Student Privacy Notice

Personal data, or personal information, means any information relating to you as an individual from which you can be identified. It does not include data where you cannot be identified, i.e. anonymous data.

Certain types of personal data are classified in the data protection legislation as ‘Special Category Data’.

We may need to process any or all of the following categories of information about you to facilitate your studies and participation in University activities:

• Name
• Contact details
• Home or term-time address
• Identification reference numbers (such as your Student ID)
• Identification documents (such as your passport)
• Nationality
• National Insurance number
• Date of birth
• Gender
• Education history
• Employment and career history
• Academic progress
• Assessment results
• Training records
• Attendance
• Placement details and progress
• Financial information
• Payment details
• Details of family members
• Photos or video images
• Audio recordings
• Disciplinary information
• Relationship status
• Travel details
• Location data

We may need to process any or all of the following types of special category data about you to facilitate your studies and participation in University activities:

• Health, disability and medical data
• Race/ethnicity
• Religion or philosophical beliefs
• Sexual orientation or sex life
• Political opinions
• Trade union status
• Genetic data
• Biometric data

Sources of your personal data

We collect or obtain your personal data from the following sources:

• Directly from you, when you apply to study or when you provide information during your studies
• Generated by University staff or as part of your progress
• Your school or previous educational establishments or employers if they provide references to us;
• Fellow students, family members, friends, visitors to the University and other contacts who may provide us with information about you if and when they contact us, or vice versa;
• External organisations such as those facilitating your application (e.g. UCAS), sponsoring you or providing you with financial support (e.g. Student Loans Company)

The UK GDPR requires that we have a lawful basis whenever we process your personal data.

Most commonly, we will process your data on one or more of the following UK GDPR Article 6 lawful bases:

• 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.

We 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 we may process your data on the basis of consent, which we will ask you for individually

Conditions for processing Special Category Data

In most instances where we process Special Category Data about you, we will rely on the following conditions as set out in Article 9 of the UK GDPR:

• With your explicit written consent; or
• Where it is necessary in the substantial public interest
• Where it is necessary for archiving purposes in the public interest, or for scientific or historical research purposes, or statistical purposes, subject to further safeguards for your fundamental rights and interests specified in law. 

We may also rely on the following conditions in limited circumstances:

• Where it is necessary in relation to a legal claim
• Where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent
• Where you have already made the data public.

 Criminal convictions and allegations of criminal activity

Further legal controls apply to data relating to criminal convictions and allegations of criminal activity.  The conditions for processing data relating to criminal convictions and activity are set out in the Data Protection Act 2018.

We have prepared a Record of Processing Activities which is a list of all processes involving personal data that the University undertakes. Included in this document are the following details specific to each processing activity:

• Source of the personal data
• Categories of personal data processed
• Purpose of processing
• Lawful basis and special category condition relied upon for processing
• Categories of external recipients of personal data
• Details of any international transfers of personal data

You should refer to this document for more information about individual functions, procedures and activities conducted by the University. In addition, please see below for summaries of specific areas of the University:

Student Services

When you engage with Student Services, we will record information about your interactions on our case management system, firstpoint Online.

Information you provide may be accessible to relevant University staff and services where they have a legitimate need to know in order to support you or fulfil the University’s legal or contractual responsibilities. This may include, where appropriate, your Personal Academic Tutor, Accommodation Services, Security, Finance and other relevant professional services.

We will only share information that is necessary for these purposes and in accordance with the University’s Data Protection Policy and Privacy Notice.

In some circumstances, we may ask you to provide special category data, such as information about your:

• physical or mental health;
• disability or accessibility requirements;
• racial or ethnic origin;
• religious or philosophical beliefs;
• sexual orientation;
• gender identity (where relevant to the support being provided).

Where we rely on your consent to record or use this information, we will ask for it explicitly. If you choose to share special category information during discussions with university staff, we may record it where this is necessary to provide appropriate support or meet our legal obligations. We will explain how this information will be used and handled in accordance with UK data protection legislation.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not, and will not, sell your data to third parties.

We may have to share your data with third parties, including third-party service providers and partner organisations (as detailed below)

We require third parties to respect the security of your data and to treat it in accordance with the law.

Why might we share your personal information with third parties?

We may share your personal information with third parties where required by law, where it is necessary to administer the contract with you or where we have another legal requirement or legitimate interest in doing so.

This includes for example:

·       where we are required to report information about students who are subject to visa controls to UK Visas and Immigration;

·       where we are required to report information to enable the University to fulfil its obligations to report information to the Higher Education Statistics Agency or its successor body in order to comply with regulatory obligations; and/or

·       where we decide to report alleged criminal misconduct to the police.

It also includes disclosures where the third party is an agent or service provider appointed by the University to enable us to operate effectively, we only do this where we are satisfied that appropriate safeguards are in place to ensure adequate levels of security for your data.

More information on the categories of recipients of your data is set out in the Record of Processing.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within the University Group. 

Examples of bodies to whom we are required by law to disclose certain data include, but are not limited to:

Examples of bodies to whom we may voluntarily disclose data, in appropriate circumstances, include but are not limited to:

Where information is shared with third parties, we will seek to share the minimum amount of information necessary to fulfil the purpose.

How secure is my information with third-party service providers and other entities in the University Group?

All our third-party service providers and other entities in the University Group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes (as written in the contract between us) and in accordance with our instructions.

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business requirement to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer [Martin Whiteside, Pro-Vice Chancellor Digital Transformation (infoassurance@worc.ac.uk].

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Sharing your data outside the UK

There may be occasions when we transfer your data outside the UK, for example, if we communicate with you using a cloud based service provider that operates outside the UK or for returns to bodies overseas such as those offering international opportunities. Such transfers will only take place if one of the following applies:

• the country receiving the data is subject to a UK adequacy decision
• the transfer is governed by an appropriate transfer mechanism;
• the transfer has your consent;
• the transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract;
• the transfer is necessary for the performance of a contract with another person, which is in your interests;
• the transfer is necessary in order to protect your vital interests or those of other persons, where you or other persons are incapable of giving consent;
• the transfer is necessary for the exercise of legal claims; or
• the transfer is necessary for important reasons of public interest.

How long we keep your data

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Records and Document Retention Schedule

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Retention periods may increase as a result of legislative changes, e.g. an increase in limitation periods for legal claims would mean that the University is required to retain certain categories of personal data for longer.  Any such changes will be reflected in updated versions of our Records and Document Retention Schedule which is reviewed on a three year basis.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We may keep anonymised statistical data indefinitely.

Once you are no longer a student or alumni of the University we will retain and securely destroy your personal information in accordance with our data retention policy.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your study with us and until after you have graduated or otherwise completed your studies with us.

Your rights in connection with personal information

Where we are processing your personal information on the basis of your consent, you always have the right to withdraw that consent.

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are processing your information on the basis of our legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. The lawful basis for any particular processing activity we carry out is set out in our detailed table of processing activities.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Suspend processing of your personal information, for example if you want us to establish the accuracy of the data we are processing.
• Object to any direct marketing (for example, email marketing or phone calls) by us, and to require us to stop such marketing.
• Object to any automated decision-making about you which produces legal effects or otherwise significantly affects you.
• Request the transfer of your personal information to another party.

Please be aware that these rights are subject to certain conditions and exceptions as set out in the data protection legislation.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer [Martin Whiteside, Pro-Vice Chancellor Digital Transformation (infoassurance@worc.ac.uk] in writing and they will explain any conditions that may apply.

Further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/).  You may also wish to contact the University’s Data Protection Officer [Martin Whiteside, Pro-Vice Chancellor Digital Transformation (infoassurance@worc.ac.uk] if you are considering how or whether to exercise your rights.

You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office if you believe that your data has been processed unlawfully.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Information Assurance (infoassurance@worc.ac.uk). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Further guidance on your rights is available from the Information Commissioner’s Office (https://ico.org.uk/).  You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully.

We may need to update this notice from time to time, for example if the law or regulatory requirements change, if technology changes, if the University makes changes to its procedures, or to make the University’s operations and procedures more efficient.  If the change is material, we will give you not less than two months’ notice of the change so that you can decide whether to exercise your rights, if appropriate, before the change comes into effect.  We will notify you of the change by email.

If you wish to access previous versions of this privacy notice, please contact infoassurance@worc.ac.uk

We are the University of Worcester, Henwick Grove, Worcester, WR2 6A

If you need to contact us about your data: for your general student record please contact: Registry Services (studentrecords@worc.ac.uk). For other data collections please contact, in the first instance, Information Assurance (infoassurance@worc.ac.uk).

The University has a Data Protection Officer, whose contact details are: Martin Whiteside, Pro-Vice Chancellor Digital Transformation (infoassurance@worc.ac.uk).