Privacy Policy

GLOBAL UNIVERSITY SYSTEMS’ PRIVACY NOTICE

Introduction

 

Welcome to the Global University Systems privacy notice.

 

Global University Systems, a trading name of Global University Systems B.V. and its subsidiary companies including Interactive Pro Limited, respects your privacy and is committed to protecting your personal data. This privacy notice tells you how we look after your personal data when you visit our websites (regardless of where you visit from) and tells you about your privacy rights and how the law protects you.

 

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.  Please also use the Glossary at section 12 for the meaning of some of the terms used in this privacy notice.

 

 

  1. IMPORTANT INFORMATION AND WHO WE ARE
     
  2. THE DATA WE COLLECT ABOUT YOU
     
  3. HOW IS YOUR PERSONAL DATA COLLECTED
     
  4. HOW WE USE YOUR PERSONAL DATA
     
  5. Purposes for which we will use your personal data
     
  6. How we use sensitive personal information (SPECIAL CATEGORY DATA)
     
  7. DISCLOSURES OF YOUR PERSONAL DATA
     
  8. INTERNATIONAL TRANSFERS
     
  9. DATA SECURITY
     
  10. DATA RETENTION
     
  11. YOUR LEGAL RIGHTS
     
  12. GLOSSARY



Purpose of this privacy notice

 

This privacy notice aims to give you information on how Global University Systems collects and processes your personal data including any data you may provide through this website when you:

 

This website is not intended for children and we do not knowingly collect data relating to children on this website.  However where GUS processes personal data of children in its business operations, we ensure that appropriate safeguards and consents are obtained from parents or caregivers as applicable [and that we follow relevant guidance from the Information Commissioner’s Office in relation to the processing of children’s data]. You may contact legal@gus.global for further information about this.

 

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

 

This privacy notice supplements the other notices and does not replace them.


1.Important information and who we are


DATA Controller

 

Global University Systems B.V. is a company registered in The Netherlands under company number 55367453 and we have our registered office and our main trading address at Tower H, WTC Amsterdam, Zuidplein 36, 1077 XV Amsterdam, The Netherlands. This website is operated on behalf of Interactive Pro Limited, a company registered in England with number 6588211 with its registered office at Belmont House, Station Way, Crawley, West Sussex, RH10 1JA.

 

The Global University Systems B.V. group of companies is made up of different legal entities, details of which can be found here [https://www.globaluniversitysystems.com/. This privacy notice is issued on behalf of the Global University Systems group of companies so when we mention Global University Systems, "GUS", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the GUS Group responsible for processing your data. When you apply for programmes, courses or otherwise purchase a product or service with us, the controller will be the name of the institution that you are register with, unless otherwise indicated in writing to you in the application process. However, when you are just browsing our websites, the relevant data controller is GUS UK Management Limited, unless specifically mentioned otherwise on a particular website.

 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

 


Contact details

 

Our full details are:


Full name of data controller legal entity:  GUS UK Management Limited

Name or title of DPO:  FAO Data Protection Officer

Email address: legal@gus.global

Postal address: Legal Department, 30 Holborn, London, EC1N 2LX,

Telephone number: + 44 (0) 20 3435 4455

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 (www.ico.org.uk). We consider that the ICO would also be the lead supervisory authority for GUS since the UK is the place of the majority of our operations. For data protection issues in other countries, you have the right to complain at any time to the supervisory authority for that country.

We would always prefer that you come to us to help address any concerns of a privacy nature however before you go to the ICO or other applicable supervisory authority, so please contact us in the first instance.


Changes to the privacy notice and your duty to inform us of changes

 

This version was last updated on 23 May 2018 and historic versions can be obtained by contacting us.

We may from time to time change the detail in this notice.  Any changes we may make in the future will be posted on this page.  Please check back frequently to see any such updates or changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 


2.The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. Anonymous data is therefore not treated as personal data.

We have grouped together different kinds of personal data which we may collect, use, store and transfer as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.


Special Category Data

 

When you make an application on our website for a course or programme we will ask whether you have any disabilities. You are not obliged to inform us but any information you do provide will assist us to assess how we will meet our statutory obligation in relation to your disability.


CRIMINAL OFFENCE DATA

For the purposes of compliance with our Safeguarding Policy, we may ask for DBS checks or seek criminal records information.  This type of data is regulated under the GDPR and we ensure that we limit the use of any such data both in time and in scope and that we meet appropriate lawful grounds for processing such data.

For further information please contact us at legal@gus.global

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.



3.How is your personal data collected?

We use different methods to collect data from and about you including through:

Technical Data from the following parties:


(a)analytics providers such as Google analytics, Google optimizer, Google Webmaster tools, Google tag manager, Facebook, Instagram and Conversant based out of Europe & Convertr Media based in UK and other similar services which we will be using in the future;


(b)advertising networks such as Google Advertising Network, Facebook, Instagram, Bing and Linkedin based outside the EU and similar network we will be partnering with; and


(c)search information providers such as Google, Bing and other search engines based inside and outside the EU, social media networks such as Facebook, Linkedin and Instagram, based inside the EU and others providing similar services.


(d)Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Conversant, Google Analytics, Facebook, Instagram, Bing, Linkedin and Stripe, based outside the EU and Convertr Media based inside the UK including similar services we will partner with in future.


(e)Identity and Contact Data from data aggregators


(f)Identity and Contact Data from publicly availably sources such as the Electoral Register based inside the EU.


(g)Student Data from staff, administrative functions of other educational establishments, mentees or mentors, complainants.


(h)Academic, contact, identity, marketing and communications and technical data from (i) publishers, who are owners of private websites, and are based in and outside Europe and (ii) agents, referring organisations such as other universities and (iii) UCAS.




4.How we use your personal data

 


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


Please see the table below to find out about the types of lawful basis that we will rely on to process your personal data.

 


Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or SMS. You have the right to withdraw consent to marketing at any time by contacting us at info@interactivepro.org.uk or by clicking the unsubscribe link in the relevant emails.

 

 


5.Purposes for which we will use your personal data

 


We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 


We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.



Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Students or prospective students

To respond to your request for a call (or email) back, course enquiries, applications

(a) Contact Data

Performance of a contract with you (in our anticipation of entering into such contract with you)

To enroll / register you as a new candidate and provide student number / identity card

(a) Identity Data

(b) Contact Data

(c) Academic Data

Performance of a contract with you

Direct marketing of or about student benefits and opportunities, University activities and events, services or career opportunities and professional and industrial bodies wishing to communicate with students about career opportunities.

Promotion of University or school via prospectus containing images of current students.

Direct marketing may include cookie based remarketing services intended to deliver targeted marketing to you based on your internet searches

(a) Contact

Consent

To process your application including for the provision of services including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) accounting for VAT purposes

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data  (e) Marketing and Communications Data

(f) Academic Data

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

(c) Consent

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Provision of learning materials

(c) Asking you to leave a review or take a survey

(d) Monitor attendance or any change in student status.

(e) Administration of appeals, complaints, and matters relating to health and conduct and to cheating and plagiarism (unfair means).

(f) Granting of awards

(g)Administration of alumni membership

 

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Marketing and Communications Data

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how students use our products/services)

(d) Necessary for the candidate’s legitimate interests (to receive the benefit of the award)

Equal opportunities monitoring (for some but not all of our institutions)

Gender ethnicity religion and nationality

Legal Obligation

 

Enrolment

(a) Identity Data

(b) Student Data

Necessary for the performance of a contract

Make adjustments to meet disability requirements / medical conditions

Health Data

Consent

Provide health and safety first aid assistance emergency evacuation, hazard risk assessment, accident monitoring

Health Data

Vital interests

Consent

Emergency accident / health management

Emergency contact / next of kin details

Vital interests

Consent

Improvements in service offering, profiling students based on their performance and other

Student Data (specifically learner analytics)

 

Customers (or prospective customers) of[ online courses and published media

Register new customer of online materials

(a) Identity Data

(b) Contact Data

Performance of a contract with you

Process / fulfil / deliver customer order

Manage payments, fees and charges

Collect/ recover monies owed

Accounting records

Defence of legal claims brought against us

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us or defend legal claims)

(c) Necessary to comply with a legal obligation

Clients of GUS (including employer clients)

To register you as a client of GUS

(a) Identity Data

(b) Contact Data

Performance of a contract with you

To process, fulfil and deliver our service to you

Manage payments, fees and charges

Collection/ recovery of monies owed

Accounting purposes

Defence of any legal claims brought against GUS

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us or defend legal claims)

(c) Necessary to comply with a legal obligation

Suppliers to GUS

To register you as a supplier of GUS

(a) Identity Data

(b) Contact Data

Performance of a contract with you

To process and receive goods/services:

(a) Manage payments, fees and charges

Accounting purposes

Defence of any legal claims brought against GUS

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to defend legal claims)

(c) Necessary to comply with a legal obligation

For All

 

 

Recruitment (Academic job applications performed via webform)

(a) Identity Data

(b) Contact Data

 

Performance of a contract with candidate

Relationship management

Updating privacy policy and notify you of the same

Updating terms and conditions and notify you of the same

Seeking your feedback

Processing complaints

 

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (continuous improvement / updating records/ analyse customer behavior patterns)

To enable you to complete a survey

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Usage

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (continuous improvement / updating records/ analyse customer behavior patterns)

To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity Data

(b) Contact Data

(c) Technical Data

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity Data

(b) Contact Data (c) Profile Data (d) Usage Data

(e) Marketing and Communications Data

(f) Technical Data

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, student and partner relationships and experiences

(a) Technical Data

(b) Usage Data

Necessary for our legitimate interests (to define customer types for our products /services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity Data

(b) Contact Data

(c) Technical Data

(d) Usage Data

(e) Profile Data

Necessary for our legitimate interests (to develop our products/services and grow our business)

 


6.How we use sensitive personal information (SPECIAL CATEGORY DATA)

The law requires us to meet additional conditions for collecting, storing and using personal data that is considered ‘special category’ data. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

 

Purpose/Activity

Type of data

Lawful basis for processing

Students or prospective students

To enroll you as a student we need to determine your immigration status with GUS

Nationality data

Immigration status (information from visas and passports)

(a) Performance of a contract with you

(b) Compliance with a legal obligation eg to the UK Home Office, German immigration authorities (and others)

To make required adjustments and necessary support for applicable learning needs

 

Disability data

Special learning needs

(a) Performance of a contract with you

(b) Complying with our legal obligations (under the Equality Act 2010)

(c) Explicit consent (information is voluntary)

To:

(a) Monitor student absences*

(b) Deal with applications for mitigating circumstances

(c) Deal with applications for interruptions of studies or deferrals

(d) Confirm any dietary requirements

Medical / health data

Doctors’ notes

Medical Records (potentially)

(a) Performance of a contract with you

(b) Explicit consent (this information is voluntary)

(c) *sometimes a visa will stipulate that a student must keep a minimum attendance level; in this case we will ask for medical evidence to support absence and thus to avoid breaching our obligations to the UK Home Office.

To monitor and report on equal opportunities

Data relating to race and ethnic origin

(a) Compliance with a legal obligation

 


The above information may also need to be used using the lawful basis of pursuant to a legal claim or to protect your interests (or someone else's interests) (where you are not capable of giving your consent (for example if you suffer a medical problem preventing your ability to communicate).

 


Consent

It is not a condition of becoming a student with us that you give us consent for any particular type of processing. However, should you choose not to give consent, then you may not benefit from certain support services for example.

 

We do not need your consent in circumstances where we use special categories of your data in accordance with our legal obligations (and we set this out in our written policies).

 

On rare occasions we may ask for your explicit (written) consent to use certain special categories of data. If we do this we will make sure you have a detailed explanation of the data we need and why. This will enable you to make an informed decision whether you wish to consent.

 


Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will always give you options to determine how we use your personal data in this regard. 

 


Promotional offers from us

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you filled out a survey or feedback form and, in each case, you have not opted out of receiving that marketing.

 


Third-party marketing

 

We will get your express opt-in consent before we share your personal data with any company outside the GUS Group of companies for marketing purposes.


Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out / unsubscribe links on any marketing message sent to you at any time or by contacting the admissions team.

Where you opt out of receiving these marketing messages, this will not stop us storing your data provided to us as a result of a applying for a course or programme or buying some other service or materials from us.


Cookies

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.


Change of purpose

 

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO.

 

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

 

7.Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

8.International transfers

 

We share your personal data within the GUS Group. This will involve transferring your data outside the European Economic Area (EEA).

 

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

The transfer is made from a register which according to Union or Member State law is intended to provide information to the public and which is open to consultation either by the public in general or by any person who can demonstrate a legitimate interest, but only to the extent that the conditions laid down by Union or Member State law for consultation are fulfilled in the particular case.

Please contact our DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


9.Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10.Data retention

How long will you use my personal data for?

 

We will only retain your personal data 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 you can ask us to delete your data: see Request Erasure below for further information.

 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

11.Your legal rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

You may raise an objection to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

You may request to restrict our processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

You may exercise your right to transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

This applies only where we rely on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

In certain circumstances, you can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also contact us at info@interactivepro.org.uk if you wish to exercise your rights.

If you wish to exercise any of the rights set out above, please contact our DPO.

 

 

12.Glossary

 

LAWFUL BASIS

 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DPO.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take preliminary pre-contractual steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

Internal Third Parties

 

Other companies in the GUS Group acting as joint controllers or processors and who are based throughout the world and provide shared services such as IT, legal services, system administration services and leadership reporting.

 

External Third Parties



SPECIFIC THIRD PARTIES

Third party systems on which data may be hosted include:

 

  

© GUS UK Management Limited May 2018

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