How We Use Your Information: Privacy Notice
West London College is committed to complying with the General Data Protection Regulation and the Data Protection Act 2018, once enacted. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised shopping experience.
We have published this notice to help you understand
- How and why West London College collect information from you;
- Who we share your information with, why and on what basis; and
- What your rights are.
If we make changes to this notice we will notify you by updating it on our website. West London College will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means West London College determines the purposes and way in which any personal data are, or will be, processed.
What is personal information?
Personal information is information that identifies you as an individual and relates to you.
This includes your contact details, next of kin and financial information. We may also hold information such as your religion or ethnic group. CCTV, photos and video recordings of you are also personal information.
Parents, carers and guardians
Under the GDPR (General Data Protection Regulation), young people aged 16 and over can decide for themselves and give consent for the processing of their personal information. Parental consent is not required. There may be exceptions in regards of students with severe learning difficulties, school link students and those who are otherwise unable to decide for themselves.
The College has found that it is very beneficial to the young person’s progress as a student if the College is able to engage with the parents (or guardian/carer). Therefore it is very important that we have the parents’ details recorded on our systems.
When a student is in Further Education, parents/carers/guardians (or any other third party) are not automatically entitled to the student’s information. We can only release information about our students if we have their consent for this recorded on the College system. Students are asked for their consent for sharing information with parents/others on the enrolment form or when enrolling face-to-face. Students can also inform the College later on of who the College may discuss with about their College matters. Students may withdraw their consent the same way which they gave it.
In general, we can only share information if we have the person’s consent, or there is a particular piece of legislation or agreement allowing us to share it without consent.
How and why does West London College collect and use personal information?
We set out below examples of the different ways in which we use personal information and where this personal information comes from. The College’s primary reason for using your personal information is to provide educational services to you.
- We obtain information about you from admissions forms and from your previous school, where appropriate. We may also get information from professionals such as local authorities.
- We may have information about any family circumstances which might affect your welfare or happiness.
- We may need information about any court orders or criminal petitions which relate to you. This is so that we can safeguard the welfare and wellbeing of yourself and other students and staff of the College.
- We use CCTV to make sure the College is safe. CCTV is not used in private areas such as toilets.
- We may take photographs or videos of you at College events to use on social media, publications and on the College’s website. This is to show prospective students what we do here and to advertise the College. We may continue to use these photographs and videos after you have left the College.
- We may send you information to keep you up to date with what is happening at the College. For example, by sending you information about events and activities taking place (including fundraising events) and the West London College Alumni newsletter.
- We may use information about you if we need this for historical research purposes or for statistical purposes.
- We will process financial information about you in relation to the payment of fees. In some cases we get information about you from third parties such as credit reference agencies.
Sharing personal information with third parties
- In accordance with our legal obligations, we may share information with local authorities and the Department for Education, for example, where we have any safeguarding concerns.
- On occasion, we may need to share information with the police.
- We may also need to share information with our legal advisers for the purpose of obtaining legal advice.
- Occasionally we may use consultants, experts and other advisors to assist the College in fulfilling its obligations and to help run the College properly. We might need to share your information with them if this is relevant to their work.
- We may share some information with our insurance company, for example, where there is a serious incident at the College.
- If you leaves us to attend another College we may need to provide that College with information about you. For example, details of family circumstances for safeguarding reasons.
Our legal grounds for using your information
This section contains information about the legal basis that we are relying on when handling your information.
Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:
- Contract - your personal information is processed in order to fulfil a contractual arrangement
- Consent – where you agree to us using your information in this way
- Legitimate Interests - this means the interests of the College in managing our business to allow us to provide you with the best service in the most secure and appropriate way
- Legal Obligation – where there is statutory or other legal requirement to share the information
This means that the processing is necessary for legitimate interests except where the processing is unfair to you. The College relies on legitimate interests for most of the ways in which it uses your information.
Specifically, the College has a legitimate interest in:
- Providing you with educational services;
- Safeguarding and promoting your welfare;
- Promoting the objects and interests of the College. This includes fundraising. It also includes making sure that we are able to enforce our rights against you, for example, so that we can contact you if unpaid fees are due;
- Facilitating the efficient operation of the College; and
- Ensuring that all relevant legal obligations of the College are complied with.
Necessary for a contract
We will need to use your information in order to perform our obligations under our contract with you. For example, we need your name and contact details so that we can update your progress and so that we can contact you (and/or your parents/guardians if appropriate) if there is a concern.
Where the College needs to use your information in order to comply with a legal obligation, for example to report a concern to Children's Services. We may also have to disclose your information to third parties such as the courts, the local authority or the police where legally obliged to do so.
For example, to prevent someone from being seriously harmed or killed.
The College considers that it is acting in the public interest when providing education.
The College must also comply with an additional condition where it processes special categories of personal information. These special categories are as follows: personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health information, and information about sex life or orientation.
Substantial public interest
The processing is necessary for reasons of substantial public interest.
To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.
Legal claims: The processing is necessary for the establishment, exercise or defence of legal claims. This allows us to share information with our legal advisors and insurers.
This includes medical treatment and the management of healthcare services.
Sending information to other countries
We may send your information to other countries where:
- we store information on computer servers based overseas; or
- we communicate with you when you are overseas (for example, during the summer holidays if you live in a different country).
The European Commission has produced a list of countries which have adequate data protection rules. The list can be found here: http://ec.europa.eu/justice/data-protection/internationaltransfers/adequacy/index_en.htm
If the country that we are sending your information to is not on the list or, is not a country within the EEA (which means the European Union, Liechtenstein, Norway and Iceland) then it might not have the same level of protection for personal information as there is the UK.
For how long do we keep your information?
We keep your information for as long as we need to in order to educate and look after you. We will keep some information after you have left the College, for example, so that we can find out what happened if you make a complaint.
In exceptional circumstances we may keep your information for a longer time than usual but we would only do so if we had a good reason and only if we are allowed to do so under data protection law.
We can keep information about you for a very long time or even indefinitely if we need this for historical, research or statistical purposes. For example, if we consider the information might be useful if someone wanted to write a book about the College.
What decisions can you make about your information?
From 25 May 2018 data protection legislation gives you a number of rights regarding your information. Some of these are new rights whilst others build on your existing rights. Your rights are as follows:
- if information is incorrect you can ask us to correct it;
- you can also ask what information we hold about you and be provided with a copy. We will also give you extra information, such as why we use this information about you, where it came from and what types of people we have sent it to;
- you can ask us to delete the information that we hold about you in certain circumstances. For example, where we no longer need the information;
- you can ask us to send you, or another organisation, certain types of information about you in a format that can be read by computer;
- our use of information about you may be restricted in some cases. For example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy;
The Data Protection Officer can give you more information about your data protection rights.
Further information and guidance
The Data Protection Officer is the person responsible at the College for managing how we look after personal information and deciding how it is shared.
Like other organisations we need to keep your information safe, up to date, only use it for what we said we would, destroy it when we no longer need it and most importantly - treat the information we get fairly.
This notice is to explain how we use your personal information. The Data Protection Officer can answer any questions which you may have.
Please speak to the Data Protection Officer if:
- you object to us using your information for marketing purposes e.g. to send you information about the College events. We will stop using your information for marketing purposes if you tell us not to; or
- you would like us to update the information we hold about you; or
- you would prefer that certain information is kept confidential.
- If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office - ico.org.uk.
You have the right to lodge a complaint with a data protection regulator in Europe. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk however, we encourage you to contact the College before making any complaint and we will seek to resolve any issues or concerns you may have.