Data and Privacy Policy
Introduction
Ignite Your Inner Potential Ltd (The Company) holds and processes a wide range of information about its students, prospective students and other persons who may be interested in its services.
This privacy notice applies to all The Company’s operations in the UK, US, and other global locations where we organise courses or promote services. The notice explains the type of information that we process, why we are processing it and how that processing may affect you.
The privacy notice is split into the sections listed below. The Glossary section explains what we mean by “personal data”, “processing”, and other terms used in this notice.
We may update this privacy notice from time to time, and will post any revised notice on this webpage. Where appropriate we may notify you by email or by a notice on our website that our privacy notice has changed but we recommend that you check this page regularly. Any changes will be immediately effective on posting.
Contents
Who we are
How and when do we collect your personal data?
What personal data do we process and why?
Who gets to see your personal data?
Is your personal data transferred out of the EEA?
How long do we keep your personal data?
What steps do we take to keep your personal data secure?
Third party websites
Access to your data and other rights
Contact Information
Complaints
Glossary
Who we are
Ignite Your Inner Potential Ltd of 20 – 22 Wenlock Road, Hoxton, London. N1 7GU
Company Number 11033545
How and when we collect your personal data
Collection directly from you in response to our request
Most of the personal data we process about you comes directly from you (whether face to face, over the telephone, on a paper form, by email or online) for example:
- when you apply for or enrol on one of our courses;
•when you call us, email us or meet with one of our staff;
• when you sign up on one of the company websites, or third party website providers, or while attending an event or student recruitment fair, to receive news about upcoming courses and events relating to particular areas of interest
Automatic collection when you call us, visit our premises or our website, or take one of our online courses
Your image may be collected by The Company if you attend our premises. We may use CCTV at our premises for the protection of our staff, our students, and our visitors, or there may be CCTV at third party locations.
We also sometimes video or record our lectures or other events, and may make these videos and recordings available through Facebook live, but we will inform you on arrival at the lecture or event if we intend to do this. If you have enrolled on one of our online courses, we also collect certain data about your progress through the course, such as which modules you have completed, the results of any test.
We collect data about your computer when you visit our website which includes your internet address, your operating system and browser type. We use this information for our internal system administration, to help diagnose problems with our servers, to administer our website and monitor and improve the user experience.
We also collect data about you through cookies. A cookie is a simple text file that is stored on your computer or mobile device by our website’s server which allows our website to remember your preferences or transactions that are in progress. You can see more detail on cookies by clicking on Cookie Settings.
Collection of data from other sources
We may also obtain information about you from other sources, for example when we verify your academic qualifications with a prior educational institution, when we seek information about the equivalence of your academic qualification from World Education Services or your language ability from Educational Testing Services, when we obtain references from a previous employer or letters of recommendation.
What personal data do we process and why?
We have set out below the types of personal data that we process, the purposes for which we use it and the legal grounds on which we process it. The Glossary contains more information about the legal grounds for processing.
Purpose |
Examples of personal data (please note that the list is not exhaustive)
|
Legal grounds for processing |
To provide you with requested services (for example assessing eligibility for a course and/or scholarship, enrolling you on a course, assessing fitness to study, delivering teaching to you)
|
· name, title, and contact details (including email address, postal address, telephone numbers) · your bank account details, payment card details, bank transfer receipt · your prior academic achievements and qualifications · ·nature of the services including contractual terms · progress in your studies with us (attendance, coursework, interim grades and awards, online module completion status) and final outcome · details of disabilities and health conditions · records of your communications with us · any information relating to complaints or academic and other misconduct
|
Performance of a contract
|
To evidence our compliance with legal requirements, (for example, verifying your identity, monitoring for the purposes of equal opportunities) |
· your date of birth, identification documents (including photo) and the results of identification verification checks · details of your visa or other evidence of your right to study and ability to financially support yourself · information on race, ethnicity, religion/belief, and/or disability/ immunisation records or other characteristics that must be monitored and/or reported to a regulator · any requirements relating to the Company’s obligation to make reasonable adjustments to accommodate a disability or otherwise meet your specific needs · any information relating to a dispute or legal proceeding
|
Compliance with a legal obligation |
To keep you, our staff, and property on our premises secure |
· CCTV images
|
Legitimate Interests
|
To provide you with details about upcoming courses and events
|
· your name, email address and/or postal address · your marketing and communication preferences and/or or any hard copy or digital sign up |
Legitimate Interests (for past students)
Consent (for individuals who have signed up online, at an event, by talking to a member of staff) |
To monitor the performance of our website and online course platform and make your user experience better |
· your internet address · your browser type and operating system · the resources you access on our website · the data obtained from cookies, web logs and other similar technologies that monitor the use of our online course platform or website and/or deliver more appropriate advertisements on or beyond our website
|
Legitimate Interests |
To monitor your use of our services, train our staff and improve your student or website experience |
· your complaints, opinions, responses to our surveys or market research
|
Legitimate Interests |
Who gets to see your personal data?
Your personal data will be processed by The Company entity that initially receives it (see Who we are), and may also be transferred to and processed by other The Company locations. The Company uses EU Commission approved standard contractual clauses to regulate the transfer and processing of data between group companies.
Outside The Company
We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes. We only transfer your personal data to other organisations where it is necessary to enable us to provide you with the services you have requested (for example: we may transfer your data to our bank, payment card acquirers, library service providers, travel agents, transport and accommodation companies in relation to trips forming part of your course, course venues, caterers, institutions who evaluate the equivalence of your existing overseas qualifications, and direct marketing fulfilment and distribution). We also transfer your data to any organisations that validate our course provision and award your qualification. Where we do so it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services. Some of these organisations may be located outside the EEA and you should refer to the section Is your personal data transferred out of the EEA? for more information.
How long will we keep your personal data?
We will retain your personal data for as long as is necessary to provide the relevant services, maintain business records or educational records to satisfy tax, legal and other regulatory requirements, and protect and defend against potential legal claims.
What steps do we take to keep your personal data secure?
We will take all reasonable and appropriate steps to protect the security and integrity of all personal information provided via our website, or by any other means electronic or otherwise.
We use a variety of security technologies and procedures to help protect your personal details from unauthorised physical and electronic access.
As effective as modern security practices are, we cannot guarantee the complete security of personal data held in our systems, nor that that information you supply through the internet or any computer network is entirely safe from unauthorised intrusion, access or manipulation during transmission. Any transmission is at your own risk. We will not be liable for any resulting misuse of your personal data.
Third party websites
The Company’s websites may contain links to other websites not operated by The Company. The information you provide to us will not be transmitted to other websites, unless we clearly say so, but these other websites may collect personal information about you in accordance with their own privacy notice. The Company cannot accept any responsibility for the privacy practices or content of those websites.
Access to your data and other rights
We try to be as open as we can about the data that we process and recommend you ask us if you have questions about the data we hold on you.
EU residents
If you are a resident of the EU, you have the legal right to make a “subject access request”. If you exercise this right and we process personal data about you by automated means or as part of a Filing System, we are required to provide you with a description and copy of that personal data, and tell you why we are processing it.
As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing, or have its processing restricted.
If you have provided us with data about yourself and the grounds for processing is Contract or Consent (see What personal data do we process and why?), you have the right to be given the data in machine readable format for transmitting to another data controller.
If we are relying on Consent as the grounds for processing your data (see what personal data do we process and why?), you may withdraw consent at any time. This will not affect the lawfulness of Christie’s processing of your data prior to your withdrawal.
Please contact us at [email protected] you would like to exercise any of your rights explained above in relation to your personal data.
Complaints
If you have any complaints relating to the processing of your personal data, please contact us at [email protected].
Glossary
Compliance with a legal obligation - processing is necessary to ensure we comply with our legal and regulatory obligations.
Consent – you have given specific consent to the processing of your personal data.
Data Controller – the person who determines the purposes and means of processing personal data.
Directory Information –a student’s name, address, email address, telephone number, date of birth, enrolment status (full/part time), field of study, dates of attendance, degree and date of graduation (including anticipated graduation date), awards received, previous institutions attended.
EEA – the European Economic Area which comprises countries that are members of the European Union and Norway, Iceland and Liechtenstein.
Filing System – a structured set of personal data that is accessible according to specific criteria.
Legitimate Interests - processing is necessary for our or a third party’s legitimate interests in carrying on, managing and administering our respective businesses effectively and properly (except where our or the third party’s interests are overridden by your own interests, rights and freedoms).
Performance of a contract – processing is necessary to carry out our contractual duties, exercise our contractual rights or otherwise perform our contract with you, or to take steps at your request to enter a contract.
Personal Data - any data relating to an identified or identifiable natural person. This can include names, user ID, location data, email addresses, photographs, job applications, purchase history, user account information, opinions, and correspondence to and from an individual.
Processing - any operation performed on personal data, such as collection, recording, storage, retrieval, use, combining it with other data, transmission, disclosure or deletion.
Public Interest – processing is necessary for the performance of a task carried out in the public interest.