Your student is enrolled in the Cambridge International Education Program that requires their exams to be delivered through the Cambridge Exam Cycle testing platform

While Pasco County Schools attempts to obtain a data privacy agreement with every third-party vendor/online educational service that collects student PII, on those occasions when that is not possible, Florida law permits disclosure of PII to the third party when the “disclosure is authorized by written consent of an eligible student or parent.  Consent must include, at a minimum, an explanation of who the PII would be disclosed to, how it would be used, and whether re-disclosure is permitted.”

This purpose of this communication is two-fold.  First, Pasco County Schools is required by Florida law to notify parents or eligible students about:

  • if and what student personally identifiable information (PII) will be collected by an online educational service that a student or parent is required to use and access through the Internet as part of a school activity or function;
  • how it will be used;
  • when it will be destroyed; and
  • the terms of re-disclosure, if any.

Pasco County Schools also must provide notice on its website of this same information along with a link to the online educational service’s terms of service and privacy policy, if publicly available.  To that end, Cambridge International Education  Terms of Use and Privacy Policy may be accessed via these links:

(Please note: Pasco County Schools highly recommends that parents or eligible students visit and fully review each of these links).

This second purpose of this communication is to obtain your consent.  In order for your child to take Cambridge exam(s), you must provide your consent for your child. As such, please visit your Parent Portal https://lively.focusschoolsoftware.com/focus/ and select [Yes] if you consent for your child to utilize the Cambridge Exam Cycle testing platform or [No] if you do not give your consent. [*Note: By selecting, [No], your child will not have the opportunity to take the exam(s) that is/are aligned to the Cambridge International Education Program. Please provide your consent on or before February 7, 2025.

The Cambridge International Education Program Terms of Use and Privacy Policy address each of the four topics (referenced above) as follows:

  1. According to its Data Protection and Privacy Policy, the types of information collected will vary depending on the context of your interactions and the product and/or service that is being provided. It may include , but is not limited to, the following information:
  • Identify data including your name, date of birth and candidate number
  • Contact data including your home address, email address and phone number
  • Exam results
  • Voice or video recording or other information by which we can tell who you are
  • Data may be collected from you directly or from your school

According to the page 12 (section C.8.1) in the 2025 Cambridge Handbook, “we will use their personal data (for example, their name, candidate number and where relevant audio or video evidence of a candidate’s performance)….”  See https://www.cambridgeinternational.org/Images/723185-cambridge-handbook-2025.pdf

  1. According to its Candidate Privacy Policy, how this vendor uses your personal data is that sometimes we may need to use your personal data where it is necessary to fulfill the requirements of a contract that you may be a party to. Apart from that we will only use personal data where we have what is known as a legitimate (business) interest or purpose.

The following activities require the use of personal data in order for us to provide our products and/or services:

  • Developing and delivering academic and vocational qualifications/programs, including the development of assessment materials (such as exam questions and marking guidelines), the collection, marking and grading of exam scripts, the administrative systems used to support these processes, and the issuing of awards and certificates.
  • Developing and delivering publications and other resources that support learning in connection with such academic and vocational qualifications.
  • Monitoring the performance of those involved in the provision of such academic and vocational qualifications.
  • Investigating allegations of misconduct in relation to the sitting of exams.
  • Ensuring the appropriate examination facilities are available to those with specific requirements .
  • Checking that an individual (e.g., a candidate) is who they say they are.
  • Handling complaints.

The following are examples of other activities which our use of personal data:

  • Carrying out research in the field of education and qualification delivery, setting standards and other activities that are required to ensure that our services are delivered to a high standard and that candidates are protected.
  • Understanding the needs of candidates and other users of our services (including qualifications).
  • Providing training to individuals, such as teachers and examiners, in connection with our services.
  • For purposes connected with our internal business, including understanding and protecting ourselves from risks, protecting any personal data that we hold, internal record-keeping and carrying out business checks.

We may use personal information provided by you to carry out marketing and market research. We will only do this where we have your consent to contact you for these purposes. You can opt out of these contacts at any time.

We may sometimes use a method known as profiling. In part, this method involves automatically collecting certain information in order to understand how people might behave, but we will not make decisions based on this without some human involvement. We occasionally use this method when someone is doing a test on a computer where his or her activity has been questioned, or to assist with the test itself.

According to page 12 (section C.8.1) in the 2025 Cambridge Handbook, personal data will be used “for the purposes of delivering our qualifications through your centre. This includes processing exam entries and results, marking exam scripts, issuing certificates, processing enquiries about results and investigating cases of malpractice.”  Furthermore, “… when applications for access arrangements, special consideration or the withdrawal of entries are made, … special categories (sensitive) of personal data [will be used] for the purposes of processing these applications….”  Page 12 (section C.8.2) in the 2025 Cambridge Handbook goes on to state that personal data will be processed for the following legitimate business purposes:

  • 2.1 to carry out research, standards setting and other activities that are related to the business of delivering qualifications (including assessments), all of which are aimed at ensuring the delivery, as well as integrity and improvement, of our qualifications and the protection of candidates
  • 2.2 to understand the needs of candidates and other users of our qualifications and carry out marketing (although we will not contact candidates/parents/guardians by email without first seeking their consent)
  • 2.3 to provide training to those involved in providing educational services in relation to our qualifications, for example, teachers and examiners
  • 2.4 for internal business purposes, including managing our risks, protecting the security of personal data in our possession and carrying out internal record-keeping, audits and investigations, including into malpractice
  • 2.5 to share the personal data with other parts of our organisation, including the University of Cambridge, Cambridge University Press & Assessment, and agents and representatives (for example, examiners, consultants and sub-contractors), which process the personal data on our behalf for the purposes described in this Cambridge Handbook
  • 2.6 to share the personal data with the Universities and Colleges Admissions Service (UCAS), other universities and, where appropriate, potential employers in order to facilitate the candidate’s relevant applications
  • 2.7 NEW to share the personal data with government or regulatory authorities for the purpose of evidencing outcomes, progression and participation in relation to Cambridge’s products and services
  • 2.8 to comply with applicable law or a court order or governmental regulation or for the purpose of any criminal or other legal investigation or proceeding here or abroad.

According to page 12 (section C.8.3) in the 2025 Cambridge Handbook, Cambridge “may use anonymised data (that is, data that does not identify a candidate) and pseudonymised data (that is, data that is anonymous to the people who receive it) for research purposes, and may share that data with third parties, also for research purposes. The third-party recipients of such anonymised or pseudonymised data are required to abide by strict data protection principles in their handling of the data and are also bound by a duty of confidentiality.”

  1. According to its Candidate Privacy Policy, regarding when the collected information will be destroyed, “We may keep personal data only for as long as necessary to fulfill the purposes for which we are processing your personal information unless the law permits or requires longer. For example, we might keep your personal data for quality assurance of the service we have provided, or we might need to keep it to defend future legal claims.”
  2. According to its Candidate Privacy Policy and 2025 Handbook, the terms of re-disclosure include sharing personal data:
  • With Cambridge University and other affiliated businesses and organizations which are owned by it;
  • With people and organizations that represent us (such as examiners);
  • With other people and/or businesses who provided services on our behalf;
  • With other schools or educational establishments which you attend;
  • With the Universities and College Admissions service, other universities and other organizations/businesses, in order to help candidates that are making applications; and
  • When required by law.

The United Kingdom and countries inside the European Economic Area have specific laws which protect the way personal data is used. We may transfer personal data to countries outside of the European Economic Area where personal data is not protected in the same way (usually to other businesses who provide services on our behalf). In such cases, we will make sure that suitable safeguards are in place to protect the personal data. What that means is that whoever we transfer data to will have to agree to protect the personal data in the appropriate way. You can request further information about this my emailing privacy@cambridge.org

Page 12 (section C.8.4) in the 2025 Cambridge Handbook, explicitly states, “we may transfer Candidate Data outside the United Kingdom and/or European Economic Area (EEA), for example for the processing of entries and results, and to provide Customer Services support. Such transfers of data are conducted in accordance with the Standard Contractual Clauses approved by the European Commission or in accordance with the UK’s equivalent Standard Contractual Clauses.”

Sincerely, Pasco County Schools

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Please fill out the consent form below:

Student Name:                                                                                                  Student ID#:                         

_____   Yes.  I consent for my child to utilize the Cambridge Exam Cycle testing platform.

              No. I do not give consent. *Note: By selecting, No, your child will not have the opportunity to take the exam(s) that is/are aligned to the Cambridge International Education Program.

Parent/Guardian Signature:                                                                                        

Printed Parent/Guardian Name:                                                                                 

Date: