PRIVACY NOTICE FOR LEARNERS AND PROSPECTIVE LEARNERS

Background-

This Privacy Notice (Notice) explains how Grupo Limited (the Training Centre, we, our, us) processes the personal data of our learners and prospective learners (which includes learners of our short courses programmes and our University recruitment Programmes) (you, your) and your rights in relation to the personal data we hold.

For the purposes of any applicable data protection laws in England and Wales, including from 25 May 2018 the EU General Data Protection Regulation 2016/679 (GDPR), the Training Centre is the data controller of your personal data. The Training Centre has appointed a Data Protection Officer, who can be contacted via email at dpo@grupotraining.co.uk, via telephone on 20 3983 4566 and via post at Grupo Training London, Data Protection Officer, 7^th Floor, 252-262 Romford Road, London E7 9HZ.

For more information (www.grupotarining.co.uk)

How your personal data is collected

The Training Centre collects your personal data from the following sources:

• from you, typically when you:
  • interact with us before joining as a learner, for example when you provide your contact details for open day events or when you apply to study at the Training Centre or our partner University/ Colleges;
  • enrol as a learner with us, as part of the learner registration process;
  • complete our surveys and feedback forms;
  • interact with us during your time as a learner of the Training Centre, including in communications you have with the Training Centre; or
  • visit the Training Centre’s website, including when you register or use our online payment portals or store.

• from third parties such as:
  • institutions such as your school or employer when they provide a reference for you;
  • other institutions involved in joint and exchange programmes you are undertaking or applying to undertake (including institutions providing clinical training components in medical education);
  • our contractors and service providers who perform services on our behalf, many of which are outlined in this Notice;
  • other relevant third parties such as the Student Loans Company.

What categories of personal data are collected?

We collect the following categories of personal data:

Identification and contact details

• biographical information such as your name, title, date of birth, age and gender;
• your image and likeness (as captured in a photograph or on CCTV);
• your contact details including address, email address and phone number;
• information that evidences periods of residency (such as utility bills, proof of mortgage and travel) or financial circumstances (such as bank statements and proof of income);
• information that evidences your family relationships (such as a birth, adoption, marriage or civil partnership certificate);
• national insurance number (or other tax identification number) and your passport number or national identity card details, country of domicile and your nationality. We will also allocate you a unique learner number and username;
• where appropriate, diversity and background information that you provide to us.

Learner life and academic

• the courses you have completed, dates of study, examination results and attendance record. We will also keep records relating to assessments of your work, details of examinations taken, your predicted and actual examination grades, disciplinary and other information in your learner record;
• information relating to your education and employment history, the school(s), Training Centres or universities you have attended and places where you have worked;
• information about your family or personal circumstances (including welfare information), and both academic and extracurricular interests, for example where this is relevant to the assessment of your suitability to receive a place on a course, a bursary or scholarship, or in order to provide you with appropriate pastoral care and welfare support;
• records of communications sent to you by the Training Centre or received from you;
• records of your attendance at Training Centre events (including participation in online events), for example the Training Centre’s open days or learner events and lectures.

Online and transactional

• details of your IP address, browser type and operating system when you visit our website;
• details of financial transactions e.g. for courses, products and services we have provided.

We may also collect the following special categories of personal data where it is necessary for the purposes set out in this Notice (please also see the section on Special categories of personal data for details about how we process this data):

• information concerning your health and medical conditions (e.g. disability and dietary needs);
• certain criminal convictions (please see the section on Criminal convictions under the Special categories of personal data) or criminal acts caught on our CCTV cameras; and
• information about your racial or ethnic origin; religion or similar beliefs; and sexual orientation.

The basis for processing your data, how we use that data and with whom we share it

We will process your personal data either in ways you have consented to, or because it is otherwise necessary for a lawful purpose. We set these out as follows:

As part of the contractual relationship between you and the Training Centre

In this respect we use your personal data for the following purposes:

• administration of your application to the Training Centre including to evaluate your suitability for admission and to determine any support requirements/arrangements to enable you to study at the Training Centre (please also see the section on processing Special categories of data);
• admission, registration and administration of your studies including the requirements of the Learner Online Evaluation Survey;
• production of learner photo ID cards and administration of Training Centre security;
• academic assessment;
• administration of complaints and appeals, disciplinary hearings, and fitness to practice hearings;
• administration of your social and sporting activities (e.g. relating to your use of the Training Centre’s sports facilities);
• provision of Training Centre accommodation (including catering services) and other support services such as those of the Library and the Careers Service;
• consideration and granting of awards, scholarships, prizes and bursaries (including the publication of awards and marks and inclusion in pass lists made available via the Training Centre’s website);
• processing and recovery of accounts and fees, including your tuition fee liability;
• administration of employment contracts where you are employed by the Training Centre. If you are employed by the Training Centre, we will provide you with a separate privacy notice explaining how we use your personal data as an employer;
• administration of placements with partner institutions or organisations;
• administration of the Training Centre’s regulations, codes of practice and policies;
• organisation of events and services (including where applicable after you leave the Training Centre), and the provision of products that you have requested or ordered from us.

As part of this process, we will expect to share your personal data with:

• our agents and contractors (including providers of our learner accommodation, catering, IT, and other support services) where they need to receive the information in order to perform the services or provide the products, we have agreed to provide to you;
• Stripe, the Training Centre’s current learner fees and payments portal provider (or any other suitable substitute provider that the Training Centre may engage from time to time for these purposes);
• third party contractors who assist us in our recruitment process, for example:
  • external interviewers and reviewers with whom we share application forms and video interviews;
• partner institutions and other bodies involved in the delivery of a course or programme e.g. affiliated Training Centres or Colleges / University partners;
• sponsors, including the UK research councils, the Student Loans Company and external bodies and individuals who have funded learner prizes, financial loans and awards;
• external examiners and providers of anti-plagiarism software / services;
• debt collection agencies where necessary; and
• relevant professional bodies where a programme of study leads to a qualification recognised by that body (e.g. the Awarding Bodies).

Other legitimate interests

Your personal data will also be processed because it is necessary for the Training Centre’s legitimate interests or the legitimate interests of a third party. This will always be weighed against your rights, interests and expectations. Examples of where we process data for purposes that fall under legitimate interests include:

• administration of the Training Centre’s ongoing relationship with you in ways which are necessary to provide your chosen course and welfare;
• publishing your name in the graduation programme and on graduation merchandise (if you do not want your name to appear in the graduation programme or on graduation merchandise please contact the Graduation Team (info@grupotraining.co.uk);
• sharing your information with:
  • UniQuest (http://www.uni–co.uk/) who engage with applicants and prospective learners on our behalf to measure the effectiveness of our marketing and recruitment activities;
  • Qualtrics (https://www.qualtrics.com/uk/) who issue surveys on our behalf to the Training Centre’s learners and applicants to the Training Centre so that we can evaluate our performance and obtain feedback;
  • organisations who conduct independent surveys in relation to our courses for their rankings or guides (e.g. the Financial Times (FT) Masters in Finance Ranking). We will share your name, email address and course details so that the organisation can send you the survey to complete. The Training Centre’s legitimate interests for sharing this data is to promote the reputation of the Training Centre’s courses. Where practicable, we will email you before we share your details with the organisation to provide you with an opportunity to opt out of participating in the survey;
  • professional and industrial bodies wishing to communicate with learners about career opportunities and membership of their body. Normally the Training Centre will forward you information on behalf of the relevant organisation;
  • prospective employers or other organisations who request a reference for you;
  • third parties wishing to access a catalogue within the Training Centre’s Library containing reference to your work;
  • research partners, where appropriate; and
• analysing and improving the use of our website and any online services we provide;
• the recording of audio/images during lectures as part of the Training Centre’s teaching provisions and for subsequent use in teaching materials see the
• the recording of audio/images on Training Centre grounds for use in our official materials to promote the Training Centre and its work, thereby furthering its mission and strategic goals. These materials may include the website, social media channels, the Training Centre intranet, in press releases and mailings, on event posters, on TV screens on campus or in magazines or prospectuses.
• analysing our recruitment and marketing activities in order to determine their effectiveness and our future strategies;
• marketing the Training Centre and its goods, services, events and resources by post, telephone and electronic means (but without prejudice to your rights under the legislation that regulates the sending of marketing communications by electronic means); and
• organising events (for example events for incoming international learners).

In addition to those organisations named above, we will also share your personal data with:

• former schools/Training Centres who will use your results for their statistics or research purposes. The Training Centre complies with these requests in order to assist your former school/Training Centre in understanding how their learners perform at higher education so they can use this knowledge to improve their support to current learners;
• our agents and contractors where they require your personal data to perform the services outlined above; and
• direct mail agencies who assist the Training Centre in the administration of mailing to learners (where learner data will only be used for mailings from the Training Centre).

It may be the case that some of the uses listed above as falling under a legitimate interest will in fact be necessary for the performance of a public interest task required of the Training Centre, although these are more fully covered in the next section.

Legal obligations and the Training Centre’s public task

As a provider of higher education, the Training Centre is in certain respects a public authority. Your personal data will also be processed by the Training Centre for compliance with the Training Centre’s legal obligations or as part of its public interest task. For example:

• subject to legal and ethical safeguards, for public interest archiving, scientific and historical research or statistical analysis (but we will not use your name or other identifying details except to the extent relevant and necessary);
• for the detection and prevention of crime and in order to assist the police and other competent authorities with investigations;
• to comply with tax legislation, immigration and visa requirements, safeguarding duties and subject access requests of others;
• for purposes connected to local authority matters such as electoral registration, council tax or the investigation of benefit fraud; and
• for the purpose of providing census or other information including the assessment of fees to governmental and regulatory authorities.

In this respect, as well as the organisations mentioned above, we may in specific circumstances need to share your personal data with third parties who have made legitimate requests under data protection or freedom of information law; the police and other law enforcement agencies; local authorities; the Home Office, British overseas consulates; other international and national governmental and regulatory bodies; HMRC and the Training Centre’s external auditors; the Office for Learners; and the Office of the Independent Adjudicator.

Where you have consented

Your personal data will also be processed by the Training Centre where we have your consent. Examples where consent would be sought or given may include where specific services have been requested or applied for from the Training Centre (for example, where an applicant or learner has requested help from the Training Centre regarding their visa status) or where the law or some other protocol requires that the Training Centre obtains your consent (for certain marketing or fundraising communications, or participation in certain types of research projects). We will also ask for your consent before we submit your details to the Disclosure and Barring Service if we require evidence of whether you have any criminal convictions (see the section on Criminal convictions below).

Where applicable, consent will always be specific and informed on your part, and the consequences of consenting or not, or of withdrawing consent, will be made clear.

Special categories of personal data

In addition to the above, Training Centre may process types of personal data that the law considers to fall into a special category (such as race, religion, health, sexual life) or criminal records information. This will be under the following circumstances:

• Where you have provided your explicit consent. Examples might include to register you with a professional body where it is a requirement of your studies (e.g. the General Medical Council for medical learners) or where it is required in connection with particular programmes of study or prior to certain placements, or with welfare or special needs; or for the assessment and provision of services to disabled learners.
• Where such processing is necessary for the establishment, exercise or defence of legal claims (including sharing with the Training Centre’s insurers and legal advisers) or the prevention or detection of crime (for example, detecting criminal actions through the use of CCTV or reporting allegations to the police);
• Where it is necessary for statistical or research purposes; for example, for researching the diversity of our learners and to help widen participation. Please note that use of your personal information in this way will be subject to appropriate safeguards including the pseudonymisation of personal information where this is possible. In all cases we will evaluate the benefits of our use of your personal information in this way against the possible impact on your rights and freedoms and any damage or distress you are likely to be caused as a result of such processing, and will not use this research or analysis in any way that will result in a direct decision or measure affecting you personally. If it is lawfully and ethically appropriate to do so, we may also seek your explicit consent to use your data in this way.
• to assist the police or other law enforcement agencies or local authorities.
• Where it is in your vital interests to do so and you are incapable of giving consent, for example to inform your specified emergency contact, the NHS or emergency services in the event of your illness or other emergency.

Criminal convictions

You will be asked to provide the Training Centre with details of criminal convictions where your course, or a project you volunteer or are employed to undertake (for example, with the Learner Recruitment and Outreach programme) requires a DBS check. A DBS check will only be conducted under the lawful process provided for by law. We will only use the criminal convictions data for the purpose it was collected and it will only be retained for a limited period (see the section on How long is my personal information retained for?).

International transfers of data

The Training Centre will in limited circumstances disclose personal data to third parties, or allow personal data to be stored or handled, in countries outside the European Economic Area.  For example, we will transfer data to:

• partner institutions or organisations where you undertake, or plan to undertake, a placement or exchange programme as part of your studies; and
• IT providers based overseas, including our providers of anti-plagiarism software and external agencies who assist in detecting plagiarism; and

In these circumstances, your personal data will only be transferred on one of the following bases:

• where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission);
• a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
• there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent).

Profiling and automated decision making

We use some personal characteristics for profiling purposes to indicate where an applicant fulfils particular contextual admission criteria as defined by the Training Centre (from time to time) to help widen participation. However, all decisions about admission will ultimately be made by a dedicated Admissions Tutor.

Your rights under the Data Protection Legislation

• To require that we cease processing your personal data if the processing is causing you damage or distress;
• To require us not to send you marketing communications.
• To request that we erase your personal data;
• To request that we restrict our data processing activities in relation to your personal data;
• To 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 transmitting that personal data to another data controller; and
• To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and requests may be refused where exceptions apply.

If you have any questions about these rights or how your personal data is used by us, you should contact the Data Protection Officer using the details below:

• Post – Data Protection Officer
  Address – 7^th Floor, 252-262 Romford Road, London E7 9HZ
• Email – dpo@grupotraining.co.uk
• Telephone – 020 3983 4566

If you are not satisfied with how your personal data is used by the Training Centre you can make a complaint to the Information Commissioner (www.ico.org.uk).

How long is my personal information retained for?

After you leave the Training Centre, some learner data (including some personal data) will be retained as a permanent archival record for research and legal purposes. Your data is otherwise retained in accordance with the Training Centre’s.

Please note: if you submit an application for admission to the Training Centre, successfully or otherwise, as a matter of course we will permanently retain a copy of your application. This is in order to research and analyse trends and identify possible improvements in the Training Centre’s admissions process and diversity, as well as its outputs including learner results and careers. This is necessary to ensure appropriate monitoring of the effectiveness of our admissions services, and core educational functions, as a UK Higher Education provider.

Any resulting outcomes or findings that we publish will be statistical and anonymised, and will not identify individuals. If you do object to our retaining your admissions information for these purposes, we will consider such objections alongside available ways to safeguard and minimise personal data that will not prejudice the Training Centre’s core research functions. We will also retain applications to assist our ability to detect fraud. If you have any further questions please contact dpo@grupotraining.co.uk.  

Document last updated in January 2022 and will be reviewed in January 2023

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