right to object to our processing of your personal data. We will consider your objection in accordance with applicable data protection law.

You can withdraw optional email permissions through your account settings or by contacting us.

If you completed a research survey without providing identifying information, we may need your survey response reference to locate your submission. Once information has been effectively anonymised, it may no longer be possible to identify or remove an individual response.

To exercise your rights, contact:

support@growformula.org

We will respond within the timescales required by applicable law, normally within one month.

13. Security

We use appropriate technical and organisational safeguards to protect information against unauthorised access, alteration, loss or disclosure.

These include, where appropriate:

Secure authentication.
Role-based access permissions.
Restricted access to research records.
Encryption in transit and appropriate protection of stored data.
Secure management of technical credentials.
Monitoring and investigation of security incidents.
Data minimisation and secure deletion procedures.

No online system can guarantee absolute security, but we take reasonable steps appropriate to the risks involved.

14. Cookies and similar technologies

The platform may use essential cookies or similar technologies required for authentication, security and basic functionality.

Where we use optional cookies or technologies requiring consent, we will explain their purposes and provide appropriate choices before activating them.

Information about cookies, their purposes and their duration will be available through the platform's cookie information or preferences.

15. Automated scoring and rankings

The Graduate Success Benchmark uses automated calculations to produce institutional readiness scores, domain scores and relative rankings.

These calculations are based on participating institutions' assessment responses and published scoring criteria.

Scores are intended to support reflection and improvement. They are not formal accreditation, regulatory assessments or guarantees of graduate success.

We do not use these scores to make solely automated decisions producing legal or similarly significant effects on individual students or graduates.

Institutions can contact us if they believe their assessment or ranking contains an error.

16. Changes to this notice

We may update this notice as the study, platform or applicable legal requirements develop.

The current version will be available on the Graduate Success Benchmark website.

Where a change materially affects how personal information is used, we will provide appropriate notice before introducing the new processing.

17. Questions, concerns and complaints

Please contact us if you have questions about how information is collected or used, wish to exercise a data protection right, or want to raise a concern.

Email: support@growformula.org

Organisation: Sole Trader Courses Ltd, trading as GROW Formula

Postal address: 12 Charmind Walk, Swindon, SN25 1QA

We will investigate data protection complaints in accordance with our applicable legal obligations.

You also have the right to raise concerns with the Information Commissioner's Office (ICO), the UK's data protection regulator.

Website: https://ico.org.uk/

Graduate Success Benchmark

Helping training providers prepare practitioners not just to qualify, but to succeed.

An initiative developed by GROW.