Privacy Policy
LAST UPDATED: 27/02/2020
Who we are
Our website address is: https://online.sunderland.ac.uk.
Higher Ed Partners UK wants you to be familiar with how we collect, use and disclose information.
This Privacy Policy describes our practices in connection with information that we collect through websites operated by us, through email messages that we send to you, as well as offline interactions you may have with us.
Higher Ed Partners is a data processor, acting on behalf of the University of Sunderland, the data controller.
Personal Information
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
As data processor, Higher Ed Partners UK processes Personal Information including:
- Name
- Surname
- Middle Name
- Postal address
- Email address
- Telephone number
- Mobile number
- Nationality
- Country of residence
- Second Nationality
- Gender
- Date of birth
- IP Address
- Educational records and qualifications, including higher and further education institutions attended, dates of
attendance, degree programme titles, subjects and grades - Higher and further education transcripts and certificates
- Work history – including employer, job title, responsibilities, location and dates in role
- School type of data subject
- Confirmation of whether English is first language
- Membership of professional or industry associations
- Disability
Collection of Personal Information
We collect Personal Information in a variety of ways, including:
Online
- We collect Personal Information through our services, for example, when you submit your details on the request information form on our website online.Sunderland.ac.uk) or paid traffic landing pages, apply for admission via our online application form, or maintain an ongoing relationship with us as a student.
- From you during your course of study or period of enrolment with the University of Sunderland.
Offline
- We collect Personal Information from you offline, such as when you contact us by phone and provide information to one of our enrolment advisors.
- All our phone conversations are recorded for training and quality purposes.
We need to collect Personal Information in order to provide the requested services to you and in order to consider and maintain an academic relationship with you. If you do not provide the information requested, we may not be able to provide our services, consider you for admission, or maintain your status as an enrolled student. If you disclose any Personal Information relating to other people to us or to our service providers in connection with our services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Use of Personal Information
Higher Ed Partners UK uses Personal Information for the purposes of recruiting and enrolling students and providing students with student support. These uses include:
Providing the functionality of our services and fulfilling your requests.
- To provide our services’ functionality to you, such as arranging access to your registered account and providing you with related assistance,
- To respond to your inquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or complaints.
- To complete your transactions, and provide you with related assistance.
- To send administrative information to you, such as changes to our terms, conditions and policies.
- To allow you to send messages to another person if you choose to do so. We will engage in these activities to manage our recruitment, enrolment and student support processes. The legal basis we rely on for processing this Personal Information is consent under article 6(1)(a) of the GDPR.
Providing you marketing materials.
- To send you marketing related emails, WhatsApp and SMS messages with information about our services and other news about us.
We will engage in this activity with your explicit consent.
Analysis of Personal Information for business reporting and providing personalised services.
We use automated processes to carry out the following activities:
- To analyse or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our services.
- To better understand you, so that we can personalise our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymise Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for the purpose of sharing with third parties to improve targeting, personalisation and overall effectiveness of marketing activity.
- Accomplishing our business purposes.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new services;
- For enhancing, improving, or modifying our current services;
- For identifying usage trends, for example, understanding which parts of our services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to comply with a legal obligation, and/or because we have a legitimate interest.
Disclosure of Personal information
By disclosing any personal or sensitive personal information to us you give us consent to use this information for the purposes of online programme marketing and admissions.
We disclose Personal Information:
- To partnering institutions that receive services from the University of Sunderland.
- To our third-party service providers, to facilitate services they provide to us.
- These can include providers of services such as contact centre outsourcing, website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. Any third-party service providers that we disclose Personal Information to
will have entered into a fully GDPR-compliant data processing agreement with Higher Ed Partners UK and The University of Sunderland.
- These can include providers of services such as contact centre outsourcing, website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. Any third-party service providers that we disclose Personal Information to
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal
obligation or legitimate interest to do so:
- To comply with applicable law.
- This can include laws outside your country of residence.
- To respond to requests from public and government authorities.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
Security
We seek to use reasonable organisational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Choices and access
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving email marketing from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions contained in each such email or by contacting us at dataprotection@higheredpartners.co.uk
- Receiving other types of marketing communications from us regarding future start dates and other online courses provided by the University of Sunderland: If you no longer want to receive marketing-related communications from us on a going-forward basis, you may opt-out by contacting us at dataprotection@higheredpartners.co.uk
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or delete your Personal Information
If you would like to request to access, review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another organisation or that Higher Ed Partners transmit your Personal Information to another organisation on your behalf(to the extent this right to data portability is provided to you by applicable law), you may contact us using the “Contact Us” information below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a payment, you may not be able to change or delete the Personal Information provided until after the completion of such transaction).
Retention period
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you are a student of ours);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Use of services by minors
Our services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).
Jurisdiction and cross-border transfer
Your personal data is stored and processed in the UK.
It will also be processed outside the European Economic Area by our third-party service providers.
For example, our contact centre operated by our sister company, Higher Ed Partners Africa, is based in South Africa, outside the EEA.
Any international data transfers will take place in full compliance with the General Data Protection Regulation.
Updates to this privacy policy
The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.
Contacting Us
Higher Ed Partners Ltd., with its registered office at 31 Hill Street, London W1J 5LS is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us at dataprotection@higheredpartners.co.uk or by mailing Higher Ed Partners, 404 Queensberry House, 106 Queens Road, Brighton, East Sussex, BN1 3XF
Because email communications are not always secure, please do not send sensitive information in your emails to us.
Additional information for individuals in the EEA
If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.
For more information on our corporate policies and procedures please visit: https://www.sunderland.ac.uk/help/corporate-legal/publication-scheme/policies-and-procedures/