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Privacy Notice – Students


Purpose of this statement

Your privacy is important to us. This privacy notice explains what personal data DN Colleges Group collects from you, through our interactions with you and through our products, and how we use that data.

DN Colleges Group is committed to protecting the privacy and security of your personal information. As a “data controller” we are responsible for deciding how we hold and use personal information about you.

We are required under data protection legislation to notify you of the information contained in this privacy notice.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).

It applies to all current and former students, and applicants.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

DN Colleges Group is registered under the Data Protection Act 2018. This means that the purposes for which the College collects, and processes personal data is notified to and registered with the Information Commissioner’s Office (ICO), under the Registration Number ZA341759.

DN Colleges Group (also referred to below as ‘we’) will collect the following information from you, which we need in order to carry out our functions. The legal grounds for processing the information are outlined under each section and where your consent is required, we give you the opportunity to opt in.

Data protection principles

We will comply with GDPR. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.

Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

Relevant to the purposes we have told you about and limited only to those purposes.

Accurate and kept up to date.

Kept only as long as necessary for the purposes we have told you about.

Kept securely.

The kind of information we hold about you

Personal data is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal data about you:

Personal data and where appropriate Special Categories of Data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:

  • Contact details such as first name, middle names, surname, address, personal and work email addresses, personal and work telephone numbers
  • Financial details e.g. student Loan, bursary, funding agreement, bank details, national insurance number.
  • Other details relating to your financial situation e.g. Student Loan, Bursary, Free School Meals, Travel Assistance, benefits information, employment status and household situation
  • Location e.g. physical or electronic information which identifies your location
  • Online/Unique identifiers such as student ID codes, Unique Learner Number, online/website details e.g. usernames, passwords, session IDs, geo locations, device/pps ID, IP addresses, cookies, RFI
  • Special Categories of Data which may include information about racial and ethnic origin, religion, politics, trade union membership, genetic and biometric data (e.g. fingerprints used for ID purposes), health, mental health, physiological and disability information, sex life and sexual orientation, behavioural characteristics, social identity, cultural background, facial Images, philosophical beliefs and economic data
  • Personal non-contact details e.g. date of birth, age, gender, photographs, video imaging, passport details, visa details, driving licence details
  • Course information and exam timetable information e.g. details of the courses you are or have been enrolled on and exam information
  • Student work e.g. paper and electronic based worksheets, books, assessments and exam papers
  • Behaviour and attendance information
  • Learning Support Information
  • References e.g. School/College/University and Character References and Employment Details
  • Parent/Legal Guardian/Next of Kin/Emergency Contact details (the details we hold will depend on whether the student is under the age of 18).
  • Main school details if you attend the college as part of an off school site provision
  • Social Worker details and other agency professionals linked to your care
  • Academic information exam results/qualifications/academic achievement/mandatory and voluntary professional body memberships/accreditations/certifications/training records/ Individualised Learner Record (ILR) data
  • Complaints/Grievances details such as Student, staff, public and other complaints to which you are a named party or involved in the investigation process
  • Health and Safety information such as accident records, risk assessments, occupational health records, personal protective equipment records, industrial disease monitoring, insurance and legal claims, disability and access requirements
  • Criminal and Conviction Information such as Disclosure Barring Service (DBS) checks, safeguarding risk assessments in relation to disclosures provided to us (see below) and other notifications (certain courses and placements require DBS checks to be carried out).

How is your personal information collected?

Whilst most of the information you provide to us is mandatory or necessary to enable us to provide services to you or conduct our core activities as an education provider, some of it is provided to us on a voluntary basis. To comply with data protection legislation, we will inform you whether you are required to provide information to us or if you have a choice in this.

We collect Student and Apprentice personal data in a variety of different ways for example paper and electronic forms via our website and student portal, by email and verbally.

We also collect your personal information from difference sources for example when you make enquiries with us; when you provide your details for marketing purposes; when you register for events such as open days and when you register as a student with us or provide us with any other information during your course or apprenticeship. Your personal information may also be provided to us by various third party sources which may include your legal guardian, current or former school, college or university, past, current and future employers and placement providers, UCAS, student loan companies, Connexions and other careers services and other institutions involved in joint programmes and sometimes we purchase personal data contact lists from data companies.

Your information may be shared with us by the Police, Social Care, Health, Youth Offending Team and sometimes voluntary agencies where there is a safeguarding concern or in relation to Public Protection.

We will ask to see your identification data to ensure we have your correct details and can verify your identity before accepting you on a course and where required we may ask to see your ID documents at various points during your study with us where your student ID is not sufficient. We may take copies for proof / auditing purposes where necessary.

Situations in which we will use your personal information

The situations in which we will process your personal information are listed below which enables us to comply with our various legal and contractual obligations and conduct our core education provider and business activities for example:

  • Administration in connection with courses, education and training services we provide you with and facilitate student learner agreements
  • To enable us to work in partnership and share necessary information with professional advisers, employers, partner agencies, voluntary initiatives and programme representatives such as attendance details and progress updates
  • To enable us to work with Connexions and other careers services
  • To enable us to speak to parent/carers/legal guardians and next of kin as necessary
  • To enable us to collect and make payments in relation to courses, education and training services, expenses, provision of goods and library and ID card fines
  • To enable us to record your destination upon leaving the college e.g. continuing education elsewhere or employment
  • To enable us to deal with student finance administration, funding agreements, financial assistance and bursary applications, student accommodation
  • To enable us at the request of the student to confirm student details to third parties such as course details, enrolments dates, eligibility to benefits and financial status e.g. Council Tax reduction for full time students or NUS membership
  • To enable us to provide mandatory training and voluntary training where necessary
  • To perform checks in connection with enrolment onto courses and training which may include obtaining references, details about prior professional qualifications and academic checks, DBS checks, Criminal offence and conviction data from Police, Visas, Right to Work in the UK (for Apprentices), Driver Checks
  • To enable us to distinguish between home and overseas students by origin, to obtain the numbers of students who live in particular EU countries and elsewhere abroad and to calculate participation rates and to monitor cross border data flow
  • To enable us to fulfil our obligations in relation to the provision of Special Education Needs support for example, participating in Educational Health Care Plans and meetings, providing additional Learner Support and carrying out risk assessments in connection with any needs under the Equality Act
  • To provide access to DN Colleges Group Systems
  • To provide a safe and secure place of study and workplace through provision of Health and Safety and Safeguarding services
  • To enable us to carry out safeguarding risk assessments for applicants and current students
  • To take photographs for the purpose of providing a Student ID card
  • To record entry and exit to our buildings/campuses
  • To use CCTV recording and photographic images for safety and security purposes
  • To assist in the detection, investigation and prevention of crime
  • To comply with our Data Subject Access Request and Individuals’ Rights obligations under the GDPR
  • To produce exam and achievement certificates, exam timetables and registration and administration of exams, academic qualifications, awards and accreditations
  • In connection with student and/or employee complaints, disputes, grievance, disciplinary and malpractice
  • To provide details of eligible students to the Student Union in accordance with the College Code of Practice relating to the Student Union
  • In connection with Alumni Membership and fundraising initiatives
  • To assist with outreach and widening participation initiatives
  • Statistical and research purposes to;
    • monitor Equality and Diversity
    • inform the development of student and apprentice recruitment and retention policies
    • collate data collection/statistical returns to the other funding bodies
    • validating/awarding bodies and partnership agreements
  • To enable us to share personal data where required with the ESFA and other services run by the ESFA, DfE and partner organisations – see Data Sharing below, (where the law allows it or they have a legal obligation to do so) will be used for the purposes of:
    • Administration for example to enable the Learning Records Service (LRS) to issue you with a Unique Learner Number (ULN)
    • Submission of individualised learner records (ILRs). The data collected is used to calculate funding due to FE providers, for performance monitoring, future planning and to ensure that public money is being spent in-line with government
    • Provision of career and other guidance
    • Statistical and research purposes, relating to education, training, employment and well- being prevention or detection of crime

 

 

How we will use information about you (lawful basis)

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:

  • Comply with a legal obligation
  • Comply with a contractual obligation
  • Carry out a task in the public interest
  • Less commonly, we may also use personal information about you were;
  • You have given us consent to use it in a certain way
  • We need to protect your vital interests (or someone else’s interests)
  • We have legitimate interests in processing the data

The purpose of processing this data is to enable DN Colleges Group to:

  • Establish and maintain effective governance
  • Meet statutory obligations
  • Facilitate a safe environment and as part of our safeguarding obligations
  • Undertake equalities monitoring
  • Ensure that appropriate access arrangements can be provided for those who require them

The majority of the processing we carry out in relation to DN Colleges Group is necessary to comply with various legal and contractual requirements such as:-

Health and Safety

  • Health and Safety at Work etc. Act 1974 (& associated regulations and codes of practice)
  • Equality Act 2010

Safeguarding/Education

  • Prevent Duty
  • Section 175 of the Education Act 2002
  • Further and Higher Education Act 1992
  • ‘Keeping children safe in education Statutory guidance for schools and colleges’ Guidance (gov.uk) and adult safeguarding guidance
  • Validating/Awarding Body Terms and Conditions/Requirements

Statutory (ESFA) / Other Funding requirements

Where the processing of your personal data relies on consent as the lawful basis and you have provided us with your consent for this, you may withdraw this consent at any time. We will make this clear when requesting your consent and explain how you go about withdrawing consent if you wish to do so.

Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify our use of your data.

Where we ask you for information for which we do not have a contractual or legal basis for processing, we will either tell you the legitimate basis for processing or obtain your consent.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or fulfil our legal obligation to another organisation (for example the ESFA who fund courses in colleges).

How we store this data (Data security)

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure and Barring Service (DBS) Checks

For certain courses and placements, we will require a Disclosure and Barring Service (DBS) or similar check for non-UK students and apprentices to be carried out, this check helps employers make safer recruitment decisions and prevent unsuitable people from working with vulnerable groups, including children. We will let you know if this applies to your course or placement. As part of the DBS check application process, as required by the DBS, we will provide you with a separate Standard/Enhanced Check Privacy Policy for Applicants and ask you to confirm you understand how the DBS will process your personal data and the options available to you when submitting an application. Further information is available at www.gov.uk/dbs.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your employment with us.

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Use of your personal information for marketing purposes

Where you have given us consent to do so, we may send you marketing information to your personal email and/or college email account or text promoting events, campaigns, charitable causes or services that may be of interest to you. You can “opt out” of receiving these texts and/or e-mails at any time by clicking on the “Unsubscribe” link at the bottom of any such communication, or by contacting the Registry department.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you in writing.

Data sharing

We do not share information about you with any third party without your consent unless the law and our policies allow us to do so.

To enable us to comply with our legal and contractual obligations, we may at times need to share some of your personal information (and in some instances special categories of data) as follows:

  • Parent/Carer/Legal Guardian or other family member or associate or representative students and apprentices choose to nominate as a contact or emergency contact. If you are under 18 we will share details of your education with those who have parental responsibility for you unless you notify us of a valid reason why we should not do this or we have been advised by our Safeguarding Team, Social Services or other official agency of a reason not to do so; the details will include behaviour, attendance, academic progress, learner support, wellbeing and other details required to keep you safe whilst you attend college
  • We will not discuss the application process with anyone other than the prospective student or apprentice unless they have given us consent to do so or, they are below the legal school leaving age or they are of an age that requires parental consent. This means that without consent we cannot discuss the application status, offers, interview details etc. with Parents/Carers/Legal Guardians or other family members or associates or representatives unless the student or apprentice applicant has requested this during the application process or the prospective student or apprentice is of legal school age and there is a data sharing agreement in place with the local authority or other agency or body. This is in our Student and Apprenticeship Privacy
  • Local and Combined Authorities/Social Care Teams/Virtual Schools
  • Your information may be shared with the Local Safeguarding Boards, Local Authority Designated Officer, Police, Social Care, Health, Youth Offending Team and sometimes voluntary agencies for child protection and safeguarding purposes or in relation to Public Protection
  • Police and Enforcement Agencies – to assist in the detection, investigation and prevention of crime this includes the Courts and Coroner Service, please note that we will provide where requested student names, addresses, contact details, next of kin or parent/carer/legal Guardian details and confirmation of attendance as part of routine police enquiries or as part of our onsite college Police liaison agreement. Any details other than these will only be provided on receipt of a signed Police/Enforcing Body Disclosure Request
  • Professional advisers, partner and support agency representatives e.g. Stronger Families Programme, Connexions and other career services, social workers and medical professionals, voluntary and charitable organisations and in connection with other programmes and initiatives
  • Trade, employers, education institutions and professional organisations in connection with reference requests and sharing of information in relation to courses funded by employers, placements, work experience, career opportunities and outreach and widening participation
  • UCAS
  • Sharing of exam timetables and other relevant information internally and with students and others at the student’s request
  • Emergency services in the event of an emergency
  • Health and Safety Executive – to report accident information/investigation purposes
  • Main school/Pupil Referral Unit – we will share details regarding attendance and behaviour if you attend the college as part of an off school site provision
  • Trade Unions/Governors/validating and examining bodies, insurers/legal representatives, professional bodies – details may be shared in connection with student and/or employee complaints, disputes, grievance, disciplinary and malpractice investigations
  • Educators, examining bodies, other validating and awarding bodies in connection with registration, administration and moderation in relation to examination and awarding qualifications, awards and accreditations
  • As an examination centre we must provide candidate personal data (name, date of birth, gender) to the awarding bodies for the purpose of examining and awarding qualifications, and that such personal data, together with the examination results and outcomes of any reviews of marking, reviews of moderation and appeals may be shared within DN Colleges
  • External Education/Training and Travel Providers for booking and administration purposes
  • Student Union for the purposes of administering Student Union Membership and access to Student Union services
  • Suppliers and 3rd party data processors to enable them to provide the service we have contracted them for e.g. Your Business voice and college systems e.g. Card and online payment system/ student portals/Microsoft Outlook/365 for payments/login details/course resources and file storage
  • Third parties at your request for confirming your student status, course details and other details as required e.g. financial status e.g. Council Tax Reduction Scheme
  • Disclosure and Barring Service – to obtain a DBS check to check for criminal convictions and offences (certain courses and placements require DBS checks to be carried out before we can place you with certain employers for apprenticeships or placements – where this applies, we will ask you to read a separate Privacy Policy)
  • In connection with DSAR requests (Data Subject or Authorised Representative) e.g. information which may be contained within emails, documents, systems, paper and electronic records/filing systems and other forms of media, this may include email address(es), contact details and also the disclosure of information of which you were the author or to which you have contributed. This includes deleted and archived personal information which is still
  • Information Commissioner’s Office (ICO) (complaints/breaches investigations)
  • Internal and External Auditors (e.g. Financial Accountants/HMI Inspectors)
  • Education, Government departments and agencies for audits, reviews, to comply with legal, funding and data collection requirements e.g. research/analysis/statistics/equality & diversity, benchmarking purposes e.g.
  • Office for National Statistics (ons.gov.uk)
  • Office for Students (OfS) (officeforstudents.org.uk)
  • Higher Education Statistics Agency hesa.ac.uk
  • Department for Work and Pensions gov.uk/dwp
  • Education Skills and Funding Agency (ESFA) including the English European Social Fund (ESF), the ESFA share this information with the following organisations:
  • Office for Standards in Education (OfSted) gov.uk/ofsted
  • Institute for Apprenticeships instituteforapprenticeships.org
  • Learning Records Services (LRS) gov.uk/lrs-organisation-portal
  • Individual Learner Records (ILR) gov.uk/individualised-learner-record-ilr
  • National Careers Services gov.uk/career-skills-and-training
  • Other educational institutions and organisations performing research and statistical work on behalf of the Department for Education, or partners of those organisations
  • The ESFA, ESF and other key service departments may wish to contact you directly about courses or learning opportunities and for survey and research purposes. We will ask you to confirm your acceptance to this during the enrolment process, you can withdraw your consent at any time through the HE Student Registrar Services or FE Student Registry. Further information is available through gov.uk/government/publications/esfa– privacy-notice.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Third Party Processors and Transferring Data Internationally

Where we use Third Party Processors or transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.

Your rights

Under the General Data Protection Regulation, you have various rights in relation to your personal information:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling

Please note, exemptions may apply when making a request to exercise your rights, for example where we have to retain or process information for legal purposes. For more information on your personal data rights visit www.ico.org.uk/your-data-matters

 How to access the personal information we hold about you

Individuals have a right to make a ‘Data Subject Access Request’ to gain access to personal information that we hold about them. Please refer to our Data Protection (GDPR) Policy for more information on how to make a request or contact our Data Protection Officer (details can be found below).

Your other rights regarding your data

Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe. You have the right to:

  • Object to the use of your personal data if it would cause, or is causing, damage or distress
  • Prevent your data being used to send direct marketing
  • Object to the use of your personal data for decisions being taken by automated means (by a computer or machine, rather than a person)
  • In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing – routine requests for changes to the information you provide us with such as changing your contacts details etc. can be directed to
  • Claim compensation for damages caused by a breach of the data protection regulations
  • To exercise any of these rights, please contact the Data Protection

Data Protection Officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Our Data Protection Officer is:

terry Hutchinson –  dataprotection@dncolleges.ac.uk

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.