Data Privacy Statement
This Privacy Notice describes how PROCAT protects and makes use of the information you provide us with.
About this document
This privacy notice explains how PROCAT ("we", "our", "us") collects, uses and shares your personal data, and your rights in relation to the personal data we hold. This privacy notice concerns our processing of personal data of past, present and prospective students of PROCAT ("you", "your").
PROCAT is the data controller of your personal data and is subject to the Data Protection Act 1998 ("DPA") (and, once in force, to the General Data Protection Regulation (the "GDPR")).
Who does this apply to?
People who use or may use our services. This includes for example:
- visitors to our website
- individuals who study a course with us
- employers who purchase training from us
- employers who take a student on work experience or placement
- employers who employ an Apprentice
- individuals who are customers of the college’s commercial operations
- individuals who request information from us.
If you are asked to provide information to us, it will only be used in the ways described in this Privacy Notice.
This Privacy Notice is updated from time-to-time. The latest version is published on our website.
How we collect your information
We may collect your personal data in a number of ways, for example:
- from the information you provide to us when you interact with us before joining, for example when you express your interest in studying at PROCAT;
- when you apply to study at PROCAT and complete enrolment forms via the admissions processes and procedures and\or the Universities and Colleges Admissions Service (UCAS) and; • when you communicate with us by telephone, email or via our website or social media, for example in order to make enquiries or raise concerns;
- in various other ways as you interact with us during your time as a student of PROCAT, for the various purposes set out below;
- from third parties, for example from your previous or current school, sixth form college, FE college or university or employers who may provide a reference about you or who may sponsor your studies.
The types of information we collect
We may collect the following types of personal data about you:
- your name, and contact information such as address, email address and telephone number, as well as your date of birth, 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 student number;
- financial information i.e. bank details
- company information e.g. financial, staff, training needs analysis
- website usage data
- information relating to your education and employment history, the school(s), sixth form college(s) and other colleges or universities you have attended and places where you have worked, the courses you have completed, dates of study and examination results. We will also keep records relating to assessments of your work, details of examinations taken, your predicted and actual examination grades and other information in your student record;
- information about your family or personal circumstances, and both academic and extracurricular interests, for example where this is relevant to the assessment of your suitability to receive a bursary or in order to provide you with appropriate pastoral care;
- location Information – We may collect and process information that may reveal your location. We use various technologies to determine location including CCTV, GPS, building access control, attendance registers and device identifiers such as IP, MAC address and computer name.
- sensitive personal data and information about criminal convictions and offences, including:
- information concerning your health and medical conditions (e.g. disability and dietary needs);
- certain criminal convictions (e.g. for students on nursing programs, following completion of an annual declaration of “good character”); and
- information about your sex, disability, racial or ethnic origin; religion or similar beliefs; and sexual orientation.
How we use that information
Collecting this data helps us provide you with a service which meets your needs. Specifically, we may use data:
- to meet our legal and statutory duties and responsibilities
- to process applications, enrolments and workforce development programmes and contracts
- for our own internal records so that we can provide you with a high quality service
- to contact you in response to a specific enquiry
- to customise our services so they work better for you
- to contact you about services, products, offers and other things provided by us which we think may be relevant to you
- to contact you via e-mail telephone or mail for research purposes
- to be shared with other organisations for education, training, employment and well-being related purposes, including for research
- We use location data to track classroom and exam attendance, building security and IT security. We also use your location data to provide a convenient way to locate your colleagues. Such as revealing what campus a staff member is working from in Skype for Business. In certain situations we may use the GPS of College assets to reveal is location in the event of theft.
At no time will we assume your permission to use information that you provide for anything other than the reasons stated here.
How we use information about our students
The purposes for which we may use personal data (including sensitive personal data) we collect during a student's association with us include:
- recruitment and admissions;
- academic matters, including:
- the provision of our core teaching and learning services (e.g. registration, assessment, attendance, managing progress, academic misconduct investigations, certification, graduation);
- maintaining student records; o assessing your eligibility for bursaries and scholarships, etc.
- providing library, IT and information services;
- non-academic matters in support of our core services, including:
- providing student support services (e.g. through Additional Learning Support, academic departments);
- monitoring equal opportunities; o safeguarding and promoting the welfare of students; o ensuring students' safety and security; o managing student accommodation; o managing the use of social media; o managing car parking on campus;
- administering finance (e.g. fees, scholarships and bursaries);
- other administrative purposes, including: o carrying out research and statistical analysis;
- carrying out audits (e.g. to ensure compliance with our regulatory and legal obligations);
- providing operational information (e.g. providing IT support, information about building closures or access restrictions on campus, or safety advice);
- promoting our services (e.g. providing information about summer schools or other events happening on and off campus);
- preventing and detecting crime; o dealing with grievances and disciplinary actions; o dealing with complaints and enquiries.
Graduation and degree information
Personal data (including award and classification) will be published in the award ceremony booklet. This information will also be passed to third parties involved in the ceremonies (including our local paper and commemorative clothing suppliers). All published details will be available following the relevant graduation events.
You may withhold your consent to your name being published for these purposes when you register online to attend the award ceremony or graduate in absentia.
All award ceremonies may recorded and, if so, will be available to view online afterwards.
We will hold your information securely.
To prevent unauthorised disclosure or access to your information, we have implemented strong organisational and technical security safeguards.
If information is shared with another organisation (reasons for this are given in the section below) we will ensure an Information Sharing Agreement is in place. We also follow stringent procedures to ensure we work with all personal data in line with the GDPR.
The basis for processing your information and how we use it
We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following: • to interact with you before you are enrolled as a student, as part of the admissions process (e.g. to send you a prospectus or answer enquiries about our courses); • once you have enrolled, to provide you with the services as set out in our Student Agreement;
- to deal with any concerns or feedback you may have;
- for any other purpose for which you provide us with your personal data. We may also process your personal data because it is necessary for the performance of our tasks carried out in the public interest or because it is necessary for our or a third party's legitimate interests. In this respect, we may use your personal data for the following:
- to provide you with educational services which may not be set out in our Student Agreement but which are nevertheless a part of our academic and educational mission;
- to monitor and evaluate the performance and effectiveness of the university, including by training our staff or monitoring their performance;
- to maintain and improve the academic, corporate, financial, estate and human resource management of the university;
- to promote equality and diversity throughout the university;
- to seek advice on our rights and obligations, such as where we require our own legal advice;
- recovering money you owe to us;
- for fundraising purposes.
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data for the following: • to meet our compliance and regulatory obligations, such as compliance with antimoney laundering laws and safeguarding requirements;
- for the prevention and detection of crime;
- in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
We may also process your personal data where:
- it is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional);
- it is necessary to protect your or another person’s vital interests; or
- we have your specific or, where necessary, explicit consent to do so.
Sharing information with others
We do not sell or rent your personal information.
Your information may by necessity be disclosed to appropriate staff members of PROCAT and to government bodies (to fulfil our statutory responsibilities) such as the Education Skills Funding Agency, Ofsted, the Department for Education and auditors or with local partners e.g. Connexions Service.
Information may be shared with third parties if it is in connection with the service we are providing to you, for example we might share information with market research companies contracted to undertake work on our behalf to assess your satisfaction with our service. When we do this we always ensure an Information Sharing Agreement is in place.
We will only share your personal information with other people e.g. parents or carers, or with agencies such as the Benefits Department with your permission.
If, as part of the entry requirements for your course or if you are applying for a job with us, we need to take up a reference or obtain ‘disclosure’ from the Disclosure and Barring Service, we will inform you beforehand.
Any personal information we hold about you is processed in accordance with the
Data Protection Act 1998 and the GDPR as of 25th May 2018
For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with certain third parties. You are given the opportunity not to opt in to of some of these data sharing arrangements, for example when you register with us, but you should carefully consider the possible impact of doing this. If an opt-in is in place, we may disclose limited personal data to a variety of recipients including:
- our employees, agents and contractors where there is a legitimate reason for their receiving the information, including:
- third parties who work with us to provide student accommodation;
- third parties who work with us to provide student support services (e.g. counselling);
- third parties who are contracted to provide out-of-hours IT services for us;
- organisations operating anti-plagiarism software on our behalf (such as Turnitin®) o internal and external auditors.
- those with an interest in tracking student progress and attendance, including: o student sponsors (e.g. the Student Loan Company);
- current or potential education providers (for example, where you take part in an exchange programme as part of your course or withdraw from a course with us a start with another provider);
- current or potential employers (to provide references and, where students are sponsored by their employer and/or where you take part in a placement, to provide details of progress/attendance);
- professional and regulatory bodies (e.g. Nursing and Midwifery Council, Health Care and Professions Council, British Psychological Society, Solicitors
Regulation Authority, Bar Standards Board, Association of Chartered Certified Accountants) in relation to the confirmation of qualifications, professional registration and conduct and the accreditation of courses;
- government departments and agencies where we have a statutory obligation to provide information (e.g. the Higher Education Funding Council for England (HEFCE), the Higher Education Statistics Agency (HESA), the Home Office (in connection with UK visas and immigration), Council Tax and Electoral Registration Officers at relevant local authorities (for the purpose of assessing liability for Council Tax and for electoral registration purposes)); • where applicable, PROCAT International team (so they can contact you to offer a pre-sessional or preparatory course relevant to your application to us);
- crime prevention or detection agencies (e.g. the police, the Department for Work and Pensions and Trading Standards);
- parents, guardians, and next-of-kin (where there is a legitimate reason for disclosure);
- third parties conducting surveys, for example the National Student Survey.
Visitors to our website
When someone visits PROCAT we collect standard internet log information and visitor details of behaviour patterns. We do this to find out things such as the number of visitors to the different parts of the site. We collect the information in a way which does not identify anyone. If we do want to collect personally identifiable information through our website we will be up front about this and will make the purpose clear.
A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website.
Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit. All cookies used by this website are used in accordance with the current Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
Controlling Information About You
When you fill in a form or provide your details on our website, you may see one or more tick boxes allowing you to:
- opt in to receive marketing communications from us by e-mail, telephone, text message or post
- opt in to receive marketing from our sponsors, third party partners by e-mail telephone, text message or post.
If you have agreed that we can use your information for marketing purposes, you can change your mind easily, via one of these methods:
- send an e-mail
- write to us
We will not lease, distribute or sell your personal information to third parties unless we have your permission or the law requires us to.
Links From Our Site
People who use our services
We hold the details you provide us with in order to deliver programmes of study, Apprenticeships, workforce development programmes and other services which meet your specific needs.
We only use these details to provide the service you have requested and for other closely related purposes. For example, we might use information about people who have enquired about a course to carry out a survey to find out if they are happy with the level of service they have received or we might use information about an employer offering a student work experience to contact them about a new Apprenticeship scheme or grant.
You are able to request that we stop contacting you at any time.
Information may by necessity be disclosed to appropriate staff members of PROCAT and to government bodies (to fulfil our statutory responsibilities) such as the Skills Funding Agency, the Education Funding Agency, Ofsted, the Department for Education and auditors or to local partners. If, as part of the entry requirements for your course, we need to take up a reference or obtain ‘disclosure’ from the Disclosure and Barring Service, we will inform you beforehand.
Any personal information we hold about you is processed in accordance with the General Data Protection Regulation.
People who use our commercial services
If you are a customer of a commercial service of the College e.g. Hair and Beauty salons the information you provide us with to enable us to deliver that service will only be held and used for that purpose or for other closely related purposes e.g. we might use information about people who use the Hair Salons to send out offers about the Beauty Therapy Services.
People who request information from us
If you request information from us by letter, telephone, email, submitting an enquiry on the website or from a sales appointment, we will make a record of that enquiry and will use the information you give us to provide you with a response. We will only use the information for these purposes and to provide a follow up service to ensure that we provided you with what you asked for.
You are able to request that we stop contacting you at any time.
Any emails sent to us, including attachments, may be monitored. Please be aware that you have a responsibility to ensure that any email you send us is in the bounds of the law.
International data transfers
Some of the personal data we process about you will be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), for example where it is processed by staff operating outside the EEA who work for us or for one of our suppliers, or where personal data is processed by one of our suppliers who is based outside the EEA or who uses storage facilities outside the EEA.
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 (e.g. where we have your explicit consent).
We share some of the information we hold about you (including your name, date of birth, nationality, student email address and programme of study) with the Students' Union at PROCAT unless you notify us that you wish to opt out of student union membership.
The Student Union use this information to administer membership of the Students' Union. The Student Union may also send some of the student data we provide to the National Union of Students ("NUS") .
The Student Union and the NUS will give students the chance to opt out of various categories of processing when they register with the Student Union
We will send some of the student information we hold to the Higher Education Statistics Agency ("HESA"). HESA collects and is responsible for the database in which HESA student records are stored. Details of how HESA will process this information can be found at: https://www.hesa.ac.uk/about/regulation/dataprotection/notices.
National Student Survey and Leaver Surveys
We may pass student contact details to survey contractors to carry out the National
Student Survey and surveys of student finances for the organisations identified by HESA in their data protection notices referred to above. These organisations and their contractors will use student’s details only for this purpose, and will then delete them.
About six months after graduation, we will contact each student to ask him or her to fill in the HESA “Destination of Leavers from HE” questionnaire. Students may also be contacted as part of an audit to check that we have undertaken this survey properly. We will not give your contact details to HESA.
Students may also be included in surveys that track the progress of leavers in the years after they graduate. If so, we will pass your contact details to the organisation that has been contracted to carry out that survey. The organisation will use your details only for that purpose and will then delete them.
If you do not want to take part in any of these surveys, please let us know.
Changes to your personal data
Please tell us promptly about any changes to the information we hold about you. This is particularly important for your contact details. Students can change your name, address, email address and contact number through ProPortal.
How long your information is kept
Subject to any other notices that we may provide to you, we may retain your personal data for a period of six years after your association with us has come to an end. However, some information may be retained indefinitely by us in order to maintain your academic record for archiving purposes (or by the Marketing team for the purposes of supporting your lifelong relationship with PROCAT).
Under the DPA you have the following rights:
- to obtain access to, and copies of, the personal data that we hold about you;
- 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.
Once the GDPR comes into force in May 2018, you will also have the following additional rights:
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us to erase your personal data;
- to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- 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 you transmitting that personal data to another data controller;
- to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
To make a request for a copy of the data we hold on you please contact us.
PROCAT accepts the following forms of ID when information on your personal data is requested:-
Passport, Driving licence, birth certificate, utility bill (from the last 3 months)
Complaints or Queries
If you have any questions about our collection and use of personal data please contact us. We are happy to provide additional information if it is required.
Changes to This Privacy Notice
We will keep this Privacy Notice under regular review and reserve the right to change it as necessary from time-to-time or if required by law. Any changes will be immediately posted on the website.