1. Introduction
Universal Consultancy is committed to a policy of protecting the rights and privacy of
individuals, including learners, staff and others, in accordance with the General Data
Protection Regulation (GDPR) May 2018. The new regulatory environment demands
higher transparency and accountability in how colleges manage and use personal
data. It also accords new and stronger rights for individuals to understand and
control that use. The GDPR contains provisions that the college will need to be
aware of as data controllers, including provisions intended to enhance the protection
of student’s personal data. For example, the GDPR requires that:
Universal Consultancy must ensure that our college privacy notices are written in a clear,
plain way that staff and students will understand. Universal Consultancy need to
process certain information about its staff, students, parents and guardians and other
individuals with whom it has a relationship for various purposes, such as, but not
limited to:
1. The recruitment and payment of staff.
2. The administration of programmes of study and courses.
3. Student enrolment.
4. Examinations and external accreditation.
5. Recording student progress, attendance, and conduct.
6. collecting fees.
7. Complying with legal obligations to funding bodies and government including local
government.
To comply with various legal obligations, including the obligations imposed on it by
the General Data Protection Regulation (GDPR) Universal Consultancy must ensure that
all this information about individuals is collected and used fairly, stored safely and
securely, and not disclosed to any third party unlawfully.
General Data Protection Regulation (GDPR)
This piece of legislation comes in to force on the 25, 2018. The GDPR
regulates the processing of personal data and protects the rights and privacy of all
living individuals (including children), for example, by giving all individuals who are
the subject of personal data a general right of access to the personal data which
relates to them. Individuals can exercise the right to gain access to their information
by means of a ‘subject access request’. Personal data is information relating to an
individual and may be in hard or soft copy (paper/manual files; electronic records;
photographs; CCTV images) and may include facts or opinions about a person.
The GDPR also sets out specific rights for College students in relation to educational
records held within the state education system. These rights are set out in separate
education Regulations: ‘The Education (Pupil Information) (England) Regulations
2000’. For more detailed information on these regulations, see the Data Protection
Data Sharing Code of Practice (DPCoP) from the Information Commissioner’s Office
(ICO). Please follow this link to the ICO’s website (www.ico.gov.uk)
2. Aim of the Policy
To protect the identity and privacy of all individuals about whom UK Versity Online
process data.
3. Scope of the Policy
The policy applies to all individuals about whom UK Versity Online hold data (e.g.
members of the Board of Management, staff, prospective staff and students.)
Data Protection Principles
The legislation places a responsibility on every data controller to process any
personal data in accordance with the eight principles. More detailed guidance on
how to comply with these principles can be found in the DPCoP. Please follow this
link to the ICO’s website (www.ico.gov.uk)
In order to comply with its obligations, CTC undertakes to adhere to the eight
principles:
1) Process personal data fairly and lawfully.
Universal Consultancy will make all reasonable efforts to ensure that individuals who are
the focus of the personal data (data subjects) are informed of the identity of the data
controller, the purposes of the processing, any disclosures to third parties that are
envisaged; given an indication of the period for which the data will be kept, and any
other information which may be relevant.
2) Process the data for the specific and lawful purpose for which it collected that data
and not further process the data in a manner incompatible with this purpose. Enam The Degree Man

 will ensure that the reason for which it collected the data originally is
the only reason for which it processes those data, unless the individual is informed of
any additional processing before it takes place.
3) Ensure that the data is adequate, relevant and not excessive in relation to the
purpose for which it is processed. Universal Consultancy will not seek to collect any
personal data which is not strictly necessary for the purpose for which it was
obtained. Forms for collecting data will always be drafted with this mind. If any
irrelevant data are given by individuals, they will be destroyed immediately.
4) Keep personal data accurate and, where necessary, up to date. Universal Consultancy
will review and update all data on a regular basis. It is the responsibility of the
individuals giving their personal data to ensure that this is accurate, and each
individual should notify the College if, for example, a change in circumstances mean
that the data needs to be updated. It is the responsibility of the College to ensure
that any notification regarding the change is noted and acted on.
5) Only keep personal data for as long as is necessary. Enam The Degree Man
undertakes not to retain personal data for longer than is necessary to ensure
compliance with the legislation, and any other statutory requirements. This means
Universal Consultancy will undertake a regular review of the information held and
implement a weeding process.
Universal Consultancy will dispose of any personal data in a way that protects the
rights and privacy of the individual concerned (e.g. secure electronic deletion,
shredding and disposal of hard copy files as confidential waste). A log will be kept of
the records destroyed.
6) Process personal data in accordance with the rights of the data subject under the
legislation.
Individuals have various rights under the legislation including a right to:
• be told the nature of the information the College holds and any parties to
whom this may be disclosed.
• prevent processing likely to cause damage or distress.
• prevent processing for purposes of direct marketing.
• be informed about the mechanics of any automated decision making process
that will significantly affect them.
• not have significant decisions that will affect them taken solely by automated
process.
• sue for compensation if they suffer damage by any contravention of the
legislation.
• take action to rectify, block, erase or destroy inaccurate data.
• request that the Office of the Information Commissioner assess whether any
provision of the Act has been contravened.
Universal Consultancy will only process personal data in accordance with individuals’
rights.
7) Put appropriate technical and organisational measures in place against
unauthorised or unlawful processing of personal data, and against accidental loss or
destruction of data. All members of staff are responsible for ensuring that any
personal data which they hold is kept securely and not disclosed to any unauthorised
third parties.
Universal Consultancy will ensure that all personal data is accessible only to those
who have a valid reason for using it. Universal Consultancy will have in place
appropriate security measures e.g. ensuring that hard copy personal data is kept in
lockable filing cabinets/cupboards with controlled access (with the keys then held
securely in a key cabinet with controlled access):
• keeping all personal data in a lockable cabinet with key-controlled access.
• password protecting personal data held electronically.
• archiving personal data which are then kept securely (lockable cabinet).
• placing any PCs or terminals, CCTV camera screens etc. that show personal
data so that they are not visible except to authorised staff.
• ensuring that PC screens are not left unattended without a password
protected screen-saver being used.
In addition, Universal Consultancy will put in place appropriate measures for the
deletion of personal data – manual records will be shredded or disposed of as
‘confidential waste’ and appropriate contract terms will be put in place with any third
parties undertaking this work. Hard drives of redundant PCs will be wiped clean
before disposal or if that is not possible, destroyed physically. A log will be kept of
the records destroyed. This policy also applies to staff and students who process
personal data ‘off-site’, e.g. when working at home, and in circumstances additional
care must be taken regarding the security of the data
8) Ensure that no personal data is transferred to a country or a territory outside the
European Economic Area (EEA) unless that country or territory ensures adequate
level of protection for the rights and freedoms of data subjects in relation to the
processing of personal data. Universal Consultancy will not transfer data to such
territories without the explicit consent of the individual. This also applies to publishing
information on the
Internet – because transfer of data can include placing data on a website that can be
accessed from outside the EEA – so Universal Consultancy will always seek the
consent of individuals before placing any personal data (including photographs) on
its website.
If the College collects personal data in any form via its website, it will provide a clear
and detailed privacy statement prominently on the website, and wherever else
personal data is collected.
Consent as a basis for processing
Although it is not always necessary to gain consent from individuals before
processing their data, it is often the best way to ensure that data is collected and
processed in an open and transparent manner. Consent is especially important when
Universal Consultancy is processing any sensitive data, as defined by the legislation.
Universal Consultancy understands consent to mean that the individual has been
fully informed of the intended processing and has signified their agreement (e.g. via
the enrolment form) whilst being of a sound mind and without having any undue
influence exerted upon them. Consent obtained on the basis of misleading
information will not be a valid basis for processing. Consent cannot be inferred from
the non-response to a communication.
Personal Details
• For the purposes of the General Data Protection Regulation (GDPR)
(Regulation (EU) 2016/679 you consent to the College holding and processing
personal data including sensitive personal data of which you are the subject,
details of which are specified in the College’s data protection policy.
• This will include marketing images and the College CCTV.”
Universal Consultancy will ensure that any forms used to gather data on an
individual will contain a statement (fair collection statement) explaining the use of
that data, how the data may be disclosed and also indicate whether or not the
individual needs to consent to the processing. Universal Consultancy will include the
specified statement from the DfE on the student enrolment form and update when
required following the ESFA’s technical guidance:
How We Use Your Personal Information
This privacy notice is issued by the Education and Skills Funding Agency (ESFA), on
behalf of the Secretary of State for the Department of Education (DfE). It is to inform
learners how their personal information will be used by the DfE, the ESFA (an
executive agency of the DfE) and any successor bodies to these organisations. For
the purposes of the Data Protection Act 1998, the DfE is the data controller for
personal data processed by the ESFA.
Your personal information is used by the DfE to exercise its functions and to meet its
statutory responsibilities, including under the Apprenticeships, Skills, Children and
Learning Act 2009 and to create and maintain a unique learner number (ULN) and a
personal learning record (PLR).
Your information may be shared with third parties for education, training,
employment and well-being related purposes, including for research. This will only
take place where the law allows it and the sharing is in compliance with the Data
Protection Act 1998.
The English European Social Fund (ESF) Managing Authority (or agents acting on
its behalf) may contact you in order for them to carry out research and evaluation to
inform the effectiveness of training.
You can opt out of contact for other purposes by ticking any of the following boxes if
you do not wish to be contacted: About courses or learning opportunities.
For surveys and research.
• By post.
• By phone.
• By email.
Further information about use of and access to your personal data, and details of
organisations with whom we regularly share data are available at:
https://www.gov.uk/government/publications/esfa-privacy-notice
Enam The Degree Man will ensure that if the individual does not give his/her consent
for the processing, and there is no other lawful basis on which to process the data,
then steps will be taken to ensure that processing of that data does not take place.
Subject Access Rights (SARs)
Individuals have a right to access any personal data relating to them which are held
by the College. Any individual wishing to exercise this right should apply in writing to
the Principal. Any member of staff receiving a SAR should forward this to the
Principal. The College reserves the right to charge a fee for data subject access
requests (currently £20). Under the terms of the legislation, any such requests must
be complied with within 40 days. For detailed guidance on responding to SARs,
please refer to the CoP.
Disclosure of Data
Only disclosures which have been notified under the College’s DP notification must
be made and therefore staff and students should exercise caution when asked to
disclose personal data held on another individual or third party.
Universal Consultancy undertakes not to disclose personal data to unauthorised third
parties, including family members, friends, government bodies and in some
circumstances, the police.
Legitimate disclosures may occur in the following instances:
• the individual has given their consent to the disclosure.
• the disclosure has been notified to the OIC and is in the legitimate interests of
the College.
• the disclosure is required for the performance of a contract. There are other
instances when the legislation permits disclosure without the consent of the
individual. For detailed guidance on disclosures contact quality manager.
In no circumstances will Universal Consultancy sell any of its databases to a third
party.
Publication of College Information
Universal Consultancy publishes various items which will include some personal
data, e.g.
• internal telephone directory.
• event information.
• photos and information in marketing materials.
It may be that in some circumstances an individual wishes their data processed for
such reasons to be kept confidential, or restricted College access only. Therefore it
is Universal Consultancy policy to offer an opportunity to opt-out of the publication of
such when collecting the information.
Email
It is the policy of Universal Consultancy to ensure that senders and recipients of
email are made aware that under the DPA, and Freedom of Information Legislation,
the contents of email may have to be disclosed in response to a request for
information. One means by which this will be communicated will be by a disclaimer
on the College’s email. Under the Regulation of Investigatory Powers Act 2000,
Lawful Business Practice Regulations, any email sent to or from the College may be
accessed by someone other than the recipient for system management and security
purposes.
CCTV
There are some CCTV systems operating within UK VERSITY ONLINE for the
purpose of protecting College members and property. UK VERSITY ONLINE will
only process personal data obtained by the CCTV system in a manner which
ensures compliance with the legislation.
Procedure for review
This policy will be updated as necessary to reflect best practice or future
amendments made to the General Data Protection Regulation (GDPR) May 2018
and Data Protection Act 1998.
Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further
detailed guidance on a range of topics including individuals’ rights, exemptions from
the Act, dealing with subject access requests, how to handle requests from third
parties for personal data to be disclosed etc. In particular, you may find it helpful to
read the Guide to Data Protection which is available from the website.
For help or advice on any data protection or freedom of information issues, please
do not hesitate to contact:
The Data Protection Officer (DPO): Philip Hodkinson, Quality Manager
POLICY REVIEW
This policy will be updated as necessary to reflect best practice in data management,
security and control and to ensure compliance with any changes or amendments to
the GDPR and other relevant legislation