What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, as also the visitor’s IP address and browser user agent string, to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Your contact information

Additional information

How we protect your data

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

• 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. Universal Consultancy 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. Enam The Degree Man 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. Enam The Degree Man 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 means 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. Universal Consultancy 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 an 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.

What data breach procedures we have in place

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

What third parties we receive data from

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 an 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 the 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.

What automated decision making and/or profiling we do with user data

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. When Universal Consultancy processes any sensitive data as the law defines it, consent is especially crucial. 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 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 it when required following the ESFA’s technical guidance:

Industry regulatory disclosure requirements

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 serves to inform students about how the DfE, the ESFA (a DfE executive agency), and any successor bodies to these organizations will use their personal information. For the purposes of the Data Protection Act 1998, the DfE is the data controller for personal data processed by the ESFA.

The DfE uses your personal information to carry out its duties and fulfill its legal obligations, including those under the Apprenticeships, Skills, Children, and Learning Act 2009, as well as to establish 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 is 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 by another individual or third party.

Enam The Degree Man 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.
• 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.