Privacy Policy
The Russian Language Centre is committed to protecting the privacy and security of your personal information (‘personal data’).
This privacy policy describes how we collect and use your personal data during and after your studies with us, in accordance with the General Data Protection Regulation (GDPR) and related UK data protection legislation.
It applies to all individuals who have or have had a contract for study. It is important that you read this policy, together with any other privacy policy we may provide on specific occasions when we are collecting or processing information about you, so that you are aware of how and why we are using the information. We may update this policy at any time.
Where we refer in this policy to your ‘personal data’, we mean any recorded information that is about you and from which you can be identified, whether directly or indirectly. It does not include data where your identity has been removed (anonymous data).
Where we refer to the ‘processing’ of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure, deletion, or retention.
Who is using your personal data?
The Russian Language Centre is the ‘data controller’ for the information we hold about you as a student or former student. This means that we decide how to use it and are responsible for looking after it in accordance with the GDPR.
Access to your student record and other data will be provided to both teaching and administrative staff, who need to view it as part of their work in carrying out the purposes set out in ‘how we use your data’. It will also be shared with the third parties described in ‘data sharing with third parties’.
The types of data we hold about you
The information we hold about you may include, but is not limited to, the following:
Personal details such as name, title, address, telephone number, email address, marital status, nationality, date of birth, sex, and gender identity, parental information (if relevant), and ID Photograph.
- Records relating to assessments of your work and details of examinations taken.
- Information captured in your student record including progression, achievement of milestones and progression reports.
- Passport information.
- Fees and financial records.
- Recordings of teaching and learning or research activities in which you were a participant.
- Your feedback on course provision and the student experience, collected through surveys, focus groups and other activities.
- Information about your engagement with the Russian Language Centre.
- Attendance records.
- Photographic data taken at events captured for the purpose of live streaming and future publicity materials.
- Information about your use of our information and communications systems, including your communication preferences.
As part of this, we may process the following ‘special categories’ of more sensitive personal data:
- Information about your health, including any disability and/or medical conditions.
How we obtained your data
We collect most of the information directly from you, through the application process and during registration. We will collect and generate additional information about you throughout the period of your study.
How we use your data
We use your data for various purposes connected with your studies, including, but not limited, to the provision of:
- Teaching and academic assessment.
- Welfare support including ensuring the health and safety of students, staff, and others.
- Funding and financial support.
- Research-related administration to support our equality responsibilities, quality assurance and planning processes.
- The administration of Russian Language Centre procedures including in relation to discipline, complaints, appeals, academic integrity, fitness to practice, fitness to teach and fitness to study.
- Supporting the provision of facilities and services.
- Understanding the educational and wider student experience in relation to admissions, teaching and learning and the student experience.
We set out below those circumstances where it is necessary for us to use your data. (These circumstances are not mutually exclusive; we may use the same information under more than one heading.)
Because we have a contract with you
We need to process your data to meet our obligations or exercise rights under our contract with you. We also need to process your data where the Russian Language Centre is working with a third party to offer you services.
Where we need to comply with a legal obligation
Information processed for this purpose includes, but is not limited to, information relating to the monitoring of equal opportunities and information provided to regulatory bodies, who may be required to share information with public authorities as necessary.
Where it is necessary to meet our legitimate interests
We need to process your data to meet our legitimate interests relating to student administration, business continuity or similar activities. Examples include, but are not limited to, the following:
- We may use email addresses to contact students to invite them to make use of opportunities related to their studies, and other related activities.
- We use your phone and email address for system authentication and access.
- We use your data held within our student records systems for system testing, training, and support purposes, allowing us to provide support to users across the Russian Language Centre and to maintain effective upkeep of our records systems.
Where we have your consent
There may be situations where we ask for your consent to process your data, for example, where we ask you to volunteer information about yourself for a survey or where we ask for your permission to share sensitive information – for example, information on your previous education.
Where it is necessary to protect your vital interests or the vital interests of another person
There may be circumstances in which it is necessary for us to process your data to protect an interest which is essential for your life or that of another person or where the processing serves important grounds of public interest and your vital interests: for example, humanitarian purposes which may include monitoring epidemics and their spread or in emergencies where there is a risk of serious harm or death to yourself or others.
Change of purpose
We will only process your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.
Please note that we may process your data without your knowledge or consent, where this is required or permitted by law.
Special Category Data
Special category data and criminal conviction data require a higher level of protection. Listed below are examples of processing activities that we regularly undertake in respect of these types of data. In addition to the activities listed below, it may sometimes be necessary to process this sort of information for exceptional reasons, for example, because it is necessary to protect your vital interests (including in relation to health and safety) or those of another person or for safeguarding purposes. This may include sharing such data with third parties. In some instances (for example responding to a request from police investigating an alleged criminal offence) this may be necessary even if data has been provided to the Russian Language Centre in confidence.
Health (Including disability)
We will process data about your health where it is necessary to make reasonable adjustments for disability and/or to monitor equal opportunities, for example to arrange reasonable adjustments for examinations or use of facilities.
Processing of this nature is necessary to meet contractual or other legal obligations. We may also process data about your health in accordance with the terms of our contract with you, to protect our legitimate interests and/or to comply with legal obligations where it is relevant. There may also be limited circumstances where your health and safety, or that of others, is at serious risk where your health data may need to be shared whether or not you have given consent (subject to data minimisation, limiting recipients of such data to those people or agencies able to assist (for example, NHS or emergency services staff). An example could be where you are at risk of causing serious harm to yourself or others (for example, threats or attempts at suicide or violence to yourself or others).
Criminal conduct (including convictions, proceedings or allegations)
We may process data about criminal conduct while you are on a course in accordance with the terms of our contract with you, in order to comply with our legal obligations or to meet our legitimate interests, including protecting other individuals from a foreseeable risk of harm, under our disciplinary, fitness to practice, fitness to teach or fitness to study purposes or where a complaint about the outcome of such a procedure is referred to a regulatory body. Such processing will be subject to suitable safeguards.
Data sharing with third parties
We may, from time to time, need to share your information with the following types of organisations:
- External institutions or organisations that the Russian Language Centre has collaboration or partnership agreements with (for example, overseas Universities and organisations).
- External organisations providing services to us, examples include those providing teaching services.
- Employers or prospective employers and educational institutions.
- Relevant public bodies and law enforcement authorities, including but not limited to: the UK Home Office; HM Revenue and Customs; the Police (including in relation to investigations into alleged criminal offences); and local authorities.
- The National Health Service or other medical practitioners (to support medical provision).
- In limited circumstances, to respond to a valid request under the Freedom of Information Act.
Where information is shared with third parties, we will seek to share the minimum amount necessary. For example, we may in appropriate cases share only your student code and not your name (this is known as pseudonymisation).
All third-party service providers that process data on our behalf are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.
Transfer of your data overseas
There may be occasions when we transfer your data overseas. Such transfers will only take place if one of the following applies:
- The country receiving the data is considered by the EU to provide an adequate level of data protection.
- The organisation receiving the data is covered by an arrangement recognised by the EU as providing an adequate standard of data protection, for example, transfers to companies that are certified under the EU US Privacy Shield.
- The transfer has your consent.
- The transfer is necessary for the performance of a contract with another person, which is in your interests.
- The transfer is necessary to protect your vital interests or of those of other persons, where you or other persons are incapable of giving consent.
Data security
We have put in place measures to protect the security of your information. Third parties that process data on our behalf will do so only on our instructions and where they have agreed to keep it secure.
Retention period
We will retain your data only for as long as we need it to meet our purposes, including any relating to legal, accounting or reporting requirements.
Your rights
Under certain circumstances, by law you have the right to:
- Request access to your data (commonly known as a ‘subject access request’). This enables you to receive a copy of your data and to check that we are lawfully processing it.
- Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
- Request erasure of your data. This enables you to ask us to delete or remove your data under certain circumstances, for example, if you consider that there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing (see below).
- Object to processing of your data where we are processing it to meet our legitimate interests (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your data for direct marketing purposes.
- Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your data to another party.
Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. However, where you have consented to the processing, you can withdraw your consent at any time by emailing us and we will stop the processing as soon as we can.
If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, please contact [email protected]. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
If you remain dissatisfied, you have the right to lodge a complaint with the ICO at https://ico.org.uk/concerns/.
Keeping your data up to date
It is your responsibility to check and ensure that your personal data is kept up to date. This is important in enabling us to be certain that the data we hold about you remains accurate and current.
Changes to this privacy policy
We reserve the right to update this privacy policy at any time and will seek to inform you of any substantial changes. We may also notify you in other ways from time to time about the processing of your personal data.