“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. As data processor, Higher Ed Partners UK processes Personal Information including:
- Middle Name
- Postal address
- Email address
- Telephone number
- Mobile number
- Country of residence
- Second Nationality
- Date of birth
- IP Address
- Educational records and qualifications, including higher and further education institutions attended, dates of attendance, degree programme titles, subjects and grades
- Higher and further education transcripts and certificates
- Curriculum Vitae
- Work history – including employer, job title, responsibilities, location and dates in role
- Name, telephone number, postal address, job title, email address and employer of data subject’s referees
- School type of data subject
- Confirmation of whether English is first language
Higher Ed Partners also processes “Special Category Information”, including:
- Disability information
Special Category Information is processed so that Wrexham Glyndwr University (the data controller) can monitor application and admission rates to advance equality of opportunity and equality between different groups in accordance with Schedule 1, Part 2, 8 of the Data Protection Act 2018: Equality of opportunity or treatment.
Collection of Personal Information
We collect Personal Information in a variety of ways, including:
- We collect Personal Information through our services, for example, when you submit your details on the request information form on our website (https://online.glyndwr.ac.uk) or paid traffic landing pages, apply for admission via our online application form, or maintain an ongoing relationship with us as a student.
- From you during your course of study or period of enrolment with Wrexham Glyndwr University.
- We collect Personal Information from you offline, such as when you contact us by phone and provide information to one of our enrolment advisors.
Use of Personal Information
Higher Ed Partners UK uses Personal Information for the purposes of recruiting and enrolling students and providing students with student support. These uses include:
- Providing the functionality of our services and fulfilling your requests.
- To provide our services’ functionality to you, such as arranging access to your registered account and providing you with related assistance,
- To respond to your inquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or complaints.
- To complete your transactions, and provide you with related assistance.
- To send administrative information to you, such as changes to our terms, conditions and policies.
- To allow you to send messages to another person if you choose to do so.
We will engage in these activities to manage our recruitment, enrolment and student support processes. The legal basis we rely on for processing this Personal Information until you have enrolled is consent under article 6(1)(a) of the GDPR. We will request both email and telephone contact details in order to ensure that any security administrative functions are robustly managed. Further, to provide verbal and written communication to ensure you are fully informed to enabling you to make the important decision of a Higher Education programme suitable for your chosen career path. Then once enrolled, we will rely on 6(1) (e); processing is necessary for the performance of a task carried out in the public interest; namely the provision of higher education.
Providing you marketing materials.
- To send you marketing related emails, with information about our services and other news about us.
We will engage in this activity with your explicit consent.
Analysis of Personal Information for business reporting and providing personalised services.
We use automated processes to carry out the following activities:
- To analyse or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our services.
- To better understand you, so that we can personalise our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our services that we believe will be relevant and interesting to you.
We will provide personalised services either with your consent or because we have a legitimate interest.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymise Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for the purpose of sharing with third parties to improve targeting, personalisation and overall effectiveness of marketing activity.
- Accomplishing our business purposes.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new services;
- For enhancing, improving, or modifying our current services;
- For identifying usage trends, for example, understanding which parts of our services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our services are of most interest to our users so we can focus our energies on meeting our users’ interests.Lawful basis used for processing the above:
No 1 – necessary for compliance with a legal obligation, for example, regulatory audits, Article 6 (1) (c)
No’s 2-7 – necessary for the purposes of legitimate interest, Article 6 (1) (f)
Disclosure of Personal information
We disclose Personal Information:
- To partnering institutions that receive services from Wrexham Glyndwr University.
- To our third-party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. Any third-party service providers that we disclose Personal Information to will have entered into a fully GDPR-compliant data processing agreement with Higher Ed Partners UK and Wrexham Glyndwr University.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law.
- This can include laws outside your country of residence.
- To respond to requests from public and government authorities.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
We will use appropriate organisational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Choices and Access
You gave consent to receive personalised information about University online courses by your preferred method. You may withdraw your consent:
- To receiving email marketing from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, unsubscribe by following the instructions contained in each such email or by contacting us at firstname.lastname@example.org
- To receiving other types of marketing communications from us regarding future start dates and other online courses provided by the University of XXXX: If you no longer want to receive marketing-related communications from us on a going-forward basis, you can unsubscribe by contacting us at email@example.com
- To change the preferred method of contact. Should you wish to change your preferred method, contact us at firstname.lastname@example.org
We will try to comply with your request(s) as soon as reasonably practicable.
How you can access, change or delete your Personal Information
We thought it would be helpful to set out your rights under GDPR. You have the right to:
- withdraw consent where that is the legal basis of our processing;
- access your personal data that we process;
- rectify inaccuracies in personal data that we hold about you;
- be forgotten, that is your details to be removed from systems that we use to process your personal data;
- restrict the processing in certain ways;
- obtain a copy of your data in a commonly used electronic form; and
- object certain processing of your personal data by us.
Please see https://ico.org.uk for further information on the above rights.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a payment, you may not be able to change or delete the Personal Information provided until after the completion of such transaction). Further information regarding retention periods can be found below.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you are a student of ours);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
- We will retain personal information for no more than the remainder of the academic year + 6 years
USE OF SERVICES BY MINORS
Our services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).
JURISDICTION AND CROSS-BORDER TRANSFER
Your personal data is stored and processed in the UK. It may also be processed outside the European Economic Area by third party service providers. Any international data transfers will take place in full compliance with the General Data Protection Regulation and any relevant UK legislation.
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA
If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.