Data Protection Privacy Notice for Students
This Privacy Notice Applicable to all (former/current/prospective) students (“you”, “your”). Students privacy is important to us and it is our top priority to ensure safety and security. London Churchill College (“LCC”, “we”, “our”, “us”, “the College”) is the data controller for your personal data. This notice will explain how the LCC processes student information in accord with the General Data Protection Regulation (“GDPR”) and the Data Protection Act 1998(“DPA”).
What is personal data/personal information?
Personal data means any information relating to an identified or identifiable living person. An identifiable person is one who can be identified, directly or indirectly, by an identifier such as a name, identification number, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. Processing is any activity carried out involving personal information, including holding and storing it in any format, both digital and hardcopy.
How we collect your information?
from the information you provide to us when you interact with us before joining, for example-
- when you express your interest in studying at LCC by application;
- contact us by email, telephone, post, social media or in person;
- register for an event;
- make an enquiry;
- respond to a questionnaire;
- taking part in survey;
- or volunteer with the College;
- from funding organisations;
- from third parties, for example your previous or educational institutes or employers who may provide a reference.
What type of data or information do we collect?
LCC accumulates and processes information relating to its students, including images, personal details, family and social circumstances, education and training records and financial information in relation to the funding organisation.
In some instances, LCC may collect and process what may be considered ‘sensitive personal data’ as described under the DPA and ‘special category personal data’ as described under the GDPR.
Why we collect and process your data?
LCC collect and process data for administrative and educational purposes. These include-
- To administer the aspects of your application; studies, academic progress and student record.
- To interact with your queries including the college administrative and academic process such as- admissions; attendance; equality and diversity; appeals, complaints and discipline; assessment and feedback; health and safety.
- Providing advice and support in academic, pastoral, careers or other matters. This includes interactions with a student support and wellbeing service.
- Compiling records and statistics for research and audit purposes and management information.
- Communications with students (including by electronic means) relating to timetable changes, security incidents, campus evacuation, College events, alumni events, Employment forum etc.
- To undertake analytics, analysis and research so that we may improve the services offered by LCC.
- Disclosures to relevant external bodies needed in the course of funding, auditing, accreditation or quality review of the College’s activities, such as- HESA returns, DLHE survey, NSS survey.
The basis for processing your information
All processing of Personal Data shall be completed in a lawful, fair and transparent manner.
We may process your personal data because it is a condition of student enrolment that they agree to the College processing certain personal information as part of its statutory obligations. Additionally, the College may also process some information that is categorised as “special category personal data”. This information may be required to comply with certain government or funding body regulations.
The College seeks the consent of the individual whom the data concerns before completing any processing that cannot be considered part of its duty as a public authority. This may include the consent to receive Direct Marketing.
When seeking consent from an Individual, the College will always ensure that it is unambiguous and that it involves a clear affirmative action by the Individual. Requests for consent shall include:
- The name of any third-party controllers who will rely on the consent;
- An explanation as to why the College would like the requested data and how it shall be processed.
- Information to the Individual on how to withdraw their consent at any time.
- Consent shall never be a precondition to enrolment or employment at the College.
Who we share personal data with
We may share your data with other departments within LCC only where necessary, such as for the delivery of alumni or development services.
For the purposes referred to in this privacy notice, we may share your personal data with certain third parties. For example-
- Third parties who work with us to provide student support services (e.g. counselling, ); organisations operating anti-plagiarism software on our behalf such as Turnitin®, internal and external auditors.
- Current or potential education providers, employers (e.g. reference purpose).
- Government departments and agencies where we have a statutory obligation to provide information (e.g. the Office for Student(OfS), Higher Education Funding Council for England (HEFCE), the Higher Education Statistics Agency (HESA), the Home Office, Council Tax and Electoral Registration Officers at relevant local authorities, crime prevention or detection agencies (e.g. the police, the Department for Work and Pensions and Trading Standards).
International data transfers
In some instances, your personal data may be subject to store at a destination outside the European Economic Area(EEA) under the GDPR Regulations.
How we keep data secure
We will never give, rent or sell your data to anyone else, nor will we make use of it ourselves for any purpose other than those described above.
Firewall and Network security systems are embedded to protect your information. Databases are further protected by access restrictions. Key information (including your password) is encrypted when stored. Our systems are constantly updated and tested to ensure this security is maintained.
How long we keep personal information
LCC will retain your personal data if necessary for the purposes described above. Please note that after completion of your studies LCC may still require to hold your personal data for a period to satisfy statutory/legal obligations and/or to meet administrative requirements. LCC is currently revising its retention schedule for student data and this will be available, on the public domain, in due course.
Under the DPA, you have the following rights:
- to obtain access to, and copies of, the personal data that we hold about you.
- to request that we cease processing your personal data if the processing is causing you damage or distress.
- to require us not to send you marketing communications.
- to request us to correct any incorrect personal data we hold about you.
Once the GDPR comes into force in May 2018, you will also have the following additional rights:
- to request us for erasure of your personal data.
- to request us to restrict our data processing activities.
- 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 your transmission of personal data to another data controller;
- to object, on grounds relating to your situation, to any of our 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 after careful consideration of any exceptions that may apply.
You have a responsibility to keep your personal details accurate and up to date and you should notify the College of any changes.
How to exercise your data rights
You have the right to request access to, copies of and rectification or erasure of personal data held by the College and to object to processing by contacting Data Protection Officer(DPO) We will explain any possible consequences of doing so in any case if you contact us to withdraw consent.
Data Protection Officer
Telephone: +44 (0) 2073771077
If you have any issues about this statement or the way LCC has handled your personal information, please contact the College Data Protection Officer in the first instance.
If you are dissatisfied with the college response, you can further communicate to the Information Commissioner’s Office. More general information on Data Protection is available at http://www.ico.gov.uk.
Our Privacy Notice is under regular review and any updates will be posted on this webpage. Please contact the Data Protection Officer if you have any questions.