--- title: "SIMON Subprocessor Register" canonical: "https://simon-knowledge-hub.refined.site/space/SHG/3918233603/SIMON%20Subprocessor%20Register" format: markdown --- > **Version:** 1.2 > **Effective Date:** 8 September 2026 > **Document Owner:** SIMON Privacy and Security Team > > [Return to End-User Licenses Agreement ](https://simon-knowledge-hub.refined.site/space/SHG/3484450834/EULA+-+++End-User+License+Agreement) > Macro (toc) ## Purpose This Subprocessor Register identifies third-party service providers that may process, store, transmit, or receive customer data in connection with the provision, operation, support, and enhancement of SIMON and related services. SIMON engages subprocessors only where necessary to deliver services requested by schools or where a school elects to enable an optional integration. All subprocessors are subject to appropriate contractual, privacy, confidentiality, and security obligations. --- ## Data Ownership All customer data entered into, created within, or generated by SIMON remains the sole property of the relevant school or education authority. SIMON acts solely as a service provider on behalf of the school and does not acquire ownership rights over customer data. SIMON does not sell, mine, profile, monetise, or otherwise use customer data for independent commercial purposes. Where optional integrations are available, schools determine whether those integrations are enabled and what information is shared with third-party providers. --- ## Subprocessor Categories SIMON utilises three categories of subprocessors: #### **Infrastructure and Platform Service Providers** Service providers engaged to host, operate, secure, support, and deliver SIMON services. #### **Integration Service Providers** Service providers engaged to facilitate secure data exchange between SIMON and approved third-party applications. #### **School-Enabled Integrations** Third-party services that schools may choose to activate to extend the functionality of SIMON. Data is shared with these providers only when the integration has been enabled by the school. SIMON does not activate optional integrations or share customer data with those providers without configuration or approval by the school. --- ## Infrastructure and Platform Service Providers ### CEnet **Service Provided:** Managed hosting and infrastructure services **Purpose:** Hosting, infrastructure, storage, backup, disaster recovery, monitoring, and operational support for SIMON deployments. **Data Categories:** Student information, parent/carer information, staff information, attendance records, assessment data, wellbeing records, learning content, operational data, user account information, and audit logs. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** Australia **Notes:** Where a school elects to host SIMON within a CEnet-managed environment, CEnet may store and process customer data solely for the purpose of providing hosting and operational services.   ### HordernIT (SIMON Everywhere) **Service Provided:** Mobile application services **Purpose:** Delivery of SIMON Everywhere functionality and school communications via mobile devices. **Data Categories:** Student, parent/carer, staff, authentication and school operational information required to provide mobile application functionality. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** May process and store data required for service delivery. **Primary Processing Region:** Australia --- ## Integration Service Providers ### Wonde **Service Provided:** Education data integration platform **Purpose:** Secure exchange of information between SIMON and approved educational applications and services. **Data Categories:** Student, staff, class, timetable and organisational information. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** May process and temporarily store data required to facilitate integrations. **Primary Processing Region:** Australia, United Kingdom and other regions utilised by Wonde for service delivery. --- ## School-Enabled Integrations The following integrations may be enabled by a school to extend the functionality of SIMON. Where enabled, relevant customer data may be shared with the third-party service for the purposes described below. Schools remain responsible for determining whether an integration is appropriate for their operational, educational, privacy, security, and regulatory requirements.   ### Intellischool **Service Provided:** Educational data analytics and visualisation platform **Purpose:** Analysis, aggregation, reporting, and visualisation of school data to support educational outcomes, operational decision-making, strategic planning, student wellbeing initiatives, and leadership reporting. **Data Categories:** Student information, academic results, attendance data, wellbeing data, behavioural data, organisational data, and other data sources authorised by the school. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by Intellischool service arrangements. **Notes:** Intellischool may receive and process data from SIMON and other school-authorised systems to provide dashboards, reporting, analytics, benchmarking, and data-driven insights.   ### Enquiry Tracker **Service Provided:** Admissions and enquiry management platform **Purpose:** Management of enrolment enquiries and prospective student information. **Data Categories:** Prospective student information, student information, parent/carer information, contact details, application data, enrolment records, communications, and related admissions information. **Data Passes through SIMON Infrastructure: **Yes  **Customer Data Stored:** Yes **Primary Processing Region:** As determined by Enquiry Tracker service arrangements. **Notes:** Enquiry Tracker may receive and process data from SIMON and information collected directly through enrolment and admissions processes.    ### EnrolHQ **Service Provided:** Student enrolment, admissions, and marketing platform **Purpose:** Management of prospective student enquiries, admissions workflows, enrolment applications, family engagement, marketing activities, and enrolment lifecycle processes. **Data Categories:** Prospective student information, student information, parent/carer information, contact details, application data, enrolment records, communications, and related admissions information. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by EnrolHQ service arrangements. **Notes:** EnrolHQ may receive and process data from SIMON and information collected directly through enrolment and admissions processes.   ### Passtab **Service Provided:** Visitor and attendance management platform **Purpose:** Visitor registration, school attendance and related administrative functions. **Data Categories:** Visitor information, student information, staff information, guardian contact information, attendance and access records. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by Passtab service arrangements.   ### VPass **Service Provided:** Visitor and attendance management platform **Purpose:** Visitor registration, school attendance and related administrative functions. **Data Categories:** Visitor information, student information, staff information, guardian contact information, attendance and access records. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by VPass service arrangements.   ### Schoolzine **Service Provided:** School communications and newsletter platform **Purpose:** Distribution of newsletters, alerts, notifications and community communications. **Data Categories:** Authentication. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** No **Primary Processing Region:** As determined by Schoolzine service arrangements.   ### Professional Advantage (Microsoft Dynamics 365 Business Central) **Service Provided:** Financial and business management platform **Purpose:** Financial management, accounting and related school administration processes. **Data Categories:** Financial, billing and operational school data, parent and student information. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by Professional Advantage and Microsoft service arrangements.   ### Turnitin **Service Provided:** Academic integrity and originality checking services **Purpose:** Assessment submission analysis and academic integrity verification. **Data Categories:** Student submissions, assessment information and user account information. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by Turnitin service arrangements.   ### Studiosity **Service Provided:** Online learning support services **Purpose:** Academic assistance, tutoring and feedback services. **Data Categories:** Student identity information and submitted learning content. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by Studiosity service arrangements.   ### EdSmart **Service Provided:** Forms, workflows and consent management platform **Purpose:** Digital forms, approvals, permissions and workflow automation. **Data Categories:** Student, parent/carer and staff information included within forms and workflows. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by EdSmart service arrangements.   ### Google Classroom **Service Provided:** Learning management and classroom collaboration platform **Purpose:** Learning content delivery, assignments, coursework management and classroom collaboration. **Data Categories:** Student and staff account information, class memberships, assignments and learning activities. **Data Passes through SIMON Infrastructure: **Yes **Customer Data Stored:** Yes **Primary Processing Region:** As determined by Google service arrangements.   ### Microsoft OneNote **Service Provided:** Digital note-taking and educational collaboration platform **Purpose:** Classroom content creation, storage and collaboration. **Data Categories:** Student and staff educational content and account information. **Data Passes through SIMON Infrastructure: **Yes  **Customer Data Stored:** Yes **Primary Processing Region:** As determined by Microsoft service arrangements. --- ## Subprocessor Assessment and Oversight SIMON assesses subprocessors before engagement and periodically thereafter as part of its Information Security Management System (ISMS). Assessments may consider: - Information security controls - Privacy and data protection practices - Data residency considerations - Regulatory compliance obligations - Operational resilience and availability - Incident management capabilities - Independent certifications and assurance reports - Contractual confidentiality and security commitments Where appropriate, subprocessors are required to enter into contractual agreements governing the protection, confidentiality, and processing of customer data. --- ## Changes to Subprocessors SIMON may add, replace, or remove subprocessors from time to time. Where a change materially affects the processing, storage, security, access to, or transfer of customer data, SIMON will provide advance notice to the school's nominated administrative, contractual, privacy, or technical contacts. Where practicable, SIMON will aim to provide at least **30 days' notice** before a material subprocessor change takes effect. Notification may be provided through customer communications, release notes, service notifications, or updates published on the SIMON website. --- ## Material Changes For the purposes of this Register, a material change may include: - Appointment of a new subprocessor that may access customer data. - Changes to hosting arrangements or processing locations. - Significant changes to services provided by an existing subprocessor. - Changes that materially affect the security, privacy, processing, or storage of customer data. - Events such as mergers, acquisitions, or ownership changes that may affect a subprocessor's handling of customer data. --- ## Questions or Concerns Schools with questions regarding this Register, a listed subprocessor, or a proposed material change may contact: **Security Contact:** [support@simonschools.net](mailto:support@simonschools.net)  **Document History** | | | | | --- | --- | --- | | **Version** | **Date** | **Description** | | 1.2 | 8 September 2026 | Updated publication | --- ## Data Ownership Statement For the avoidance of doubt, all customer data remains the property of the school or education authority. SIMON and its subprocessors process customer data solely for the purpose of providing contracted services to the school. Schools retain control over their data and over the activation and use of optional third-party integrations. Schools remain responsible for determining whether any communication to staff, students, parents, guardians, or other end users is required under their own policies or legal obligations. --- [Return to End-User Licenses Agreement ](https://simon-knowledge-hub.refined.site/space/SHG/3484450834/EULA+-+++End-User+License+Agreement)