Privacy & Data Protection

Privacy Policy

We take your privacy seriously. This Privacy Policy, explains how University College Isle of Man (UCM) (“We”) collect, use and process your personal data, as well as ensure information about you is kept confidential. Any information you are asked to provide using this website will only be used in the ways described in this privacy policy.

Please read it carefully, as by using the pages of the UCM, or our services, you will be deemed to have read and accepted its terms.

This website privacy policy was updated on: 15/06/2020

Definitions

“UCM” means University College Isle of Man.

“UCM Form(s)” means any enquiry or application that this Privacy Policy applies to.

Introduction

The UCM and UCM Forms, including all information and materials contained on them are managed by the Senior Leadership Team and Principal at UCM. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using the UCM and/or filling out a UCM Form, you are accepting and consenting to the practices described in this policy. If you do not agree to these terms of use, you must not use our site. 

For the purpose of the General Data Protection Regulation (GDPR) 2018 (the Act), the data controller is University College Isle of Man c/o Homefield Road, Douglas. Isle of Man. IM2 6RB. British Isles email: mail@ucm.ac.im

The Data Protection Officer for UCM and the Department of Education, Sports and Culture is the Legal and Administration Manager, who can be contacted at the Department of Education, Sport and Culture, Hamilton House, Peel Road, Douglas.  Isle of Man.  IM1 5EZ 

Accessing our site

Our site is made available free of charge. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. Access to our site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of our site without notice. We will not be liable to you if for any reason our site is unavailable at any time or for any period. You are responsible for making all arrangements necessary for you to have access to our site. You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

University College Isle of Man Data Privacy Policy

In compliance with the Isle of Man General Data Protection Regulations GDPR (as prescribed in legislation) which is consistent with that for the UK and Europe, this privacy policy explains what personal information we collect from you when you visit our website, when you apply to, or join us as a student or are a recipient of our services.

University College, UCM, is a college for higher and further education and we are committed to processing all personal information about our students, staff or visitors in ways that comply with the College’s legal and regulatory obligations, and to being clear about what it does with personal information.

Data collection

The data we collect to provide our services, we take as a data controller.  This means that we are responsible for deciding how we hold and use personal information about you.  We are required under data protection legislation to notify you of the information contained in this privacy notice.

We may collect personal information when:
•           you use our website
•           you apply to or enroll with the college as a student
••         you are a recipient of other training or events we provide.
•           you use our commercial services such as room hire, salons or commercial restaurant.

We may collect the following types of information:
•           Name, Address, Email, Phone/mobile, DOB
•           Previous school, Course fees
•           Parent name / email, Emergency contact (name/relationship/email/mobile/landlines)
•           Car registration
•           Nationality
•           Qualifications
•           Referee details (name/address/phone/email)
•           Employment status / details
•           CCTV footage
•           Information obtained through electronic means such as swipe card records.
•           Information about your use of our information and communications systems
•           Photographs

Special Categories of data

We also collect special category data, necessary for legal requirements and reporting but also to help us provide you with the most effective education and to keep you safe whilst in the College.

Special categories of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information and we do this with either your consent or as permitted by the Isle of Man data protection legislation

The special category information we collect includes:
•           Learning difficulty/disabilities
•           Ethnicity
•           Religion
•           Sexual Orientation
•           Disability & learning support,
•           Household status
•           Details of any Criminal convictions

Why do we collect this information? 

The personal data collected is needed in order to
•           provide you with higher and further education; 
•           to give our staff information necessary to facilitate your learning;
•           for necessary funding and administrative purposes;
•           to meet our legal and regulatory obligations as a college;
•           promote the college to prospective students or clients

Information we may collect through our website is needed
•           to help identify your computer;
•           analyse data about web page traffic and to help us tailor our website for your needs; 
•           to allow students, staff and guests to access information they may require.

We also collect personal contacts from our Business and Corporate clients for our legitimate interests.  Almost entirely, these contacts are corporate or business individuals and while this is still categorised under Isle of Man legislation as personal data we are aware that it can be used for business-to-business purposes.

How do we collect this information? 

We collect personal information:
•        directly from students:  e.g. when a student applies to join us, attends a promotional              pre enrolment event or at enrolment;
•        from publicly available sources: eg.  networking, social media, internet services, exhibitions, direct referrals, other Corporate bodies;
•        from guests or visitors 

We are committed to keeping your information up to date as far as is reasonably possible. However, if you believe that we have made an error, then please contact us as we have outlined below and we will use reasonable endeavors to correct your record. 

Website cookies

We also capture data using Cookies.  A cookie consists of a piece of text sent by a web server to a web browser, and is stored by the browser.  The information is then sent back to the server each time the browser requests a page from the server.  This enables the web server to identify and track the web browser. 

How do we use the data we collect?

The majority of our data is held within our student database, accessible only to those staff who need access.

Any processing activities we undertake are fully compliant with Isle of Man and UK data protection legislation

Information collected may be used for the following:

1.         On internal displays (including digital display) – to inform students of college related activities and news; 
2.         disciplinary/grievance procedures; 
3.         attendance monitoring; 
4.         correspondence to students relating programme of study; 
5.         distribution of examination/registration documents; 
6.         storage and usage of student image to create ID Cards and for identification purposes; 
7.         contact to students via text, e-mail or post using information collected on the enrolment/learning agreement; 
8.         the provision of advice and support to learners via, amongst others, Student Support & Inclusion; 
9.         registration with awarding bodies;
10.       we make use CCTV cameras throughout the College for security, crime prevention and safeguarding purposes, both for the public and vital interests of our visitors, staff and students 
11.       Safeguarding; 
12.       disclosing information where necessary, either with your consent or as required by law to:
•           Local Authority;  
•           sponsors/employers (where stated on the Learning Agreement) 
•           external work based training providers; 
•           professional and statutory bodies; 
•           Isle of Man Government agencies including the Police, if deemed necessary and within the confines of legislation.  In particular in relation to safeguarding of young people and vulnerable adults. 
•           funding agencies: 
13.       Disclosing information on your learning status including – attendance, awarding body entry and exam attendance, if you are a 16-18 year old student (at the start of your learning programme).  This data will only be disclosed to the next of kin(s) (i.e. parent/guardian) details you provided at enrolment.  If your next of kin/guardian details change during your time at the College, please contact UCM’s support team.
14.       Marketing purposes, such as to keep you informed of College activities and services which may interest you.

Keeping your information safe and secure. 

UCM is committed to keeping your personal information secure to protect it from being inappropriately or accidentally accessed, used, shared or destroyed, or lost.  

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal information on our instructions and they are subject to a duty of confidentiality

In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. 

We currently do not share any data outside the UK but should we need to transfer personal information to third parties located outside the UK, we will ensure that information is protected to a level which meets the requirements of the Isle of Man and UK data protection regulations
If we provide you with a login and password in order to access any of our systems, you are responsible for keeping your password and user details confidential and safe.  We will never ask you for your password, never disclose it to anyone.

Third party access

Access to your personal information is only allowed when required by law or is required in order to fulfil our service obligations.  We do not, and will never, sell or share your personal information with other third parties.

All our third-party service providers and other entities in the College are required to take appropriate security measures to protect your personal information in line with our policies. . 


Links to other websites: 

Our website and email newsletters and bulletins may contain links to other websites of interest. 

However, you should note that we do not have any control over these other websites. Once you have used any of these links to leave our site, therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites and such sites are not governed by this privacy statement.

How long do we keep personal information?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

•           For our students we are required by law to retain all the personal details we collect for as long as they remain a student and only certain personal details after they leave us in line with the UCM Retention Policy.
•           For anyone who enquires about joining the college but does not register we will hold these personal details for a maximum of two years

Details of retention periods for other aspects of your personal information are available in our retention policy which is available from the College Data Protection Officer (see contact details below)

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a student, worker or contractor of the College we will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations.

Marketing 

UCM undertake limited marketing activity and only necessary to promote the college to prospective students or sponsors. This is completed for our legitimate interests and will include:
•           E-Communications such as keep warm from application to enrolment, emails to event data where you have opted in
•           Social Platform activity, sharing information with Facebook, Instagram, Twitter and LinkedIn
•           Events to profile the college to new entrants or prospective new markets
Any marketing we undertake is made in a fully compliant manner as governed by Isle of Man data protection regulations with the contacts being given the option to opt out from such contact.

             

Controlling your personal information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

If you want to review, verify, correct or question anything detailed in this policy or anything about your personal information, please contact the Department Data Protection Officer in writing.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances to the extent permitted by law

Under certain circumstances, by law you have the right to:
•           request details of personal information which we hold about you
•           restrict the collection or use of your personal data
•           to withdraw any permission you have given us to use your data
•           or even to delete any records that we may hold; 

Data Protection Officer

UCM operates within the Department of Education, Sport and Culture who has an appointed Data Protection Officer (DPO) to oversee compliance with this Privacy Notice.  If you have any questions about this Privacy Notice or how we handle your personal information, please contact the DPO via the contact details below. 
You have the right to make a complaint at any time to the Information
Commissioner's Office (ICO); the Isle of Man supervisory authority for data protection issues.

Changes to our Privacy Policy: 

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.  We may also notify you in other ways from time to time about the processing of your personal information.
This privacy policy was last updated in September 2019.

 

Contact Details
Department of Education, Sport and Culture
Data Protection Officer:  Andrew Shipley
Department of Education Sport and Culture
Hamilton House
Peel Road
Douglas
IOM
IM1 5EP