Privacy Notice

TeZe Ltd (“we”) operates the Tactile Framework app, a clinical companion for practitioners working with learners who are deafblind or who use bodily-tactile communication. We are registered in England and Wales, company number 17137231, registered office 66 Paul Street, London, EC2A 4NA. Our ICO registration is ZC134108.

For data protection matters write to compliance@teze.app. For anything else, hello@tactileframework.app.

The answer differs by record type, and the distinction matters:

• Learner records (observations, skill assessments, goals). The organisation the practitioner works for, a school, an NHS trust, a local authority service or an independent practice, is the controller. We are the processor, acting on that organisation’s instructions under our Data Processing Agreement. Where a practitioner is genuinely self-employed with no employing organisation, that practitioner is the controller.
• Practitioner accounts and our own business records. We are the controller. This notice is the notice for that processing.

• Practitioner account data. Email address, display name, optional organisation name and role, authentication timestamps. Passwords are held as hashes by our authentication provider and are never visible to us.
• Learner records, pseudonymous. A short code and a label, both chosen by the practitioner, the framework stage, a list of communication partner roles, and activity dates. The app has no field for a learner’s name, date of birth, address, NHS number or school. The database schema does not contain one.
• Observations, assessments and goals. Free-text notes written by the practitioner, timestamped and attributed to them, plus skill ratings and goal text.
• AI usage records. When an optional drafting feature is used we log that it happened, by whom and when, so the feature can be audited. See section 7.
• Technical logs. The minimum needed to run and secure the service: IP address, user agent, request path, status code.

We set no analytics, advertising or tracking cookies, and we do not fingerprint visitors. The only cookies are the session and refresh cookies that keep a practitioner signed in.

Because observation notes are free text, a practitioner cantype a name into them. The app is designed so that they never need to, and the guidance in the product is to use the learner’s code. We cannot technically prevent it, so we say it plainly rather than claim a guarantee we cannot keep.

Treat the content as sensitive regardless. Observations describe a disabled child’s communication and development. In the controller’s hands that is special category data concerning health under Article 9 of the UK GDPR, and it is handled that way here whether or not a name ever appears.

For learner records, the controller decides. A school or NHS service will usually rely on Article 6(1)(e) (public task) with the Article 9(2)(h) condition (health or social care provided by a professional under a duty of confidentiality). An independent practice may rely on Article 6(1)(b) or (f) with explicit consent under Article 9(2)(a). That determination, and the record of it, belongs to the controller. We do not make it for them and we do not assume it has been made.

For our own processing we rely on Article 6(1)(b) (performance of a contract) for practitioner accounts, Article 6(1)(c) for legal and tax obligations, and Article 6(1)(f) (legitimate interests) for security, fraud prevention and reliability, balanced against the rights of the people concerned.

The database and authentication service are hosted by Supabase in eu-west-3 (Paris, France), inside the European Economic Area. The application is hosted by Vercel. Personal data is not stored outside the UK or EEA.

A note for UK public sector buyers. EEA hosting is lawful for UK data under the current adequacy arrangements, but some NHS and local authority procurement policies specify UK-only residency. If that applies to you, raise it before you deploy: a UK region is available and we would rather move you than have you discover the region in an assessment. The one exception to EEA-only processing is the optional AI feature in section 7.

Three features draft text for a practitioner to edit: turning a goal into SMART form, drafting a parent summary, and polishing report prose. They are optional, they always return an editable draft, and they never write to a learner’s record.

• Names, contact details, links and long digit runs are stripped from the text on our server before any request is sent, by a scrub the drafting prompts are built on so a route cannot skip it.
• The de-identified text is processed by Anthropic. Anthropic does not train its models on data submitted through its API.
• Stated precisely:we rely on the provider’s standard API terms. We have not signed a separate zero-retention agreement, so we do not claim one. If your assessment requires zero retention in writing, tell us and we will arrange it before you enable the feature.

Learner records are kept for as long as the controller instructs.UK clinical record-keeping practice for speech and language therapy records is retention for 8 years from the last entry, or until the person’s 26th birthday if later, under the NHS Records Management Code of Practice 2021. Your organisation’s own retention schedule governs, and we delete on instruction.

Said plainly: automatic retention enforcement is not yet built into the app. Nothing is deleted on a timer today, so deletion happens when you ask. Building scheduled retention is on the list before general release, and until it ships the responsibility to ask sits with the controller.

• Practitioner accounts: for the life of the account, deleted within 30 days of a deletion request.
• AI usage records: 12 months.
• Technical logs: 30 days.
• Accounting records: 6 years, as HMRC requires.

Only the providers on our sub-processors page, and only as needed to run the service. We do not sell personal data, we do not share it for marketing, and we do not use it to train machine learning models.

Under UK GDPR you can ask for access, correction, deletion, restriction and portability, and you can object to processing.

About a learner’s records,including a request from a parent or guardian, contact the practitioner’s organisation. They are the controller and they hold the key that connects a learner to a code. We cannot identify a learner from our own systems, which is the point of the design, and we will support the controller in answering within statutory time limits.

About your own practitioner account, email compliance@teze.app. Export and deletion are handled by request today rather than by a self-serve button.

You can complain to us using our complaints procedure and to the ICO at ico.org.uk.

The learners described in these records are usually children. The app is deliberately practitioner-only: a learner has no account and cannot sign in, there is no child-facing interface, no profiling of children, no behavioural nudges and no location tracking. We do not knowingly collect data directly from a child.

Access is restricted by row-level security in the database so a practitioner reaches only their own caseload. Traffic is encrypted with TLS in transit and data is encrypted at rest. Administrative access to our providers requires multi-factor authentication. TeZe Ltd is Cyber Essentials certified (IASME, 31 July 2026). The fuller posture is on teze.app/trust.

The app is in active development and is not yet sold. Two things above will change as it matures, and we would rather they were on the record now than discovered later: scheduled retention is not implemented, and account export and deletion are handled by request rather than in the interface. This notice is updated when either changes.