NSPC and personal data
NSPC works very closely with Middlesex University both on our joint and validated programmes as all our students are studying towards the award of a Middlesex degree. Our privacy standards are therefore comparable to Middlesex University and this document is an adapted version of a document first produced by Middlesex University.
The following also applies to ‘staff’: contractors, including teachers, academic and non-academic staff and any other person who has a contract with NSPC or one of its sister organizations.
The General Data Protection Regulation (GDPR) protects the rights of individuals by setting out certain rules as to what organisations can and cannot do with information about people. A key element to this is the principle to process individuals’ data lawfully and fairly. In order to meet the fairness part of this we need to provide information on how we process personal data.
NSPC takes its obligations under the GDPR very seriously and will always ensure personal data is collected, handled, stored and shared in a secure manner.
The following statement will outline what personal data we collect, how we use it and who we share it with. It will also provide guidance on your individual rights and how to make a complaint to the Information Commissioner’s Office, the regulator for data protection in the UK.
NSPC’s official contact details are:
Data Protection Officer
Professor Digby Tantam
61-63 Fortune Green Road London NW6 1DR
Tel: +44 (0)20 7435 8067
Email: [email protected]
How does NSPC collect your personal data?
We primarily collect your personal data through the information you submit via our applications on the NSPC portal home page or other relevant recruitment processes.
We also ask for additional personal data during our enrolment process as we require additional information about you when you actually become a student at NSPC.
Some NSPC services also require you to provide your personal data in order for them to be able to deliver additional services. The data needed and the justification as to why will be provided to you at the point you access the service(s).
What personal data does NSPC collect?
NSPC collects personal data from staff or students at various stages. The volume and nature of the personal data collected is outlined below:
- Details from application forms:
- name and address
- contact details (telephone number, email address)
- age / date of birth
- nationality and country of residence
- educational records to date
- academic references (including personal statement and predictive grades)
- disability declaration
- criminal conviction declaration
- Further data collected at enrolment or updated during a student’s time at NSPC:
- Home address and next of kin
- Term-time address
- Entry and other qualifications
- Demographic information
- Next of kin (in the event of an accident or illness)
- Funding, bursary and fee related information
- Information needed to provide services in relation to disability, wellbeing or any other type of pastoral support
- Course and stage details
- Attendance, progress and current status
- Assessment results
- Photograph for identification badge
- For all students training to become coaches, psychotherapists, psychologists or pastoral carers, a DBS check and an occupational health check will be completed to allow a student to commence a placement
- Anonymous data collected for statutory monitoring and reporting purposes:
- Religious belief
- Parental occupation and education
- Sexual orientation
- Ethnic origin
- Data collected from international students on a Tier 4 (or similar) visa to meet UK Visa and Immigration requirements:
- passport details
- visa lifecycle details
- data to evidence attendance on course of study
Additional personal data may be collected by NSPC where relevant in relation to placements, professional body requirements, extenuating circumstances applications, appeals/complaints/disciplinary cases and any further optional student services.
How and why does NSPC use personal data?
The primary purposes we process information about current students include:
- to enable us to administer student-related functions from original applications through to graduation and to provide alumni services;
- to plan and account for the use of the services provided;
- to enable NSPC staff to communicate with staff or students;
- to monitor academic progress over the period of enrolment towards completion of a qualification;
- to carry out assessment, authorise award of qualifications and verification of awarded qualifications post-study;
- to administer staff or student related policies and procedures including appeals, complaints, academic misconduct and general conduct and discipline;
- to provide student support services, including financial, pastoral, sporting, employability and IT/learning resources;
- To issue communications on student benefits and opportunities and NSPC or Middlesex University activities or events organised for students;
- to comply with immigration compliance checks in relation to sponsored migrants;
- to monitor, develop and update NSPC systems to ensure they continue to operate effectively and securely;
- to monitor equality and diversity objectives within NSPC;
- To undertake surveys, market research and statistical analysis to improve the student experience. This is done both to assess your learning or staff experience but also your wider student experience at NSPC.
Finally, NSPC processes personal data as part of research activity that has to be consistent with the policies of, and approved by, the Research Ethics Committee.
Sharing of personal data
NSPC is required to share personal data with certain other organisations in order to meet statutory requirements or to provide services to students. Sharing will always be undertaken in line with the requirements of data protection law, using the relevant legal basis as defined by the GDPR and other data protection legislation. The personal data that is actually shared will always be limited precisely to what the other organisation needs to meet its requirements or deliver its services.
The information below outlines the key partners with whom the NSPC shares personal data with on a periodic basis:
- Middlesex University
- Professional and Funding Bodies:
- Validation of registrations and awards; and
- Approval of funding applications.
- Skills Funding Agency in order to make them aware who enrolled apprenticeships students are and subsequently the academic progress those students are making;
- UK Immigration agencies to ensure compliance with the conditions attached to student visas;
- the Student Loans Company in connection with grants, fees, loans and bursaries;
- The courts, the police and other organisations with a crime prevention, Prevent, or law enforcement function (subject to meeting the conditions of relevant legislation);
- The NHS for the purpose of coordinating student placement activity for nursing and midwifery students; and
- Local authorities for the purposes of assessing and collecting council tax.
- Other individuals / organisations:
- External examiners for examination, assessment and moderation purposes;
- International recruitment consultants, agents and Middlesex regional offices (for relevant international students);
- NSPC or Middlesex University’s insurers and legal advisers for the purpose of providing insurance cover or in the event of a claim;
- The Office Of The Independent Adjudicator to review student complaints;
- Employers who request a reference from NSPC (for relevant students).
- IPSOS-MORI and JISC online surveys for inclusion in the National Student Survey (NSS), Postgraduate Taught Experience Survey (PTES) and the Postgraduate Research Experience Survey (PRES).
- Xero.com, the providers of our accountancy program
- Little-fire.com the web developers who develop and maintain our databases
How long does NSPC keep personal data?
NSPC takes its obligations under the GDPR seriously in terms of not holding onto personal data for any longer than is necessary. NSPC has a retention schedule in place for[DT1] the different categories of data it holds.
In some cases, there are good reasons as to why NSPC needs to retain data about students for a significant period of time. The most important reasons are outlined below:
- in order that student awards can be verified in the long-term;
- to produce transcripts and references;
- to maintain staff records for employment, welfare, or disciplinary purposes;
- for alumni services and ongoing relations with NSPC;
- for careers and employability services;
- to deal with complaints, appeals and disciplinary cases;
- for statutory reporting purposes and in order to complete statutory surveys such as the Destination of Leavers from Higher Education Surveys and Graduate Outcomes;
- Your rights
- In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
- Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
- You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting your profile pages when logged into the website.
- You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
- In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
- In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
- You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
- You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
- To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section.
To exercise any of the above rights please get in contact with NSPC’s Data Protection Officer using the contact details provided at the start of this notice.
You also have the right to complain to the UK Regulator the Information Commissioner’s Office (ICO) if you believe your request has not been dealt with properly or you have a complaint to raise against NSPC for any other data protection related issue..
You also have the right to withdraw consent from the processing of your personal data by NSPC at any time, if your consent was sought initially to use your personal data.
All staff or students who handle personal information for which NSPC is responsible for must follow the requirements of the Data Protection Policy and other relevant guidance issued by NSPC or Middlesex University.