Policy

This policy applies to all members of London Graduate College (LGC) including students, who could be from different countries. For the purposes of this policy, the term “Staff” means all members of College staff including permanent, fixed term, and temporary staff, governors, any third-party representatives, agency workers, volunteers, interns, agents and sponsors engaged with the College.

This policy applies to all personal and sensitive personal data processed on computers and stored in manual (paper based) files. It aims to protect and promote the rights of individuals and the College.

Personal Data

This is any information which relates to a living individual who can be identified from the information. Examples of personal data:

·        A person’s name and address (postal and email)

·        Date of birth

·        Any expression or opinion communicated about an individual

·        Minutes of meetings, reports

·        Emails, file notes, handwritten notes, sticky notes

·        Employment and student applications

·        Spreadsheets and/or databases with any list of people set up by code or student/staff number

·        Employment or education history

Sensitive Personal Data

Any information relating to an individual’s:

·        Ethnicity

·        Gender

·        Religious or other beliefs

·        Political opinions

·        Membership of a trade union

·        Sexual orientation

·        Medical history

·        Offences committed or alleged to have been committed by that individual

Definition

The Data Protection Act 1998 is designed to protect individuals and personal data, which is held and processed on their behalf.  The Act defines the individual as the ‘data subject’ and their personal information as ‘data’.  These are further defined as:

·        Data Subject: Any living individual who is the subject of personal data whether in a personal or business capacity

·        Data: Any personal information which relates to a living individual who can be identified. This includes any expression of opinion about the individual.

Data is information stored electronically i.e. on computer, including word processing documents, emails, computer records, CCTV images, microfilmed documents, backed up files or databases, faxes and information recorded on telephone logging systems.

Manual records are files which are structured, accessible and form part of a ‘relevant filing systems’ (filed by subject, reference, dividers or content), where individuals can be identified and personal data easily accessed without the need to trawl through a file.

General Principles

The Data Protection Act 1998 and new GDBR 2018 sets legislative requirements for organisations processing personal data.  The College will be open and transparent when processing and using private and confidential information by ensuring we follow the 8 Data Protection Principles of good data handling:

Principle 1: Personal data shall be obtained and processed fairly and lawfully.

Principle 2: Personal data shall be obtained only for the specified and lawful purposes and shall be processed for limited purposes.

Principle 3: Personal data shall be adequate, relevant and not excessive in relation to the purpose for which it is obtained.

Principle 4: Personal data shall be accurate and kept up to date.

Principle 5: Personal data shall not be kept for longer than necessary.

Principle 6: Personal data shall be processed in accordance with the rights of the data subject under the Data Protection Act 1998.

Principle 7: Personal data (manual and electronic) must be kept secure.

Principle 8: Personal data shall not be transferred outside the European Union unless that country provides adequate levels of protection for the rights of the data subject.

The College recognises and understands the consequences of failure to comply with the requirements of the Data Protection Act 1998 may result in:

·        Criminal and civil action;

·        Fines and damages;

·        Personal accountability and liability;

·        Suspension/withdrawal of the right to process personal at by the Information Commissioners Office (ICO);

·        Loss of confidence in the integrity of the College’s systems and procedures;

·        Irreparable damage to the College’s reputation.

Roles and Responsibilities

Staff will not attempt to gain access to information that is not necessary to hold, know or process.  All information which is held will be relevant and accurate for the purpose for which it is required. The information will not be kept for longer than is necessary and will be kept secure at all times. The College will ensure that all personal or sensitive personal information is anonymous as part of any evaluation of assets and liability assessments except as required by law. Staff who manage and process personal or sensitive personal information will ensure that it is kept secure and where necessary confidential. Sensitive personal information will only be processed fairly and lawfully and in line with the provisions set out in the Data Protection Act 1998 and only processed in accordance with instructions set out by the respective Data Controllers. The College will ensure that all staff are made aware of the reasons why personal and sensitive personal data is being processed.

Data Subjects Rights

The College acknowledges individuals’ rights under the Data Protection Act to access any personal data held on our systems and in our files upon their request, or to delete and/or correct this information if it is proven to be inaccurate, excessive or out of date. The College recognises that individuals have the right to make a request in writing to obtain a copy of their personal information, if held on our systems and files. The College recognises that individuals have the right to prevent data processing where it is causing them damage or distress, or to opt out of automated decision making and stop direct marketing.

College Obligations

The College will follow Code of Practice issued by the ICO when developing policies and procedure in relation to data protection. The College will ensure that Data Processing Agreements are applied to all contracts and management agreements where the College is the data controller contracting out services and processing of personal data to third parties (data processors).  The College will ensure this agreement clearly outlines the roles and responsibilities of both the data controller and the data processor. The College will adhere to and follow the 8 principles of data protection when conducting surveys, marketing activities etc., where the College collects, processes, stores and records all types of personal data. The College will not transfer or share personal information with countries outside of the United Kingdom unless that country has a recognised adequate level of protection in place in line with the recommendations outlined in the Data Protection Act.

Complaints

Complaints relating to breaches of the Data Protection Act 1998 and/or complaints that an individual’s personal information is not being processed in line with the 8 principles of data protection will be managed and processed by the Administrator.  All complaints of dissatisfaction will also be processed in accordance with the College’s Complaints Process.

Confidentiality and Information Sharing

The College will only share information in accordance with the provisions set out in the Data Protection Act 1998. Where applicable the College will inform individuals of the identity of third parties to whom we may share, disclose or be required to pass on information to, whilst accounting for any exemptions which may apply under the Data Protection Act 1998.

Privacy Notice

We are committed to safeguarding the confidentiality of information provided by all employers, students, and users of our website in compliance with legislation and regulation in force at the moment and in the future. We shall be open and transparent in all our dealings regarding the use of data and act in accordance with all codes of practice.

1)    What information will we collect and store both computerized and manual?

Similar information will be collected for both staff and students as follows:

Name:

Address:

Telephone No:

Date of birth:

Sex:

Nationality:

Disabilities (if any):

Ethnic Origin:

Educational qualification:

Work experience:

References:

Next of kin:

Visa status:

Passport No:

2)    How will we use your personal data?

The personal data that we collect from you will only be used in the necessary running of the college. In relation to employees we need to provide various government authorities with details about you e.g. HMRC. In relation to students we may need to provide details to eg HEFC, awarding bodies local authorities and the Home Office. We shall not sell/give your data to third parties for marketing purposes without your consent. We would only disclose information on you if required to do so legally. We will only retain your data as long as is necessary either for legal reasons or the requirements of official bodies. However, the cvs of unsuccessful applicants or students will only be kept for 9 months.

3)    How will we secure your data?

Some data will be held in metal/ wooden cabinets which will be locked when unattended and held in secured offices. Personal data held on computerized systems will be protected by firewalls anti-virus software and passwords which are regularly changed. The college will keep back up files securely held in the event of corruption of data on computerized systems. All staff with access to your required data will receive training in their legal responsibilities to safeguard your data. In the event of a data breach that is likely to harm by putting your personal data at risk we would notify the ICO within 72 hours of becoming aware of it. We would also notify individuals if they had been put at high risk.

4)    How long will your data be held?

Your data will only be held as long as is necessary either for statutory requirements or for your benefit e.g. so request for references can be provided. We will review on a regular basis our data requirements.

5)    Cookie policy

We do not collect cookies.

6)    What rights do you have regarding data held by London Graduate College (LGC)?

You entitled to request to see information that we hold about you within a month of asking for it. We will not charge you for providing this.

7)    Who should I contact If I have question about this privacy policy and data protection?

Registrar

London Graduate College (LGC)

Suite 6, The Generator Business Centre

95 Miles Road, Mitcham, Surrey

United Kingdom, CR4 3FH

Email: info@lgc.ac  

Phone: +442084081546