University of Essex Online is committed to maintaining the privacy and security of your personal data. This Privacy Policy explains how we collect, use, share and protect your personal data.

It is important that you read this Privacy Policy so that you are aware of how and why we are using your personal data.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below:

1. Who we are

University of Essex Online is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Where we act as a data controller, we are required under data protection legislation to notify anyone who provides personal data to us, either directly or through a third party, of the information contained in this Privacy Policy.

University of Essex Online is a trading name for Kaplan Open Learning (Essex) Limited (company number 06245017 and registered address at Palace House, 3 Cathedral Street, London, SE1 9DE) which is a company in the Kaplan International Pathways group. Within this Privacy Policy when we mention University of Essex Online (which can also be referred to as “we”, “us” or “our” in this Privacy Policy), we are referring to Kaplan Open Learning (Essex) Limited.

2. Data Protection Officer

Kaplan International Pathways has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details:

Our contact details

Email address: enquiries@online.essex.ac.uk
Postal address: Kaplan Open Learning (Essex) Ltd, Palace House, 3 Cathedral Street, London, SE1 9DE.

We will then refer your request to the DPO. Alternatively, you may contact the DPO directly using the following details:

DPO contact details

Name of DPO: Rachael Convery
Email address: dpo@kaplaninternational.com
Postal address: Palace House, 3 Cathedral Street, London, SE1 9DE.

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 would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you are an EU national or resident in an EU country, and wish to contact our EU Representative: Kaplan Ireland Education Limited, 13/14 Aungier Street, Dublin 2, D02 WC04 Ireland.

If you are a UK national or resident in the UK, and wish to contact our UK Representative: Kaplan UK Limited, UK Data Protection Representative, Palace House, 3 Cathedral St, London SE1 9DE, England.

3. What is personal data?

Personal data is any information about an individual from which that individual can be identified. Your name, address, phone number and bank account number are examples of personal data. It does not include data where the identity has been removed (anonymous data).

4. Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

• used lawfully, fairly and in a transparent way
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
• relevant to the purposes we have told you about and limited only to those purposes
• accurate and kept up to date
• kept only as long as necessary for the purposes we have told you about
• kept securely

5. 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:

• where we need to perform a contract we have entered into with you
• where we need to comply with a legal obligation
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

We may also use your personal data in the following situations, which are likely to be less common:

• where we need to protect your vital interests (or someone else’s interests)
• where it is needed in the public interest or for official purposes

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. You have the right to withdraw consent to marketing at any time by contacting us.

6. The personal data we collect from you

Enquiries

When you request information or make enquiries about any of our services, courses or modules, we may use the personal data you provide in order to fulfil your request or respond to your enquiry. We may email you or contact you regarding educational services by telephone utilising automated technology at the telephone number(s) you provided. It is in our legitimate interests to use your personal data in this way so that you receive the information you have requested.

You may give us information about you by applying or enrolling on one of our courses, on our site http://online.essex.ac.uk, completing a form, downloading a prospectus, by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.

Applications

If you make an application to study one of our courses or modules we may collect the following categories of personal data about you:

• personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• date of birth
• gender
• nationality and country of residence
• photo ID (e.g. your passport, driving licence or government ID)
• visa information and immigration status
• education history
• employment history
• funding information

It is in our legitimate interests to collect and use the above information in order to consider and process your application.

As part of our application process, we are obliged to ask for the following information on behalf of Jisc. Jisc is the body responsible for collecting and disseminating information about higher education in the UK and the designated data body for England. You can choose whether to provide this information to us or not.

• gender
• religion
• sexual orientation
• disabilities
• ethnic origin
• gender orientation

Study

If we enter into a contract with you relating to study, we may collect additional personal data relating to you including:

• bank account details
• billing address
• credit card or other payment information in order to process your payments.

This information, together with the personal data provided to us above at application stage, will be used by us to perform the contract we have entered into with you.

We may also collect further personal data relating to your visa application and immigration status as we have a legal obligation to use this information.

During your studies we will collect information about your academic experience and progression. This is in order to fulfil our contract with you but it is also in our legitimate interests to use this personal data in order to monitor the provision of our service to you.

We may also collect personal data about your health in order to make appropriate arrangements and reasonable adjustments for you regarding your welfare or participation in your studies. We use this information in order to perform our contract with you but it also may be in your vital interests for us to do so.

If you use an agent to arrange your application and study with us, we may collect the categories of personal data described above from your agent.

Marketing

Where you have explicitly consented to do so, we may use your personal data to inform you of special offers and new or existing services or courses we offer that are similar to those that you have already purchased or enquired about. This may also include surveys or questionnaires so that we can learn more about your needs and interests.

From time to time we may use your personal data to offer you the opportunity to participate in contests, sweepstakes and other promotions. When you enter you should carefully review any rules, as they may contain additional information about our use of your personal data.

If you would prefer that we do not send such communications to you, please follow the opt-out links on any marketing message, or change your settings on the social media platform, or contact us using the contact details in this Privacy Policy. If you prefer that all your details provided are removed from our database, please contact us using the contact details in this Privacy Policy.

Please also see the section entitled “Your rights as a data subject” in this Privacy Policy.

Automated technologies or interactions

As you interact with our website or learning platform, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the cookie policy on our learning platform website and the cookie policy on our website for further details.

Our website and learning platform

With regard to each of your visits to our website and learning platform we may automatically collect the following information:

• technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time);
• pages you viewed or searched for;
• page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you and assist you in participating in interactive features of our service and track your progress on one of our courses;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Internal business purposes

We also may use your personal data for our internal business purposes.  This is in our legitimate interests in order to operate as a business and monitor and improve the services we provide.  Where possible we will anonymise this information.  Please contact us using the contact details in this Privacy Policy if you would like more information.

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.

Parents and guardians

We collect personal data as described above. However if you are under 16 years of age and want to request information, download a prospectus, apply or enrol on one of our courses or contact us, you must ask your parent or guardian for permission. Our courses are not available to anyone under the age of 18.

7. When and how we share your personal data with others

We may share your personal data with third parties where required by law, where it is necessary to perform our contract with you or where we have a legitimate interest in doing so. Such third parties may include the following: