Information Governance and Security
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- Privacy Notice - Students
Applicants and Students - How we use your personal information
Keele University is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your academic relationship with us, in accordance with the General Data Protection Regulation (GDPR).
It applies to all students and prospective students (applicants and enquirers) of the university.
Keele University is a “data controller”. 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 notice.
This notice applies to students, applicants and prospective student enquirers. This notice does not form part of any contract to provide services. 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.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of Information we hold about you
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.
We may collect, store, and use the following categories of personal information about you:
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses, date of birth, gender, marital status and dependants, Next of kin and emergency contact information, financial information (including copies of evidence you have submitted to support financial applications), School/College records and qualifications, communications regarding your application and decision, qualifications, immigration information (including copies of passports, visas etc), references and other information included as part of your application process.
During you time at Keele we will store and use further information which we will collect from you or from other parties or will be generated by your activities as a student. These may include disciplinary and grievance information, CCTV footage and other information obtained through electronic means such as Keele card records, attendance, extenuating circumstances, Information about your use of our information and communications systems, Photographs, and Examination and Assessment information.
We may also collect, store and use the following “special categories” of more sensitive personal information (sometimes as part of, for example, extenuating circumstances or disciplinary/grievance processes):
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Student union membership.
- Information about your health, including any medical condition, disability or other reasonable adjustment requirements
How is your Personal Information collected?
We typically collect personal information about you through the following routes:
- Received directly from you as an applicant or during your time as a student e.g. at registration or when engaging with any university service;
- From UCAS as part of your application process;
- From the Student Loan Company as part of your application process. This includes data to allow us to check whether you may be eligible for a Keele Bursery or Scholarship;
- From other institutions who we may be partnering with in joint programmes;
- From other legitimate third party services.
- From your interaction with university services e.g. CCTV, Keele card use, IT services and so on.
We may sometimes collect additional information from third parties including former education institutions, employers, credit reference agencies, Sponsors or other background check agencies.
How we will use information about you
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:
We may also use your personal information in the following situations, which are likely to be rare:Where we need to protect your interests (or someone else’s interests).
Situations in which we will use your personal information
- To process your application to the university and to decide whether to offer you a place here
- To manage your registration with the university in accordance with the university policies and procedures
- To deliver and administer your education in line with the contract we have with you and the rules and regulations of the university
- To record the details of your studies (including any placements with external organisations)
- To determine your academic and some non-academic achievements you attain whilst at the university (e.g. results, awards, prizes, volunteering).
- To administer the financial arrangement between you and the university including any relationship you have with any funders/sponsors.
- To deliver facilities and support services to you, including Accommodation, IT, sport, library, careers, and student support services.
- To enable you to access the facilities and support offered by Keele University Student Union. The University has a legal duty to support the Student Union so that it be a strong and well run body representing the students of the university.
- To enable your participation at events – including for example graduation.
- To communicate effectively with you by post, email and phone, including the distribution of relevant newsletters and circulars regarding information related to your course, your use of the many university services and facilities, and relevant information which is related to your student life.
- To operate security (including CCTV), governance, disciplinary (including plagiarism and academic misconduct), complaint, audit and quality assurance processes and arrangements.
- To support your training, medical, safety, welfare and religious requirements.
- To assess whether you may qualify for any of our Bursaries & Scholarships
- To compile statistics and conduct research for internal and statutory reporting purposes.
- To fulfil and monitor our responsibilities and obligations under equalities, immigration and health and safety legislation.
- To fulfil our duty of care we owe to all our students, staff, clients, and visitors
- To enable us to contact others in the event of an emergency
- To help determine your eligibility for Council Tax Exemption and voter registration.
- At the end of your studies to stay in touch with you after graduation as a Keele Alumni. In return you'll receive:
- Mentoring and networking opportunities to help you succeed
- Invitations to exclusive Keele events and reunions happening around the world
- Opportunities to enhance your CV or take on new challenges through volunteering or fundraising activities
- Careers support, university news, alumni insights on topical issues and so much more
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our students).
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.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we will use particularly sensitive personal information
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent; or where you have already made the information public.
We may use your particularly sensitive personal information in the following ways:
- We may use sensitive information to assess and manage:
- The ‘Leave of Absence’ process – https://www.keele.ac.uk/studiesandcareer/leaveofabsenceloa/
- the exceptional circumstances process - https://www.keele.ac.uk/ec/
- student complaints, disciplinary cases or appeals – https://www.keele.ac.uk/sas/academicservices/studentappealscomplaintsandconduct/
- We will use information about your physical or mental health, or disability status, to ensure your health and safety and to assess your fitness to work/study (e.g. for placements), and to provide appropriate accommodation, study or work adjustments, support or assistance. These services may be provided through our Student Services.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful anonymous equal opportunity monitoring and reporting.
- We will use details about you health or disability status to assess and administer reasonable adjustment requirements for teaching and examinations - https://www.keele.ac.uk/disability/
- We may use your disability status to assess whether you may be eligible for one of our Burseries or Scholarships
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Information about criminal convictions
We will have received information about disclosed criminal convictions from your UCAS application (or other application route). We will use this information where required by law to assess your suitability for specific regulated courses (e.g. certain medical courses). We may also use the information for preventing or detecting unlawful acts, and safeguarding of children and of individuals at risk (Further details on how we consider criminal conviction data can be accessed here)
Automated Decision Making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
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 envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
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.
We may transfer your personal information outside the EU.
If we do, you can expect a similar degree of protection in respect of your personal information.
The University may share your personal data with third parties such as:
- Higher Education Statistics Agency see https://www.hesa.ac.uk/about/regulation/data-protection/notices
- Any funders/sponsors (e.g. the Student Loans Company or private/government sponsors)
- Employers (where employers are funding your course or as part of a degree apprenticeship arrangement or similar).
- The providers of any external/collaborative learning and training placements or fieldwork opportunities.
- External examiners and assessors, and external individuals involved in relevant University committees or procedures.
- Relevant Government Departments (e.g. Department for Education, Home Office, Foreign and Commonwealth Office, Department of Health).
- Relevant executive agencies or non-departmental public bodies (e.g. UK Visas and Immigration, HM Revenue and Customs, the Health and Safety Executive).
- Relevant Higher Education bodies (e.g. Office for Students, UK Research and Innovation, Universities and Colleges Admissions Service (UCAS), Office for Fair Access, Office of the Independent Adjudicator, the organisation(s) running the National Student Survey and other student and leaver surveys).
- Any relevant professional or statutory regulatory bodies (e.g. General Medical Council, SRA).
- External accommodation providers (where student accommodation is provided on behalf of the University)
- UK NARIC (see https://www.naric.org.uk/naric/About%20Us.aspx) to assist in verification, and for information, advice and opinion on academic, vocational and professional qualifications and skills from all over the world.
- Agents assisting the University with international admissions (this may include the disclosure of personal data outside the European Economic Area)
- Keele University Students’ Union (KeeleSU) and student clubs and societies including the Keele Postgraduate Association (KPA), in order to facilitate your membership of those bodies, and your eligibility to vote as a member of those bodies. For further information on membership of KeeleSU and KPA see here
- Keele University Students' Union where required to prevent or detect crime or investigate disciplinary offences
- Local authorities (in particular, we pass lists of students to Newcastle-under-Lyme Borough Council, Stoke-on-Trent City Council and Cheshire East County Council) to assist with the administration of students’ exemption from Council Tax and to administer Voter registration (where relevant).
- On occasion and where necessary, the police and other law enforcement agencies.
- Companies or organisations providing specific services to, or on behalf of, the University. This includes but is not limited to:
- Google (the university uses Google G-Suite for email and cloud storage services);
- Library IT systems;
- Bulk email services (e.g. Mailchimp);
- CRM systems;
- Accommodation systems;
- Students Records Systems;
- Lecture and Examination Timetabling systems;
- Gradintelligence (to provide your Higher Education Achievement Report, where applicable);
- Anti-plagiarism services e.g. Turnitin
- other cloud based systems supporting the university's service provision.
- For Research applications: if you engage in research funding application, we may be required to share your data concerning academic/career summary and salary details (if applicable) with collaborating institutions and/or funding bodies.
- Potential employers and other educational institutions requesting a reference or confirming the award of a current or past student either directly or via the Higher Education Degree Datacheck (HEDD).
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.
For admissions, we will keep records documenting the handling of applications for admission for end of student relationship + 6 years.
Details of retention periods for different aspects of your personal information are available in our retention policy which is available from https://www.keele.ac.uk/recordsmanagement/recordsretentionschedule/
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 you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our Data Retention Policy.
We will endeavour where appropriate to give further privacy information to you if you engage with specific services or facilties during your time at the university. These notices should be read in conjunction with this main privacy notice.
You have a number of rights with regards to how we process your information including access, correction, erasure and restriction.
Full details of these rights and how to exercise them can be found at https://www.keele.ac.uk/informationgovernance/yourdata-yourrights/
Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You 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.
DPO contact details : firstname.lastname@example.org
ICO contact details : www.ico.org.uk
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.