1. Purpose of this privacy notice
This privacy notice is a statement that explains how and why the University Access and Widening Participation Team processes (‘collects’, ‘uses’, ‘retains’, ‘discloses’, ‘disposes of’) personal information about individual learners provided by Schools and Colleges in relation to our Access and Widening Participation programmes and activities.
We, as a registered Data Controller, have an obligation to comply with the General Data Protection Regulations (GDPR) and other application data protection law. We maintain a data protection registration with the Information Commissioner’s Office (ICO), the independent authority which oversees compliance with the Data Protection Laws. Our registration numbers are:
- Solent University Z5969541
- Solent University Limited Z6147551
This notice explains how you can control how we use your information in accordance with your rights under the General Data Protection Regulations.
2. What personal data do we collect about you?
- Full name
- Current school
- Date of birth
- Home postcode
- Parental HE status
3. What special category data do we collect about you?
- Experience of local authority care
- Carer responsibilities
- Disability declaration
4. Why do we collect the data and what is our legal basis for doing so?
Why do we collect your data?
We organise and deliver a variety of outreach activities aimed at addressing and overcoming potential barriers prospective students may face. In order to build upon our successes and to continually monitor our performance we are required by the Office for Students (OfS) to gather and report on data (both qualitative and quantitative) with regards to how effective our outreach programmes and activities are.
To ensure these activities are useful and effective for underrepresented groups and to enable us to continue to make these activities available we need to gather certain personal and special category data about you. We need access to special category data about you in order to ensure we are meeting specific targets set of us by the OfS.
All data collected will be stored in accordance with applicable data protection laws by the Access and Widening Participation Team at the University. It will be used for reporting, research, and monitoring and evaluation purposes and to administer your participation in the relevant event or activity.
Legal basis for processing your data
We must have a legal basis for processing your personal data. This is based on satisfying one or more “conditions for processing” for personal data and at least two conditions for “special category data”. The data we are requesting sits across both categories.
Under GDPR, the “legal basis” for processing conditions must be communicated to you, alongside the type of processing they relate to as part of this privacy notice. The conditions identified below may be subject to change if there are changes to GDPR legislation. With regards to special category data, if we need to use this for any other purpose not outlined in this privacy notice then we will seek consent from you.
The legal basis identified for processing under this privacy notice is that which is outlined in Article 6(1)(e) and Article 9(2)(g) of the GDPR, ‘public interest’:
“Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”.
Our rationale for data collection under ‘public interest’ is as follows:
- To drive progress on access and participation for underrepresented groups, following the publication of the new regulatory framework and guidance provided to higher education providers by the Office for Students (OfS).
- To further public understanding of, and participation in, the debate of issues related to Widening Participation to Higher Education.
- To facilitate accountability and transparency in the spending of public money.
5. When do we collect your personal data?
5.1 Prior to the commencement of any outreach activities we will communicate with a pre-determined contact within your school or college to share this privacy notice and to determine the personal and special category data we require to complete our work.
5.2 We will receive your data directly from our pre-determined contact within your school or college who will have access to this privacy notice and will be responsible for sharing our privacy notice with you.
6. Who do we share your personal data with and how is it stored?
6.1 We comply with our obligations under relevant data protection legislation by keeping personal data up-to-date; by storing and destroying it securely; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
6.2 Your data will be collected by your school or college and shared with us in a secure manner that is accessible only by relevant members of the University. Those selected have a contractual responsibility to maintain confidentiality. Following the activity your data will be uploaded into the Higher Education Access Tracker database (HEAT) which is hosted and maintained by the University of Kent (https://heat.ac.uk/). Once imported into this database your information will be archived but will remain secure.
7. Do we transfer your personal data outside the European Economic Area (EEA)?
No data processed under this Privacy Notice is transferred outside the European Economic Area (EEA).
8. How long do we keep your personal data?
8.1 As a University we will retain your personal and special category data for 2 full years following the date of the activity you participated in. This will be stored in a secure manner that is accessible only by relevant members of the University. We will store this data in order to ensure we can appropriately measure and track educational outcomes of those that have participated in our outreach activities.
8.2 Your data will be retained on HEAT until you reach 30 years of age, unless during this period you enter Higher Education, in which case your data will be retained for a further 15 years from the date of your graduation. This retention schedule is in-line with best practice guidelines provided by HEAT.
9. Telling us about changes in your personal data
Please advise us promptly about changes to the data we hold about you so that we can maintain accurate records. You can tell us about changes by using the Departmental contact information given in section 12 of this privacy notice. This will then be communicated by us to HEAT.
10. Your rights in relation to the personal data we hold
Under the General Data Protection Regulation you have the following rights. Further data about these rights can be found on the Information Commissioner’s Office web site: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation- gdpr/individual-rights/?q=article+4
- The right to be informed at an appropriate time about the collection and use of the personal data we hold about you.
- The right of access to, your personal data and other supplementary data.
- The right to request correction of the personal data we hold about you if it is incorrect.
- The right, in certain circumstances, to require erasure of your personal data.
- The right, in certain circumstances, to restrict processing or your personal data.
- The right, in certain circumstances, to receive from the University the personal data you have provided to us in a reasonable format, specified by you. You may also request that we pass that personal data to another data controller.
- The right to object to certain processing of your personal data by us.
- Rights in relation to automated decision making and profiling.
These rights are not absolute and we may be entitled to refuse requests when there are valid exceptions; we shall explain the reasons to you in such cases. If you wish to exercise any of the rights above, please email email@example.com in the first instance.
11. Regulation of the use of your personal data
The University maintains a data protection registration with the Information Commissioner's Office, the independent authority which oversees compliance with the Data Protection Laws.
The University's registration numbers are:
- Solent University Z5969541
- Solent University Limited Z6147551
12. How to contact us
Please use the following contact details for any queries, concerns or complaints about this privacy notice or how we process your personal data.
Access and Widening Participation Team
Phone: 023 8201 3836
The University's data protection officer is Mr P Colbran.
Mr P Colbran
East Park Terrace
Southampton, SO14 0YN
Phone: 023 8201 3085
13. Requesting access to your personal data
To request access to the personal data that we hold about you please contact the Information Rights Office:
Information Rights Office
Policy, Governance and Information Service
East Park Terrace
Southampton, SO14 0YN.
Tel: 023 8201 3229 / 023 8201 3978
14. Information Commissioner's Office
We will always aim to respond clearly to any concerns you have regarding the processing of your data and to requests to exercise the rights stated above. However if you remain concerned or believe that Solent University has failed to comply with the data protection legislation then you have the right to complain to the data protection regulator, the Information Commissioner. Contact details follow:
The Information Commissioner’s Office
Cheshire SK9 5AF
Phone: 0303 123 1113
You are welcome to contact us if you have any concerns about how we process your personal data.
15. Changes to this privacy notice
We regularly review this notice and will update it if there are changes in how we manage or use your data. This page will always contain the latest version of this notice.
Updated: 30 October 2018
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