Privacy Policy
INTRODUCTION
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London Postgraduate Credit Management College (LPCMC) is committed to protecting and safeguarding your personal information and data privacy rights. This Privacy Policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you.
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This Privacy Policy applies to the personal data of our Students, Website Users, Affiliates, Partners, Suppliers, recruiters, and any other third parties we engage with. It also applies to the emergency contacts of our Staff.
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For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data is (“LPCMC” or “us” or “we”).
We will keep this Privacy Policy under regular review and update from time to time. Please visit this page if you want to stay up to date, as we will post any changes here.
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WHAT KIND OF DATA DO WE COLLECT?
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Students
In order to provide and support you throughout your programme, we need to process certain information about you. We only ask for details that will genuinely help us fulfil this. Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us process your admission and support you throughout your programme:
• Your biological information – name, title, date of birth, age and gender
• Your contact details – address, e-mail address and phone number
• Photograph and photographic identification document
• Education details
• Referee details
• Employment history and professional activities
• Nationality/citizenship/place of birth
• Immigration status (whether you need a work permit etc.)
• Extra information that you choose to tell us
• Extra information that your referees chooses to tell us about you
• Records of communications sent to you by the College or received from you
***Please note that the above list of categories of personal data we may collect is not exhaustive.
Affiliates/Partners/Beneficiaries
We usually only need to have your contact details or the details of individual contacts at your organization/institution (such as their names, telephone numbers and email addresses) to ensure that our relationship runs smoothly. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
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Other Users, such as Referees and Emergency Contacts
In order to care for our staff and provide our students with adequate support during their admission and programme, we require some basic background information (such as name, email address and telephone number). We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Students or Staff members.
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HOW DO WE COLLECT YOUR DATA?
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There are two main ways in which we collect your personal data:
• Directly from you; and
• From third parties
Through the below means:
• Personal data that you, the Student, give to us on web or hard copy forms, via e-mail, on social media platforms and over the phone
• Personal data that we receive from other sources (our Educational Partners – if you require more information about our partners, please contact londoncredit@lpcredit.co.uk
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HOW WILL LPCMC USE MY PERSONAL DATA?
Students
The main reason for using your personal details is to help you process your admission and support you throughout the duration of your programme. We ensure we receive adequate personal information to be able to do this.
We generally use Students data in the following ways:
• Admission Activities – this also involves sharing your personal details with our affiliate
• Provide you with information about the programme and other important notices
• For the direct marketing of LPCMC programmes and services
• To help us to establish, exercise or defend legal claims
• To respond to academic or performance reference
• To respond to hiring organisations’ resourcing directly from LPCMC where consents have been received from our students indicating their interest in job opportunities. For more details about this process, please contact londoncredit@lpcredit.co.uk
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Email marketing and broadcast
LPCMC is keen to connect and communicate our activities, institutional views, latest news and values with staff, affiliates, partners, students, alumni and supporters. We do this by providing information through a range of online and offline channels including publications, events, press releases, social media and email. We value our relationship with you and we use your personal data to communicate industry trends, opportunities and discounts, notify you of upcoming events and to also ensure we work efficiently and effectively.
In order to do this, we have a database that contains personal data collected by the Institution during the course of our relationship with our affiliates, partners, staff, students, and alumni. We aim to keep your data up to date and welcome any updates to your details or corrections to any inaccuracies you may wish to provide.
If you no longer want us to use your data, or wish to amend the type of communications you receive, please contact londoncredit@lpcredit.co.uk
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Other Users, such as Referees and Emergency Contacts
We collect your contact details only where a Student or a member of our Staff puts you down as their emergency contact or as a referee.
We use personal data from Web Users and social media platforms to provide you with information about our programmes including course details and other information that may be relevant to your interests.
WHO LPCMC SHARES YOUR DATA WITH
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Apart from the reason of delivering our educational programme to you, we will never share your personal data to third parties for their own purposes unless we are required by law to do so.
Your personal data may be shared with:
• Our educational affiliates/partners/hiring organisations in order to provide you with our services
• Individuals and organisations who hold information related to your reference, admission or job application to work with us
• Third parties requesting academic or performance reference on behalf of our staff or students
• Regulatory bodies
• Third party service providers who perform functions on our behalf (including accountants and professional associates, professional partners, business associates)
• We have our own obligations under the law, if we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation
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HOW LONG WILL LPCMC RETAIN MY PERSONAL DATA?
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We will hold your personal information on our systems for as long as necessary for the relevant activity, or as long as is set out in any relevant contract you hold with LPCMC after which it will be deleted.
If you’ve shown an interest in taking one of our programmes, we’ll retain your data for a period of two years from the point that you last engage with us.
If you are an existing students and have indicated interest in our alumni activities, your relevant data will be kept for longer to enable you derive associated benefits. Otherwise, your data will be retained for a period of ten years after your programme ended. However, core data like your name, e-mail address and other academic reports will be retained on our system for official use such as responding to academic reference requested on our students’ behalf.
Your personal data may be held for longer where we believe in good faith that the law or other regulations requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
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HOW DO WE SAFEGUARD YOUR PERSONAL DATA?
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LPCMC is committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal data, please let us know immediately by contacting londoncredit@lpcredit.co.uk
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OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION
Our legal basis for collecting and using the personal data described above will depend on the personal information referred and the specific context in which we collect it.
Consent
We understand that once your personal data is submitted to LPCMC for the purpose of which it has been requested, we have your consent to process such information to be able to deliver our services or meet our contractual obligation. If the circumstance for processing your personal data is no longer in place, your data will be retained for a certain period after which it will be deleted from our system (Please refer to “How long will LPCMC retain my personal data?”)
In certain circumstances, we may require additional consent to process your personal data in relation to certain activities that are advantageous to your activities with us. You will be able to provide your consent via opt-in consent and adequate information will be provided on the purpose of such request.
We are likely to provide you with a tick box for you to check or a reply e-mail requested to make this process clear and unambiguous.
Legitimate Interest
Processing your personal data may be in our legitimate interests pursued by us or by third party, where such interests are not overridden by your fundamental rights or freedom which require protection of personal data.
We do not think any of the following activities prejudice individuals in any way, rather, they help in offering an efficient and seamless service.
• Students – Processing admission and supporting students throughout their programmes
• Affiliates/Partners/Beneficiaries – Administration of students’ programme and meeting contractual obligations
• Other Users, such as Referees and Emergency Contacts – Providing relevant information as it relates to our services and obtaining information to support our staff and students
Legal
In some situations, we may have a legal obligation to collect personal information from you. If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not. We will also advise you on the possible consequences if you do not provide your information.
Sometimes, it may become necessary to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims.
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WHAT ARE MY RIGHTS?
Right to access
You have a right to request copies of the data held about you by the Institution at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “noticeably unsubstantiated or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.
Your request will detail a description of your personal data that we hold, why we hold it, who it could be disclosed to and we will let you have a copy of the information in an understandable form.
To request an access or correct any mistakes, please contact londoncredit@lpcredit.co.uk
Right of rectification
You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Please send request to londoncredit@lpcredit.co.uk
Right to erasure
You have the right to request that we erase your personal data in certain circumstances. Generally, the basis must be consistent with the following criteria:
• the data are no longer necessary for the purpose for which we originally collected and/or processed them
• where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing
• the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR)
• if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing
Please note that in certain circumstances where we comply with additional local law requirements regarding data subject right to erasure, we may refuse your request in accordance with local laws.
Request may be refused where there is a need to comply with legal obligation, resolve a complaint or defend a legal claim.
Please send request to londoncredit@lpcredit.co.uk
Right to withdraw consent
Where LPCMC have obtained your consent to process your personal data for certain activities (for example, for our alumni), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Please send request to londoncredit@lpcredit.co.uk
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Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances. This implies that we can only continue to store your data but will not be able to carry out any further processing activities with it until either:
• You give consent to commence processing
• further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest
• Surrounding circumstances for restricting processing are resolved
You may request for your personal data to be restricted under the following circumstances:
• where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified
• where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data
• where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
• where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible. We will, of course, notify you before lifting any restriction on processing your personal data.
Please send request to londoncredit@lpcredit.co.uk
Right to data portability
You have the right to obtain a copy of your personal data so that it can be reused for your own purposes in another IT environment. This right of data portability applies to personal data provided by you and personal data that we process based on your consent or in order to fulfil a contract. To request a copy, please send an e-mail to londoncredit@lpcredit.co.uk
RIGHT TO MAKE A COMPLAINT TO the supervisory authority
You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found below:
Phone: 0303 123 1113
E-mail: casework@ico.org.uk
Post: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
OFFENSIVE OR INAPPROPRIATE CONTENT ON LPCMC WEBSITES
We may choose to remove posted or sent content that may practically be deemed to be offensive, inappropriate or objectionable anywhere on or to LPCMC websites or social media channels, or otherwise engage in any disruptive behaviour on any LPCMC service.
Where we reasonably believe that you are in breach of any applicable laws, we may disclose your personal information to relevant third parties, including law enforcement agencies or your internet provider. LPCMC would only do so in situations where such disclosure is allowed under applicable laws, including data protection law.
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CHANGES TO LPCMC’S WEBSITE PRIVACY POLICY AND NOTICES
We keep our Privacy Policy under regular review. So you may wish to check it each time you submit personal information to LPCMC. The date of the most recent revisions will appear on this page and we may notify you by e-mail if material changes are made to the Privacy Policy. If you do not agree to these changes, please re-consider the use of LPCMC websites to submit personal information to us.
CONTACTING LPCMC ABOUT THE PRIVACY POLICY
We take privacy seriously and promise to get back to you as soon as possible if you have any comments or questions about this privacy policy. To do so, please contact:
The Data Compliance Officer
London Postgraduate Credit Management College
Email: londoncredit@lpcredit.co.uk