Higher Education Student Privacy Notice

We collect a number of different types of personal data. The following are examples of personal data (not exhaustive) which may be collected, stored and used:

• Name, address and contact details (including personal email address)
• Date of birth
• NI number
• Dates of enrolment
• Exam and assessment results
• Predicted and final grades
• Next of kin
• Sex
• Your image
• Marital and family details
• Complaints and disciplinary records including fitness to practice/study
• Appeals
• Extracurricular activities
• Educational background
• CCTV footage
• Bank and financial information
• Health records
• Disability information assessments
• Educational certificates
• Placement details
• Accommodation issues
• Employment details
• Care leaver status

In certain circumstances special category personal data may be collected. These are more sensitive categories of identifying information including but not limited to the following: racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning health or data concerning a natural person’s sex life or sexual orientation and data relating to criminal convictions.  If you apply for extenuating circumstance we will also collect and retain the evidence you provide to support your application.

The College will collect your information in different ways during its relationship with you. These will include:

• Information you provide directly to us such as on enrolment or during your period of study
• Information you provide directly to us after you complete your studies with us
• Information you provide through UCAS or other admission procedures, and
• We may also gain your personal data from third parties, for example, from references, information from your sponsor or from previous educational establishments

The College will use your personal data to administer and deliver your student contract. This includes:

• Academic administration such as enrolment on programmes and modules, organising professional placements or field trips, organising exams and assessments, recording marks and producing certificates or transcripts
• Administration of your financial relationship with the College and any relevant funders or sponsors such as the assessment and collection of fees due to the College
• Management of your use of and access to facilities and enabling participation in events, for example production of the student card, provision of IT services and accommodation and attendance at graduation
• Communicating with you
• Operation of security, disciplinary, complaint and quality assurance processes and arrangements including campus-wide CCTV images
• Providing you with services and support such as accommodation, access to the library, computer facilities, lecture capture and tutor support as well as employability services, guidance and tutor support
• Support of health, safety and welfare requirements, production of statistics and research for internal and statutory reporting purposes which may include data on your attainment, attendance and interactions with academic resources. This may be used to monitor progress and enables the College to offer personalised support and guidance

The College may also process more sensitive personal data (special category data) in the following ways:

• Your race, national or ethnic origin, religious, philosophical or moral beliefs or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting (including where required for monitoring purposes conducted by the Education Skills Funding Agency, and the Office for Students)
• Certain courses of study, placements and work opportunities may require disclosure or information about past criminal convictions and offences. This will be processed where relevant because you are working with children or vulnerable adults, and/or because of fitness to practise requirements in certain regulated professions. In these circumstances a DBS check may be required, and where this is the case you will be informed separately
• Information about physical or mental health or disability status to ensure your health and safety whilst registered at the College and to assess your fitness to study, travel, take part in placements, provide appropriate reasonable adjustments and where you request it, to make decisions relating to applications for extenuating circumstances
• Where you choose to provide the College with sensitive information about yourself for the purposes of student support we will use this to work with you and provide the support requested

The College must have a lawful basis in order to process personal data. For the processing of students’ data these have been identified as follows:

• where it is necessary to perform the contract we have entered into with you;
• where it is necessary for the performance of a task in the public interest;
• where it is necessary to comply with a legal obligation;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

The College may also use your data, typically in an emergency, where this is necessary to protect your vital interests, or someone else’s vital interests. In a small number of cases where other lawful bases do not apply, we will process your data on the basis of your consent. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

In relation to more sensitive personal data (special category data) the additional legal bases for these are:

• where we need to carry out our legal obligations,
• where you have made the data public,
• where it is necessary to protect your vital interests or those of another person and where you/they are physically or legally incapable of giving consent. This would be in an emergency situation where your health, wellbeing or welfare was at risk,
• where processing is necessary for the establishment, exercise or defence of legal claims,
• where we have your consent to do so,
• where it is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes

If consent is required for any additional uses of your personal information, including your image and more sensitive personal information we will collect it at the appropriate time and explain this to you. Where the College is processing your data on the basis of your consent, you can withdraw your consent at any time. We will not use your personal information to carry out any wholly automated decision-making that affects you.

Should you seek support from the teams in Learning Support and Wellbeing Services (which include Disability Services) they will also collect special category data from you for the purposes of providing you with their support services.

To obtain details of the timeframes for the College to keep your personal data are available via [email protected]  

Where there is a legitimate need or statutory obligations the College will disclose necessary personal data to third parties. Depending on individual circumstances these may include the following:

• Education Skills Funding Agency – published at https://www.gov.uk/government/publications/esfa-privacy-notice , and the Office for Students published at https://www.officeforstudents.org.uk/ofs-privacy/privacy-notice/
• Partner institutions where your programme is run in conjunction with a partner or involves an exchange programme, this includes the University of Plymouth – published at – https://www.plymouth.ac.uk/student-life/your-studies/essential-information/data-protection
• Funders and/or sponsors (e.g. the UK Student Loans Company, funders based in other countries including those outside the EEA, UK Research and Innovation, Research Councils, Teach First, the funders of any awards or prizes)
• Providers of any external/collaborative learning, training, work and other placements (e.g. schools involved in the provision of teacher training and hospitals hosting student placements), or fieldwork opportunities e.g. affiliated institutions, exchange partners, including to providers based overseas
• Providers of external/collaborative research projects involving students including sponsors of studentships, research collaborations and enterprise experience opportunities with third parties as part of a programme of study
• External examiners and assessors, including End Point Assessment organisations for Apprenticeships, and external individuals involved in relevant College panels, committees or procedures
• Relevant UK Government Departments (e.g. Department for Education, Home Office (including UK Visas and Immigration), Foreign and Commonwealth Office, Department of Health) in accordance with the College’s obligations as a Tier 4 sponsor
• Relevant Higher Education bodies (e.g. Office for Students, UK Research and Innovation, Universities and Colleges Admissions Service, Office of the Independent Adjudicator, the organisation(s) running the National Student Survey and other student and surveys)
• Any other relevant professional or statutory regulatory bodies
• To third party student accommodation providers operating under contract on behalf of the College
• The South Devon College Students’ Union (SU), and other Student Unions that we associated with in order to facilitate your membership of this and associated clubs and societies
• Council Tax Offices where limited data is provided to assist with the administration of students’ exemption from Council Tax
• On occasion and where necessary, Torbay, and Devon County Council, the police and other law enforcement agencies for the purposes of prevention or detection or crime including anti-social behaviour issues
• Where necessary the emergency services and your designated emergency contact where there is an urgent requirement to share information e.g. illness, serious injury, bereavement or the suspicion/risk of this
• College’s professional advisors, solicitors, accountants and auditors and, where required, other statutory bodies acting in an audit capacity e.g. OFSTED
• Third party providers providing specific services to, or on behalf of, the College under contract for the purposes of teaching, learning, research and administration
• To banks (and other payment agencies you may use), family members who are paying your fees, sponsors or other third parties to enable them to pay student debts and this includes the disclosure of relevant information to our supplier of banking services for the purposes of complying with anti-money laundering regulations and to agencies engaged on our behalf for the collection of unpaid debts
• External organisations contracted by the Office for Students or other regulatory organisations to carry out surveys on student experience or teaching quality eg. National Student Survey (NSS), Student Perception Survey (SPQ) and Graduate Outcomes Survey (GO).
• Where requested the College will provide references to third parties with your consent
• We will make your name and confirmation of your award available at your graduation ceremony
• To third party providers such as Turnitin whose systems are used to check for improper citation and potential plagiarism in students’ work. Students may therefore be required to provide a limited amount of personal data, for instance name, email address and course details and submissions, to Turnitin® when using the service.
• If you are on an Apprenticeship will may share you performance and attainment with your employer, including but not limited to your attendance, progress and grades (formative and summative).

We will share your data with your relevant professional body eg. Nursing and Midwifery Council, Solicitors Regulation Authority, Health and Care Professions Council:

• Registration: we will share your name, contact details and personal data including age, disability and ethnicity with the accrediting or regulatory body if requested.
• Graduation: we will share a list of students who completed their award with the regulatory or accrediting body in order to register you to practise as a professional or complete your registration. This may include information about Fitness to Practise/Study incidents which the College investigated while you were a student.

The College may also share information to assist the accrediting or regulatory body with its statutory duties or for research purposes to enable them to conduct research into education for the profession. Any data shared for research purposes will not be used for other purposes, will not be used to make decisions about you nor published in ways which could identify you.

On occasion, the above types of sharing may involve the transfer of your personal information outside the European Economic Area (e.g. to facilitate your participation in an exchange visit or to report to an overseas funding provider). Such transfers usually are necessary in order to meet our contractual obligations with you, and are carried out with appropriate safeguards in place to ensure the confidentiality and security of your personal information.

Other than as set out above, we will not normally publish or disclose any personal information about you to other external enquirers or organisations, including family and friends unless you have requested it or consented to it, or unless it is in your vital interests to do so (e.g. in an emergency situation).

As a data subject you have a number of rights in relation to your personal data. You can:

• access and obtain a copy of your data on request
• require the College to amend incorrect or incomplete data
• require the College to stop processing your data, for example where the data is no longer necessary for the purposes of processing
• object to the processing of your data where the College is relying on its legitimate interests as the legal ground for processing
• require us to erase your personal data
• require us to restrict our data processing activities (and, 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)
• 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 the purpose of you transmitting that personal data to another data controller

Please note that the above rights are not absolute, and the College may be entitled to refuse requests where exceptions apply.

For further information or if you wish to exercise any of these rights or if you have a complaint about the way you believe your data is being processed, in the first instance, please see Your Information Rights or email: [email protected]

If you have a complaint and you remain dissatisfied with how your complaint has been dealt with you can take your complaint to the Information Commissioner’s Office (ICO) for a review. They can be contacted at [email protected]