This Privacy Policy explains how ALWD Limited, trading as "Benchmark" ("Benchmark", "we", "us" or "our"), processes personal data when you visit or use the Benchmark website, platform and related services (the "Platform").
Benchmark may act as either a data controller or a data processor, depending on the circumstances and the purpose of the processing. Where Benchmark acts as a processor on behalf of a training provider, the relevant training provider remains responsible for determining the purposes and lawful basis of that processing.
Benchmark is a trading name of ALWD Limited, a company registered in England and Wales under company number 14458561, whose registered office is at 124 City Road, London, EC1V 2NX.
You can contact us at app@benchmark.ac.
Benchmark acts as an independent data controller where we determine the purposes and means of processing personal data for our own purposes.
This includes, where applicable:
For this processing, Benchmark is responsible for complying with applicable data protection legislation and this Privacy Policy applies.
Where a training provider or other organisation ("Provider") uses Benchmark to provide examinations, assessments or related services to its students or users, the Provider is generally the data controller of the personal data it instructs Benchmark to process for those purposes.
In those circumstances, Benchmark acts as the Provider's data processor and processes personal data only on the Provider's documented instructions, subject to applicable law.
This may include student registration information, examination submissions, answers, assessment results, scores, progress and related technical information processed to provide the Provider's services.
The Provider is responsible for determining the purposes and lawful basis for that processing and for providing its own privacy information to affected individuals. Where you use Benchmark through a Provider, you should therefore also refer to the Provider's privacy notice.
Benchmark may nevertheless process certain personal data relating to those users as an independent controller where Benchmark determines its own purpose for the processing, including for platform security, fraud prevention, technical operations and other purposes described in this Privacy Policy.
The personal data we process depends on how you use Benchmark and whether we are acting as controller or processor.
If you visit this website or use the free mock without creating an account, we may process:
Guest exam answers are not intentionally linked to your identity and are deleted automatically within 24 hours of the session ending.
Where Benchmark acts as a processor on behalf of a Provider, the Provider may instruct Benchmark to process:
The Provider determines the purposes for which this data is processed.
Where Benchmark acts as an independent controller, we may process:
We may process personal data for purposes including:
Where Benchmark processes personal data on behalf of a Provider, we process that data only for the purposes specified by the Provider and agreed in the applicable contractual arrangements.
These purposes may include:
Where Benchmark is the controller, we rely on the lawful basis appropriate to the relevant processing activity. These may include:
Where we rely on legitimate interests, we consider the impact of the processing on individuals and ensure that our interests are not overridden by their rights and freedoms.
Where Benchmark acts as a processor on behalf of a Provider, the Provider determines the purposes of the processing and the applicable lawful basis. Benchmark processes personal data in accordance with the Provider's documented instructions and the applicable data processing agreement.
Benchmark may provide optional AI-assisted marking, review or feedback features.
Where an AI-assisted feature is provided as part of a Provider's service and the Provider has opted into that feature, Benchmark acts as the Provider's processor and may provide submitted content to an authorised AI sub-processor for the purpose of generating the requested output.
Where Benchmark independently provides an AI feature for its own purposes, Benchmark will act as controller for that processing.
AI-generated outputs may be inaccurate or incomplete and are provided for educational and informational purposes only.
We may share personal data with:
Where we act as a processor, we may process or disclose personal data only as authorised by the relevant Provider and in accordance with the applicable data processing agreement.
This may include authorised sub-processors such as Google Cloud Platform, Google Firebase/Identity Platform, Sentry, Postmark and Google Gemini API, where applicable to the relevant service.
Where you access Benchmark through a Provider, your registration details, examination submissions, results and progress may be made available to that Provider in accordance with its instructions.
We do not sell personal data to third parties.
Some third-party service providers used by Benchmark may process personal data outside the United Kingdom, including in the United States.
Where Benchmark is the controller, we will only make a restricted transfer where permitted under applicable data protection legislation and where an appropriate safeguard is in place, such as an adequacy regulation or an applicable contractual transfer mechanism.
Where Benchmark acts as a processor, any restricted transfer will be carried out in accordance with the Provider's documented instructions and the applicable data processing agreement.
Further information about applicable transfer safeguards is available on request.
Where Benchmark is the controller, we retain personal data only for as long as reasonably necessary for the relevant purpose, taking into account legal, regulatory, accounting and operational requirements.
Indicative retention periods are:
Retention periods may be extended where necessary for legal proceedings, regulatory compliance, dispute resolution or other lawful purposes.
Anonymised or aggregated information that no longer identifies an individual may be retained for longer.
Where Benchmark acts as a processor on behalf of a Provider, the Provider determines the applicable retention requirements for that processing, subject to the contractual arrangements between the Provider and Benchmark.
Benchmark will retain, return and delete such personal data in accordance with the Provider's documented instructions and the applicable agreement, subject to any legal requirement requiring Benchmark to retain the data.
Accordingly, retention periods for examination submissions, answers, results and other Provider-controlled data may differ between Providers.
Benchmark takes appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
These measures include, where applicable:
No online service can guarantee absolute security.
Where Benchmark acts as a processor and becomes aware of a personal data breach affecting Provider-controlled personal data, we will notify the relevant Provider without undue delay in accordance with the applicable agreement and applicable law.
Where Benchmark acts as controller, we will assess and respond to any personal data breach in accordance with applicable data protection law.
Depending on the circumstances, you may have rights under applicable data protection legislation, including the right to:
Where Benchmark acts as controller, you may exercise your applicable rights directly against Benchmark by contacting app@benchmark.ac.
Where Benchmark processes your personal data on behalf of a Provider, the Provider is the controller of that processing.
Requests concerning examination data, assessment data, results, progress and other Provider-controlled personal data should normally be directed to the relevant Provider in the first instance.
Benchmark will provide reasonable assistance to the Provider in responding to such requests as required by applicable law and our agreement with the Provider.
If you contact Benchmark directly regarding Provider-controlled data, we may need to refer the request to the relevant Provider or confirm the appropriate response with the Provider.
Benchmark uses cookies and similar technologies.
These cookies are required for the Platform to function, including session management and authentication, and are used without consent where permitted because they are necessary for the service.
We use Google Analytics to understand how the Platform and website are used. These cookies are only placed after you have given consent through our cookie banner where consent is required. You may withdraw or change your cookie preferences at any time.
We do not use cookies for advertising or tracking across third-party websites.
The Platform relies on third-party services for functions including hosting, authentication, monitoring, communications and, where enabled, AI-assisted features.
Where Benchmark acts as controller, those providers may process personal data on Benchmark's behalf.
Where Benchmark acts as processor, relevant providers may act as authorised sub-processors subject to the applicable contractual arrangements.
The Platform is intended for users aged 18 and over.
We do not knowingly collect personal data from children under 18 for the purpose of providing the Platform.
If you believe that a child has provided personal data to us, please contact app@benchmark.ac.
We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal requirements or data processing practices.
Updated versions will be published on this page and will take effect when published, unless otherwise stated.
This Privacy Policy and the Platform are operated by:
Questions or requests relating to this Privacy Policy should be sent to app@benchmark.ac.
If you believe that your personal data has been processed unlawfully or that your data protection rights have been infringed, you also have the right to complain to the Information Commissioner's Office (ICO).