LEARNERS PROGRESS COLLEGE PRIVACY NOTICE
Learners Progress College (“the College”) is registered as a Data Controller for the purposes of the Data Protection Act and from 25 May 2018, the General Data Protection Regulation and is committed to protecting your personal information and being transparent about what information we hold about you, how we use it and who we share it with.
This privacy notice informs you what to expect when the College collects personal information.
Why we collect personal information
The College collects and processes personal data relating to its learners to effectively manage your learning and to meet its statutory obligations as a provider of further and higher education.
HOW WE COLLECT YOUR INFORMATION
We may collect your personal information in a number of ways, for example:
- from the information you provide to us when you express your interest in studying at the College
- when you apply to study at the College and complete the formal admission process or via the Universities and Colleges Admissions Service (UCAS)
- when you communicate with us by telephone, email or via our website
- in various other ways as you interact with us during your time as a student of the College, for the various purposes set out below
- from third parties, for example from your previous or current school, sixth form college, university or employers who may provide a reference about you or who may sponsor your studies
THE TYPES OF INFORMATION WE COLLECT
We may collect the following types of personal data about you:
- your name, and contact information such as address, email address and telephone number, as well as your date of birth, national insurance number (or other tax identification number) and your passport number or national identity card details, country of domicile and your nationality. We will also allocate you a unique student number
- information relating to your education and employment history, the school(s), sixth form college(s) and other colleges or universities you have attended and places where you have worked, the courses you have completed, dates of study and examination results. We will also keep records relating to assessments of your work, details of examinations taken, your predicted and actual examination grades and other information in your student record
- information about your family or personal circumstances, and both academic and extracurricular interests, for example where this is relevant to the assessment of your suitability to receive a bursary or in order to provide you with appropriate pastoral care
- sensitive personal data and information about criminal convictions and offences, including:
* information concerning your health and medical conditions (e.g. disability and dietary needs);
* certain criminal convictions (e.g. for students on nursing programs, following completion of an annual declaration of “good character”); and
* information about your racial or ethnic origin; religion or similar beliefs; and sexual orientation
HOW WE USE YOUR INFORMATION
The purposes for which we may use personal information (including sensitive personal information) we collect during a student’s association with us include:
- recruitment and admissions;
- academic matters, including:
* the provision of our core teaching, learning and research services (e.g. registration, assessment, attendance, managing progress, academic misconduct investigations, certification, graduation);
* maintaining learner records;
* assessing your eligibility for bursaries and scholarships, etc.
* learner destination surveys;
* providing library, IT and information services;
* non-academic matters in support of our core services, including but not limited to:
* providing student support services (Disability and Additional Learning Support, Careers and Employability Services, Health and Wellbeing Services);
* monitoring equal opportunities;
* safeguarding and promoting the welfare of learners;
* ensuring learners’ safety and security;
* managing the use of social media;
* administering finance (e.g. fees, bursaries);
* other administrative purposes, including:
* carrying out research and statistical analysis such as learner satisfaction surveys;
* carrying out audits (e.g. to ensure compliance with our regulatory and legal obligations);
* providing operational information (e.g. providing IT support, information about building closures or access restrictions on campus, or safety advice);
* promoting our services (e.g. future learning opportunities, or other events happening on and off college);
* preventing and detecting crime;
* dealing with grievances and disciplinary actions;
* dealing with complaints and inquiries.
THE LEGAL BASIS FOR PROCESSING YOUR INFORMATION
We process your personal data as part of our public interest task of providing an education to you and to meet our statutory obligations as an education provider. In this respect, we use your personal data for the following:
- to interact with you before you are enrolled as a learner, as part of the admissions process (e.g. to send you information or answer enquiries about our courses)
- once you have enrolled, to provide you with the services as set out in your Learning Agreement;
- to deal with any concerns or feedback you may have;
- for any other purpose for which you provide us with your personal data.
- to monitor and evaluate the performance and effectiveness of the College, including by training our staff or monitoring their performance;
- to maintain and improve the academic and corporate management of the College;
- to promote equality, diversity and inclusion and safeguarding throughout the College;
- to seek advice on our rights and obligations, such as where we require our own legal advice;
- recovering money you owe to us;
- for fundraising purposes.
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data for the following:
- to meet our compliance and regulatory obligations to Government agencies, funding and exam bodies, compliance with anti-money laundering laws and safeguarding requirements;
- for the prevention and detection of crime;
- in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
We may also process your personal data where:
- it is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional);
- it is necessary to protect your or another person’s vital interests; or
- we have your specific or, where necessary, explicit consent to do so.
SHARING INFORMATION WITH OTHERS
For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with staff internally and certain third parties.
You are given the opportunity to opt out of some of these data sharing arrangements, for example when you register with us, but you should carefully consider the possible impact of doing this. Unless an opt-out is in place, we may disclose limited personal data to a variety of recipients including but not limited to:
- our employees, agents and contractors where there is a legitimate reason for their receiving the information, including:
* third parties who work with us to provide learners support services (e.g. counselling);
* third parties who are contracted to provide IT services for us;
* organisations operating anti-plagiarism software on our behalf
* internal and external auditors.
- those with an interest in tracking student progress and attendance, including:
* learner sponsors (e.g. the Student Loan Company, NHS);
* current or potential education providers (for example, where you take part in an exchange programme as part of your course);
* current or potential employers (to provide references and, where learners are sponsored by their employer and/or where you take part in a placement, to provide details of progress/attendance);
- professional and regulatory bodies in relation to the confirmation of qualifications, professional registration and conduct and the accreditation of courses;
- government departments and agencies where we have a statutory obligation to provide information:
* the identification of young people not in education, employment or training (NEET)
* the Education and Skills Funding Agency (ESFA)
* the Higher Education Funding Council for England (HEFCE)
* the Higher Education Statistics Agency (HESA)
* Council Tax and Electoral Registration Officers at relevant local authorities (for the purpose of assessing liability for Council Tax and for electoral registration purposes));
- crime prevention or detection agencies (e.g. the police, the Department for Work and Pensions and Trading Standards);
- parents, guardians, and next-of-kin (where there is a legitimate reason for disclosure);
- third parties conducting surveys, for example the National Student Survey.
If you have attended an educational establishment in the UK since 1994 then we will hold personal data about you in some or all of the following databases:
- The Education and Skills Funding Agency (ESFA)
- Individual Learner Record (ILR)
- Learning Records Service (LRS)
- Office for Students
- Higher Education Statistics Agency (HESA)
- HESA Destinations of Leavers from Higher Education in the UK (DLHE)
- National Student Survey (NSS)
- UCAS Admissions Data
WHEN VISITING OUR WEBSITE
- Filling forms
When filling forms the personal data you provide, will be handled according to this Privacy Notice. This also refers to when clicking boxes e.g. “Newsletter sign-up”. We advise against filling any personal data in the field for the message.
- Online Chat
We record your name and IP address during online chat conversations. This is a 3rd party tool which is based outside of the EU. However, they do comply with Google Data Protection rules and following a GDPR update to this tool prior to 25 May 2018, your personal chat data will be deleted after the purposes for collecting this information has been completed.
USE OF PERSONAL PHOTO AND VIDEO IMAGES
A photo or a video of you may have already been on our website prior to 25th May 2018 and you are hereby informed that you can request to “opt out” in other words ask us to remove it which we will endeavor to do once given instructions to. However, we do appreciate your privacy but your experience is a valuable tool to encourage other learners to benefit from support to embark on a career in the same manner that you did. We are happy to remove your photo or video if you require us to do so in keeping with GDPR compliance policies.
We often take photographs or films at events that we host, so that we can use them for marketing purposes. Images taken for official College use may be covered by the Data Protection Act 1998, so our policy is to advise students and visitors when and why their images are being taken at each event.
If you are attending one of our events (such as an Open Day) and you don’t want your image to be used then you can simply opt out. Just let the photographer and a member of our staff know. That way we will instruct our photographer not to take any images of you. You are also advised to try to stay out of the shot, as you may appear in the background in error.
If you don’t opt out then your image may be used (which could be a photograph or a moving film) in one or more of the following ways:
- Prospectuses and other promotional materials
- As part of an advert or advertisement feature (which includes possible use on outdoor media such as buses and billboards)
- On our website, intranet, or the websites of our partners
- On CDs or DVDs we distribute as part of a marketing campaign
- In non-university publications which our marketing team have approved and authorised
Where you have previously studied at the College or commenced an application process with us before, then we will send you information about the courses we provide on the basis of our legitimate business interests. In doing so, we will comply with the requirements of the “soft opt in” and offer you an opportunity to refuse marketing when your details are first collected and in subsequent messages (by way of an unsubscribe feature on marketing emails and text messages).
Any other marketing activity we carry out not directly related to your course of study will be on the basis of explicit consent.
FUNDRAISING AND ALUMNI RELATIONS
We pass some of your personal data to the Learning Revolution Trust (LRT) following successful application for additional funding is applicable. The LRT are a registered charity which aims to provide financial assistance to students to enable them to complete their chosen course of study.
Former students may be contacted as part of our Alumni communications. However, you can request to be removed from this database at any time after leaving the College.Acceptable Use of College Equipment
We keep an eye on how you use the College’s equipment and computers and what websites you visit when you are browsing the internet at College. This is because we have legal obligations to protect you, and we also have a legitimate interest in making sure you are using our computer equipment correctly and that you are not looking at any inappropriate content.
If you want to browse the internet privately, you will need to use your own devices which are not linked to the College’s network or internet connection.
HOW DO WE PROTECT YOUR INFORMATION?
We have robust technical and organisational systems and policies in place to manage and protect your information. These measures include data encryption, restricted access rights to personal information and up to date security software to ensure confidentiality and to guard against unauthorised access, unlawful processing, accidental loss, damage and destruction.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. All information collected and processed on behalf of the ESFA will be held as long as is necessary to fulfil our contractual obligations. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
TRANSFERRING INFORMATION OUTSIDE OF EUROPE
We do make use of suppliers who will store and process personal data outside of Europe. However, we have a third party processing agreement in place with each of these suppliers compliant with current data protection regulations.
CHANGES TO YOUR PERSONAL INFORMATION
Please tell us promptly about any changes to the information we hold about you. This is particularly important for your contact details. You can do this by contacting a member of the Admissions Team and completing a Change of Personal Details Form or by emailing Dwaine@learnersprogress.co.uk.
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us to erase your personal data;
- to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
- to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
REFUSAL TO PROVIDE PERSONAL INFORMATION
If you have given your consent and you wish to withdraw it, please contact our Data Protection Officer using the contact details set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services to you.
If you have any queries about this privacy notice or how we process your personal data, you can contact our Data Protection Officer by:
Telephone: +44 (0) 020 3475 5499
Post: The Data Protection Officer, Learners Progress College, 3 Oakfield House, Ilford, IG1 1EF
To request access to the personal data that we hold about you, you may contact our Data Protection Officer by using the contact details above or by contacting the College Reception.
If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner.
You can find out more about your rights under data protection legislation from the Information Commissioner’s Office website available at: www.ico.org.uk.
CHANGES TO THIS PRIVACY NOTICE
We keep this Privacy Notice under regular review. Any changes we make to our Privacy Notice in the future will be notified to you by email.
This policy was last updated on 24 May 2018.