​LincHigher Privacy Statement

LiNCHigher is committed to protecting the privacy and security of the personal information we collect. This privacy policy explains how we collect and use your personal information when you visit our website or take part in any of our activities, in accordance with the General Data Protection Regulation (GDPR). It applies to all learners, teachers and advisors and parents who take part in our activities, and visitors to our website.

LiNCHigher will be what is known as the ‘Data Controller’ of the personal data we hold about you. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Section 1 – The information we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.

LEARNERS TAKING PART IN OUR ACTIVITIES

We may collect (with consent), store, and use the following categories of personal information about you:

  • Full name
  • Postal address
  • Name of school or college you attend
  • Date of Birth
  • Gender
  • Next of kin and emergency contact details

We may also collect (with consent), store and use the following ‘special categories’ of more sensitive personal information:

  • Your ethnicity
  • Details of disability or relevant medical condition
  • Care status
  • Young carer status

This data can be collected through a number of different routes, please see Section 2 for further detail.

TEACHERS AND ADVISORS ATTENDING OUR ACTIVITIES

We may collect, store, and use the following categories of personal information about you:

  • Full name
  • School or college you work at
  • Relationship to attending learners, or job title
  • Email address used for work purposes

PARENTS AND CARERS ATTENDING OUR ACTIVITIES

We may collect, store, and use the following categories of personal information about you:

  • Full name
  • Postcode
  • School or college your child attends

CURRENT STUDENTS AT OUR PARTNER INSTITUTIONS ENGAGED ON CASUAL CONTRACTS AS STUDENT AMBASSADORS

We may collect, store and use the following categories of personal information about you:

  • Full name
  • Sex
  • Date of birth
  • University and personal email addresses
  • Personal telephone number
  • University/College you study at
  • Course and year of study

VISITORS TO OUR WEBSITE

We may collect, store, and use the following categories of personal information about you:

  • Full name
  • Postcode
  • School or college you are affiliated with
  • Email address

We may also collect, store and use the following ‘special categories’ of more sensitive personal information:

  • Your nationality

Section 2 – How we collect personal information

LEARNERS TAKING PART IN OUR ACTIVITIES

We collect personal data about you through the following routes:

  • Completion of evaluation forms at the activities you take part in
  • Consent and completion of EMWPREP forms (see section 2a) before activities you take part
  • Consent and completion of additional information forms for taking part in certain events, such as residential events (staying over at one of our universities), or where there may be photographs or film footage taken of you. These will be signed by your parents if you are aged 16 or under
  • From your communication with LiNCHigher, for example if you contact us by email or telephone, or via social media
  • Directly from the school or college you attend

TEACHERS AND ADVISORS ATTENDING OUR ACTIVITIES

We collect personal data about you through the following routes:

  • Completion of evaluation forms at the activities you attend
  • From your communication with LiNCHigher, for example if you contact us by email or telephone, or via social media

PARENTS AND CARERS ATTENDING OUR ACTIVITIES

We collect personal data about you through the following routes:

  • Consent and completion of evaluation forms at the activities you attend
  • From your communication with LiNCHigher, for example if you contact us by email or telephone, or via social media
  • Completion of additional information forms allowing your child to attend certain events, such as residential events (staying over at one of our universities), or where there may be photographs or film footage taken of your child

CURRENT STUDENTS AT OUR PARTNER INSTITUTIONS ENGAGED ON CASUAL CONTRACTS AS STUDENT AMBASSADORS

We collect personal data about you through the following routes:

  • Applications to LiNCHigher to become an Ambassador
  • From your communication with LiNCHigher, for example if you contact us by email or telephone, or via social media

VISITORS TO OUR WEBSITE

We collect personal data about you through the following routes:

  • When you sign up to our newsletter through the website
  • When you use the  ‘Ask a question’ forms on our website
  • When you use the ‘Book activities’ section of our website
  • From your communication with LiNCHigher, for example if you contact us by email or telephone, or via social media

SECTION 2A – EMWPREP

As a condition of our funding, we use the EMWPREP monitoring and evaluation database to track the education journey of the learners we work with, and to use as a tool to evaluate our work.

LiNCHigher are required to comply with the data protection policies put in place by EMWPREP.

The full EMWPEP privacy policy can be found here: http://www.emwprep.ac.uk/schools-parents/gdpr/

The EMWPREP data sharing policy can be found here: www.emwprep.ac.uk/data-sharing-policy

Section 3 – How we use the personal information we collect

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • To prove to our funders, the Office for Students and Department for Education, that we are working with the people that our funding is provided for
  • To prove the impact of the work we are doing
  • To track the educational journey of the learners we work with, to measure the impact of the activities they take part in
  • To ensure the safety of learners when attending certain activities, such as residential events (staying over at one of our universities)
  • Where you have explicitly agreed to a particular use of your data (consent)
  • To communicate effectively with you by email or phone, where you have agreed to be contact, including the distribution of relevant newsletters and evaluation forms
  • In the case of current students who apply to become LiNCHigher Ambassadors, we may use your data to confirm with the partner institution you attend that you are a current student engaged on a casual contract there
  • For current students who have been accepted as LiNCHigher Ambassadors, we may share your details with third parties delivering activities you are engaged to work on

LEGAL BASIS FOR PROCESSING

LiNCHigher collects and processes personal information under the legal basis of public interest. This means that the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority (Office for Students and Department for Education).

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to allow you or your child to take part in certain activities.

CHANGE OF PURPOSE

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

AUTOMATED DECISION MAKING

Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention. LiNCHigher does not use automated decision making.

Section 4 – Data sharing

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. Your data will not be transferred, stored or processed outside of the EU.

We may share the personal information we collect and process with one or more of the following receiving organisations:

  • The Office for Students, and Department for Education (who fund our activities)
  • Our partner universities and colleges
  • The schools and colleges that the learners we work with attend
  • The Local Authorities of the schools and colleges that the learners we work with attend
  • Third party activity providers working in association with LiNCHigher
  • The national evaluators of our programme, CFE Research
  • Companies or organisations providing specific services to or on behalf of LiNCHigher, including but not limited to
    • Cosmos Engagement Ltd
    • EMWPREP
    • (For Student Ambassadors )we may share your name, email address, course studied and year of study with our online mentoring platform Unibuddy (whose privacy notice can be found   INSERT)

Section 5 – Data retention

HOW LONG WILL YOU USE MY INFORMATION FOR?

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.

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.

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.

Once we no longer need the personal data we have collected, or have reached the date of deletion as outlined in our Records Retention Schedule, it will be securely destroyed in accordance with the Records Retention Schedule.

Section 6 – Data breaches

LiNCHigher are committed to protecting the privacy and security of the personal information we collect and process, and take this responsibility very seriously. We have a robust data breach reporting process in place, of which all LiNCHigher staff members are aware.

We also have the following security measures in place to avoid data breaches from occurring:

  • Personal data is saved on restricted access drives only, and can only be accessed by those who need access to the data
  • Personal data is not transferred outside of the EU
  • Any personal data being transferred must be encrypted
  • Records Retention Schedule sets out the length of retention and method of secure destruction and deletion of personal data
  • Risk Register which is updated regularly, monitoring any risks to data processing

Any data breaches or suspected data breaches will be inspected and reported appropriately to the ICO within 72 hours of discovery. Where the data breach relates to individuals, we will do our best to notify those involved.

Section 7 – Your rights

Under GDPR, all individuals have the following eight rights:

THE RIGHT TO BE INFORMED

  • This means you have the right to be given information about how and why your data is being processed
  • When you provide your information directly to LiNCHigher, you will be informed at that time how it will be used. This will include the purpose of processing, how long it will be held, and details of any recipients of your data (who it may be shared with)

THE RIGHT OF ACCESS

  • You have the right to receive confirmation that your data is being processed and to access it by request
  • You can access your personal data by submitting a Subject Access Request to LiNCHigher and, after your identity has been verified, you will receive a response within one month
  • You can submit a Subject Access Request by emailing us at linchigher@bishopg.ac.uk

THE RIGHT TO RECTIFICATION

  • You have the right to correct your personal data if it is inaccurate or incomplete.
  • LiNCHigher will respond to requests for rectification within one month or, in the case of a complex request, up to three months. If your data has been shared with a third party, LiNCHigher will inform them of the rectification where possible.
  • You can request a rectification by emailing us at linchigher@bishopg.ac.uk

THE RIGHT TO ERASURE

  • You have the right to request that your personal data is removed, so long as there is no compelling reason for it to continue to be processed.
  • This does not mean that you have an absolute right ‘to be forgotten’, but that you can have personal data erased or prevent its processing in the following circumstances:
    • Where your personal data is no longer necessary for the purpose for which it was originally collected/processed
    • When you object to the processing and there is no ‘legitimate interest’ for LiNCHigher to continue the processing
    • Where your personal data was unlawfully processed
    • When your personal data has to be erased in order to comply with a legal obligation
  • LiNCHigher can refuse a request for erasure for the following reasons:
    • To exercise the right of freedom of expression and information
    • To comply with a legal obligation or for the performance of a public interest task or exercise of official authority
    • For public health purposes in the public interest
    • For archiving purposes in the public interest, scientific research, historical research, or statistical purposes
    • The exercise or defence of legal claims
  • If your data has been shared with a third party, the University will inform them of the erasure where possible.
  • You can make a request for erasure by emailing us at linchigher@bishopg.ac.uk

THE RIGHT TO RESTRICT PROCESSING

  • You have the right to restrict the processing of your personal data so that it may continue to be held but no longer processed
  • LiNCHigher will restrict processing in the following circumstances:
    • If you contest the accuracy of the data
    • Where you have objected to the processing of personal data where LiNCHigher has a legitimate interest
    • When processing is unlawful but you oppose erasure and request restriction instead
  • If your data has been shared with a third party, LiNCHigher will inform them of the restriction of processing where possible
  • You will be informed when LiNCHigher decides to lift a restriction on processing
  • You can make a request to restrict the processing of your personal data by email us at linchigher@bishopg.ac.uk

THE RIGHT TO DATA PORTABILITY

  • You have the right to obtain your personal data in an easily transferable format to reuse for your own purposes
  • This right only applies:
    • To personal data you provided to LiNCHigher;
    • Where processing is based on your consent or for the performance of a contract; and
    • When processing is carried out by automated means
  • LiNCHigher will respond to requests within one month or, in the case of a complex request, up to three months
  • You can make a request of data portability by emailing linchigher@bishopg.ac.uk

THE RIGHT TO OBJECT

  • You have the right to object at any time to the processing of your personal data for the purposes of direct marketing; processing based on ‘legitimate interests’ or; processing for research or statistical purposes. Please note, LiNCHigher will not use your personal data for direct marketing purposes.
  • This right relates only to the following specific purposes for processing, there is no right to object to processing in general:
    1. Processing based on legitimate interests – you must have grounds relating to your particular situation in order to object to your personal data being processed for this purpose. LiNCHigher must stop processing your data unless it can demonstrate compelling legitimate grounds which override your interests, rights and freedoms as an individual
    2. Processing for research or statistical purposes – you must have grounds relating to your particular situation in order to object to your personal data being processed for this purpose. If the research being conducted requires the processing of your personal data for the performance of a public interest task, LiNCHigher is not required to comply with an objection
    3. You can make an objection by emailing linchigher@bishopg.ac.uk

RIGHTS IN RELATION TO AUTOMATED DECISION MAKING AND PROFILING

  • You have the right not to be subjected to a decision that is based on automated processing which results in a legal impact upon you
  • In such a circumstance LiNCHigher must ensure that you are able to have human intervention in the decision, express your views and receive an explanation of the decision so that you may challenge it
  • This right does not apply if a decision does not have a legal effect on you, or if a decision:
    • Is necessary for entering into, or performance of, a contract between the data subject and LiNCHigher
    • Is authorised by law, for example for the purpose of fraud prevention
    • Is based on your explicit consent
  • The right to erasure and the right to portability do not apply when the legal basis for processing is public interest.

Section 8 – Data Protection Officer Details

LiNCHigher is based at Bishop Grosseteste University, and is required to comply with data protection policies put in place by Bishop Grosseteste University. Therefore, our Data Protection Officer is based at and works for Bishop Grosseteste University. You can contact the Data Protection Officer at dpo@bishopg.ac.uk

Full details of Bishop Grosseteste Universities’ Information Governance and Security Policy to which we are required to adhere can be found here: http://www.bishopg.ac.uk/wp-content/uploads/2018/05/Privacy-Policy.pdf

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. ICO contact details: www.ico.org.uk

Section 9 – Web browser cookies

a) What is a Cookie?

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (all referred to here as a "device") web browser from a website's computer and is stored on your device's hard drive. Each website can send its own cookie to your web browser if your browser's preferences allow it. Many websites do this whenever a user visits their website in order to track online traffic flows. Similar technologies are also often used within emails to understand whether the email has been read or if any links have been clicked. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on the LiNCHigher website. However, you can change your cookie settings at any time.

It is important to note that if you change your settings and block certain cookies, you will not be able to take full advantage of some features of LiNCHigher’s services.

On the LiNCHigher website, cookies record information about your online preferences and allow us to tailor our websites to your interests.

During the course of any visit to the LiNCHigher website, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things like find out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit.

b) How does LiNCHigher use cookies?

Information supplied by cookies can help us to understand the profile of our visitors and help us to provide you with a better user experience. 

c) Third party cookies in embedded content on the LiNCHigher pages

Please note that during your visits to the LiNCHigher website you may notice some cookies that are not related to the services LiNCHigher provides.

We sometimes embed content from social media and other third party websites. As a result, when you visit a page containing such content, you may be presented with cookies from these websites and these third party cookies may track your use of the LiNCHigher website. LiNCHigher does not control the dissemination of these cookies and you should check the relevant third party's website for more information. 

Where LiNCHigher embeds content from social media and other third party websites, some websites may use Google Analytics to collect data about user behaviour for their own purposes. LiNCHigher does not control this. For more information, see the Google webpage “How Google uses data when you use our partners’ sites or apps”.

d) Other information collected from web browsers

Your web browser may also provide LiNCHigher with information about your device, such as an IP address and details about the browser that you are using. 

DO NOT TRACK (DNT) BROWSER SETTING

DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. This website does not currently respond to DNT requests.