General Privacy Notice – HSDC Students

HSDC is a General Further Education College and the contact details are:

Alton Campus: Old Odiham Road, Alton, GU34 2LX
Havant Campus: New Road, Havant, PO9 1QL
South Downs Campus: College Road, Waterlooville, PO7 8AA

Telephone: 023 9387 9999
Email: customerservices@hsdc.ac.uk

For the most part, HSDC manages your personal data and is the ‘Data Controller’ for personal data we hold about you. We keep your personal data securely and restrict access to personal information to people who need to use it in their duties. When collecting and processing information about you, we must comply with the UK Data Protection Act, 2018, the UK General Data Protection Regulation (UK GDPR).

We have a data protection officer who can be contacted about any queries or concerns regarding this privacy notice or the way your personal data is being processed. The contact details are:

Data Protection Officer
HSDC South Downs
College Road
Waterlooville
PO7 8AA

Telephone: 023 9387 9999
Email: DataProtection@hsdc.ac.uk

It is important that students read and retain 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 and what your rights are under the data protection legislation. We have several different reasons why we would need to process your personal data. The purpose of processing your data is as follows:

For Academic purposes: to provide you with teaching, learning and support services, assess your work, record your progress and confer awards

What is our lawful basis for processing personal data?

• We have a legal authority to process your personal data where this is necessary to perform a task carried out in the public interest, namely the provision of further education.
• If you use optional free services like careers advice, you can opt into these and withdraw your consent to them at any time.
• Suppose you have applied to us through the Universities and Colleges Admissions Service (UCAS), a partner institution or one of our agents. In that case, we will have received the information that you have provided to these bodies.

We collect and use your information to:

• For management of enquiries with prospective students and communication of information about our services, events and activities;
• Correspondence with offer holders regarding the next steps in the application and enrolment processes
• Enrol you as a student;
• Administer our programmes of study and research and associated funding and fee arrangements;
• Monitor performance and attendance, supervise conduct assessments and examinations and discuss and confirm awards using ProMonitor or Moodle.
• To give you access to student support, IT, library, careers, mentoring, social, sport, catering, and other services to the College community;
• Deal with appeals, complaints and disciplinary matters promptly and fairly;
• Provide academic guidance and enable you to communicate with staff, your student representative and fellow students on your programme of study;
• Seek your feedback on our programmes and facilities.
• We may, from time to time, take images and recordings (both audio and video) of our students in the conduct of their studies, or when engaging in a college sanctioned or organised event or programme. This may occur on college premises or elsewhere. This is to assist you in evaluating your performance and to provide a basis from which you can work to improve your attainment. You will always be informed before such images and recordings are taken, and you will be asked to give explicit further consent before images and recordings taken in this manner are used for any other purpose than to assist you with your programme of study.

For Administrative & Financial Management purposes: To administer fees and paid-for services

What is our lawful basis for processing personal data?

• If you pay fees or use paid services like printing services and gym membership services, we need to process your data to fulfil a contract you entered with us.

These may include:

• Fees and payments;
• Graphics and printing services;
• Catering services;
• Club and facility memberships;
• Fines;
• Travel support i.e. bus pass;
• Bursary for Vulnerable Group Scheme.

To meet our duty of care to you and our legal obligations:

What is our lawful basis for processing personal data?

• Comply with a legal obligation;
• Protect vital interests in an emergency;
• Exercise or defend legal claims or comply with court judgements;
• Provide medical and health services;
• Protect public health.
• To meet our legal duty of care to you under health and safety and safeguarding laws;
• To provide counselling and health services;
• To protect your vital interests or someone else’s, e.g. in a medical emergency;
• To comply with a statutory obligation, e.g. under tax or immigration law;
• To meet our obligations under equality law:

 For public safety and the prevention and detection of crime
What is our lawful basis for processing personal data?

• Where this is necessary for the prevention, investigation, detection or prosecution of criminal offences, including the safeguarding against and the prevention of threats to public security.

Processing for these purposes includes:

• Use of CCTV systems to monitor and collect visual images;
• Monitoring use of IT facilities;
• Applying security, welfare and other procedural measures where necessary for the safety and security of students and the wider College community under health and safety and other relevant laws.

To promote our college
What is our lawful basis for processing personal data?

• Where we have your consent;
• Where necessary for archiving purposes in the public interest.

We may take photographs and other images and recordings of students for possible use in our publicity and promotional material in print and online on our websites and social media. We always inform people when filming and will only feature you in such promotional material with your consent. We keep copies of promotional material for as long as required and may save some images as achieve.

For archiving and research
What is our lawful basis for processing personal data?

Where this is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

While always protecting your privacy rights, we will:

• Keep a permanent archival record of your time studying with us;
• Retain copies of promotional material and other records of College community life that may include images and other data about students.
• Produce management and statistical information to monitor and improve our performance and services to you and inform strategic planning, e.g., recruitment.

The College discloses information about students to a variety of third parties. This will always be done following the relevant legislation. However, you should be aware that it is not necessary to seek your consent to share your personal data in many cases. This may be for several reasons; for example, the College is under a legal or statutory obligation to provide the information.

See the following list:

We pass most of the information to government agencies to meet funding arrangements. This means that the College will pass most of the personal information and some of the sensitive information you provide to the Education and Skills Funding Agency (ESFA). Where necessary, it is also shared with the Department for Education (DfE).

The information is used to exercise these government departments’ functions and to meet statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009. It is also used to create and maintain a unique learner number (ULN) and a Personal Learning Record (PLR). In addition, we may share your data with Ofsted and other auditors for Analytical and statistical purposes and Hampshire Country Council and other Local Authorities.

The information provided may be shared with other organisations for administration purposes, the provision of career and other guidance and statistical and research purposes relating to education, training, employment and well-being. For example, if you have consented and are participating with  What Works for Children’s Social Care and King’s College London to evaluate the Future YOU programme. This will only take place where the sharing follows the Data Protection Act 2018 and GDPR. We may also contact your previous school to enable your transition from school to HSDC.

You may be contacted after you have completed your programme of learning to establish whether you have entered employment or gone onto further training or education.

You may be contacted by the English European Social Fund (ESF) Managing Authority or its agents to carry out research and evaluation to inform the programme’s effectiveness.

If your consent is required before sharing your information, we will contact you to ask for this. If you do not consent, your data will not be shared (unless we are legally required to do so). Personal data will only ever be disclosed in accordance with the data protection legislation in force at the time.

The College may also appoint people and organisations to work for us and contract with them to act as data processors on our behalf for any of the above purposes. Examples include training, setting and administering examinations, provision of email and other IT services, hosting communications services, IT systems maintenance, sub-contractors to deliver learning.

Some of the reasons why we share your data are:

Applicants:

• During the application process we may share your application data with your current school or education provider on the basis of consent. We ask for your consent to do this during the application process, and this can be withdrawn at any time by contacting optout@hsdc.ac.uk.
   
• We may continue to communicate with your parents/guardians after your 18th birthday about your progress, if you provide consent. During the application stage we ask your permission to share this past your 18^th birthday, this can be withdrawn at any time by contacting optout@hsdc.ac.uk. 

For Academic purposes

• With a partner institution to deliver a programme collaboratively or jointly between the College and the partner institution.
• With our external examiners: to check that our assessment of your work is fair;
• For an official independent assessment of our programmes, e.g. Pearson
• With employers that you have an apprenticeship with

And to:

• Verify your attendance and qualifications, e.g. in a reference for a potential employer or agency
• Confirm your attendance for the Student Loans Company processing
• Arrange a suitable placement if this is part of your course;
• Administer your right to be a member of the HSDC Student Union
• Publicise your award in our newsletter and in the list of awards we provide in press releases to news media and your previous school or College. You have the right to opt-out of this;
• Enable you to participate in the National Student Survey or other official surveys that give us your feedback on our academic quality and student experience.

To meet our legal obligations to you and another organisation, we will:

• Help the emergency services (fire, police, ambulance) or a health professional to protect your vital interests or someone else’s, e.g. in a medical emergency;
• Submit statistical returns to the government or its agencies, including the Education Skills Funding Agency (ESFA), and other official bodies, such as the Higher Education Statistics Agency (HESA)

This may include sensitive data for equality monitoring purposes. You can find a copy of the ESFA privacy notice on their website which can be found here.

• Meet a statutory or regulatory obligation, e.g. a court order;
• Confirm fee payments you may make
• Confirm your eligibility for tuition fee funding with agencies including the ESFA, and the Student Loans Company

Any data that is stored outside the UK will ensure it meets data protection obligations.

We keep information about you only for as long as needed to provide you with academic and support services and meet our legal obligations and rights. Almost all your personal data is destroyed securely six years after you leave the College. We keep a limited permanent record of your attendance, what you studied and your qualification grade so that we can verify this as needed and for archival purposes.

You have a number of rights over your personal information, which are:

• the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy about the way your personal data is being used – please refer to the ICO’s website for further information about this (https://ico.org.uk/);
• the right to ask us what personal information about you we are holding and to have access to a copy of your personal data;
• the right to ask us to correct any errors in your personal information;
• the right, in certain circumstances such as where our use of your personal information is based on your consent, and we have no other legal basis for using your personal information, for asking us to delete your personal data;
• the right, in certain circumstances such as where we no longer need your personal information, to request that we restrict the use that we are making of your personal data;
• the right, in certain circumstances, to ask us to review and explain our legitimate interests to you;
• the right, where our use of your personal information is carried out for an agreement with us and is carried out by automated means, to ask us to provide you with a copy of your personal information in a structured, commonly used, machine-readable format.

We keep our privacy policy under regular review.