Privacy policy
Welcome to Cambridge Education Group Limited’s Privacy Notice.
Welcome to Cambridge Education Group Limited’s Privacy Notice.
This Privacy Notice applies to Cambridge Education Group (CEG) and all CEG’s subsidiary companies (CEG Group).
When we mention Cambridge Education Group, CEG or refer to we, us or our in this Privacy Notice then we are referring to the relevant company that is responsible for protecting your personal data.
The relevant CEG companies are:
- Cambridge Education Group Limited
- CEG Administrative Services Limited
- Cambridge Education Group Consulting Limited (Shanghai and Beijing branches)
- Castel Education Limited (Ireland)
- iheed Health Training Limited (Ireland)
- UniHaven Limited (Ireland)
- CEG UFP Limited
- ONCAMPUS Aston Limited
- ONCAMPUS Hull Limited
- ONCAMPUS London Limited
- ONCAMPUS Loughborough Limited
- ONCAMPUS LSBU Limited
- ONCAMPUS Reading Limited
- ONCAMPUS Southampton Limited
- ONCAMPUS Sunderland
- ONCAMPUS UK North Limited
- Hull London Campus Limited
- ONCAMPUS Amsterdam BV
- ONCAMPUS Paris SASU
- CEG Digital Limited
- CEG Online Limited
- CEG UNW Online Limited
- Arts Online Bournemouth Limited
- Falmouth Flexible Limited
- Kings College London
- Hull Online Limited
- Plymouth Online Limited
- Portsmouth Online Limited
- Queen Mary Digital Limited
- Southampton Online Limited
1. IMPORTANT INFORMATION AND WHO WE ARE
1.1.Purpose of this Privacy Notice
This privacy notice aims to give you clear and detailed information about:
- How CEG collects and processes your personal data.
- The legal grounds allowing CEG to do so
- How CEG looks after your personal data
- Your privacy rights and how the law protects you
1.2.Controller
Under data protection law the controller of your personal data decides how and why your personal data will be processed and takes responsibility for looking after your personal data. The controller of your personal data will be Cambridge Education Group Limited. We are registered with the Information Commissioner’s Office (ICO) with reference number Z1727261.
1.3.Data Protection Officer
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Full name of legal entity: Cambridge Education Group Limited
Name or title of DPO: Kathryn Brooks
Email address: [email protected]
Postal address: 51-53 Hills Road, Cambridge CB2 1NT
1.4.Changes to the Privacy Notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
When we issue a new version of this privacy notice we will post a message on our websites advising of this.
1.5.Third-party links
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. The websites of any of CEG’s subsidiary businesses are subject to this privacy policy.
1.6.Use of Artificial Intelligence (AI)
AI technologies are used to enhance our services and improve your experience with CEG, we may use AI to support your journey with us and ensure that you have the right information required to make a decision about either studying or working for CEG.
We are committed to ensuring that our use of AI is transparent, fair, and does not result in unfair or discriminatory outcomes. We regularly test our AI systems to ensure they comply with ethical standards and legal requirements.
All personal data processed by AI is handled in accordance with the UK GDPR and this Privacy Notice. We implement robust security measures to safeguard your data and ensure that AI systems are designed with privacy in mind.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username, student ID number, marital status, title, date of birth, gender, photograph, immigration status, right to work, curriculum vitae (CV), covering letter, academic record, employment history and references and images captured by CCTV.
- Special Category Data includes details about your race or ethnicity, religious beliefs, information about your health, genetic and biometric data (we have in place safeguards for processing such data including confidentiality agreements and restrictions on access to such data).
- Criminal Conviction Data includes details about any unspent criminal convictions and offences (where not covered by Section 1 (1) of the Rehabilitation of Offenders Act 1974) (we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data).
- Contact Data includes your home address, email address and telephone numbers, next of kin and emergency contact information.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use when accessing our website or any of the websites of our subsidiaries accessed from that website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our websites and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Aggregated Data includes statistical or demographic data which we may collect, use, and share for any purpose. Where Aggregated Data can directly or indirectly identify you, we will use it in accordance with this Privacy Notice.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
3.1.Direct interactions
You may give us your Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data by filling in application forms, by sending us your CV and covering letter or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Create an account on our website.
- Request marketing information.
- Apply for one of our courses.
- Apply for a job.
- Complete a survey.
- Submit feedback.
3.2.Third Parties or Publicly Available Sources
We may receive personal data about you from various third parties and public sources such as those set out below:
- Educational agents – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
- Parents or parental approved representatives – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
- Universities – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
- Named Referees – Identity Data and Contact Data
- Recruitment agencies – Identity Data and Contact Data
- Disclosure and Barring Service – Criminal Conviction Data
- Providers of Technical, Payment and Delivery Services – Contact, Financial and Transaction Data.
- Technical Data from the following parties:
- Analytics providers.
- Advertising networks.
- Search information providers.
3.3.Cookies (Automated technologies or interactions)
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our separate Cookies Policy for further details.
4. OUR LEGAL BASIS FOR USING YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for us to perform a contract entered into with you or is necessary for us to take steps (at your request) prior to us entering into a contract (CONTRACT).
- Where we have a legitimate organisational interest and use your personal data in a way that you would reasonably expect, and which has a minimal impact on your privacy (LEGITIMATE INTERESTS).
- Where we need to comply with a legal or regulatory obligation (LEGAL OBLIGATION).
- Where you have given us your consent to process your personal data (CONSENT).
- Where there is an emergency situation that is essential for someones life (VITAL INTERESTS).
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the processing of Special Category Data or when sending third party direct marketing communications to you via email or text message.
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your Personal Data where more than one ground has been set out in the table below.
You have the right to withdraw your consent at any time by contacting us.
Please see Section 10: Your legal rights
5. HOW WE USE YOUR PERSONAL DATA
5.1.Prospective Students and Agents
PROSPECTIVE STUDENTS AND AGENTS | ||
Purpose/Activity | Type of Data | Lawful basis for processing |
To register you on our website and subscribe to our services | Identity Contact Marketing and Communications Data | Contract Consent |
To process your application form and correspond with you including: (i) arranging visas (ii) processing deposits and course fees (iii) verifying exam and test results | Identity Contact Financial Criminal Conviction Special Category | Contract Consent |
To assess students’ eligibility for scholarship or bursary | Contact Identity Financial | Contract |
ACCOMMODATION PROVIDERS (INCLUDING HOMESTAY PROVIDERS) | ||
To process your application to become an approved accommodation provider (includes compulsory DBS check/background check in North America) | Identity Contact Financial Transaction Criminal Conviction | Contract Legal obligation |
Provision of personal data to third parties | ||
To educational agents where the agent has submitted an application on behalf of a prospective student | Identity Contact Financial Criminal Conviction Special Category | Contract Consent |
To parents/parental approved representatives where the parents or representatives have submitted an application on behalf of a prospective student who is under 18. | Identity Contact Financial Criminal Conviction Special Category | Contract Consent |
To third party online conversion service where an applicant has started the application process but does not complete it. | Identity Contact | Legitimate interests (CEG has a business interest in securing applications for its courses) |
To Third party agencies supporting the processing of an application for a Tier 4 visa, if required. | Identity Contact Financial Transactional | Consent (provided by applicant to CEG at the time of referral) |
To third party applicant screening companies supporting compliance interviews, if required | Identity Contact | Consent (provided by applicant to CEG at the time of referral) |
To UK Visas and Immigration (UKVI) to facilitate the application for a Tier 4 visa | Identity Contact | Legal obligation |
To Immigration and Naturalisation Service (Netherlands) | Identity Contact | Legal obligation |
To cloud hosted virtual learning environment (VLE) services | Identity Contact | Legitimate interests (CEG has a business requirement to use VLEs in order to provide online teaching resources) |
To financial or government sponsors of a course | Identity Contact Special Category | Legal obligation Consent |
5.2.Enrolled Students
5.3.Employment Candidates
EMPLOYMENT CANDIDATES | ||
Purpose/Activity | Type of Data | Lawful basis for processing |
To assess your skills, qualifications, and suitability for the role | Identity Contact | Contract |
To assess information about disability status to consider whether we need to make appropriate adjustments during the recruitment process | Special Category | Consent |
Once an offer has been made to carry out background and reference checks, where applicable (excluding criminal record) | Identity Contact | Contract |
Once an offer has been made to carry out a criminal record check where required by law due to the nature of the role applied for | Identity Criminal Conviction | Contract Legal obligation |
To communicate with you about the recruitment process | Contact | Contract |
To comply with equal opportunities monitoring and reporting requirements | Identity Special Category | Legal obligation Legal obligation and necessary for statistical purposes |
5.4.All visitors to website
ALL VISITORS TO WEBSITE | ||
Purpose/Activity | Type of Data | Lawful basis for processing |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity Contact Profile Usage Technical Marketing and Communications | Legitimate interests (to study how our services are used, to develop them, to grow our business and to inform our marketing strategy) Consent |
To use data analytics to improve our website, services, marketing, customer relationships and experiences | Technical Usage | Legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you | Identity Contact Technical Usage Profile | Legitimate interests (to develop our services and grow our business) |
Provision of personal data to third parties | ||
External | ||
To service providers worldwide acting as processors who provide IT and system administration services | Identity Contact Technical Usage Profile | Legitimate interests (CEG have a business requirement to use specialist IT and system administration providers that cannot be provided internally) |
To third parties to whom we may choose to sell, transfer or merge parts of our business as our assets. | Identity Contact | Legitimate interests (CEG may wish to do this as part of its business strategy) |
5.5.Marketing
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition, registered for a promotion or attended an event and, in each case, you have not opted out of receiving that marketing.5.6.Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any company outside the CEG subsidiaries for marketing purposes.5.7.Opting-Out
You can ask us or third-parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing a service or other transaction.5.8.Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
6.1.Internal Third-Parties
CEG companies acting as joint controllers or processors and who are based in the UK, EU, the Netherlands and China and provide (i) application and admissions services, (ii) core teaching and learning services, (iii) student administration services and (iv) student welfare services.
6.2.External Third-Parties
We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
We share your personal data within the CEG Group. This will involve in some cases transferring your data outside the European Economic Area (EEA) and the UK.
Some of our external third parties are based outside the EEA and the UK so their processing of your personal data will involve a transfer of data outside the EEA and the UK.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission which are specified on their website:https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_enWhere we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if we have specific contracts approved by the European Commission in place which give personal data the same protection it has in Europe and the UK, with standard contractual clauses and by using additional technical or organisational safeguards.
8. DATA SECURITY
The Personal Data that we collect from you will be stored by cloud providers or third-party services hosted in the Microsoft Azure UK or Western Europe regions. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third-parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. DATA RETENTION
How long will you use my Personal Data for?
Details of retention periods for different aspects of your personal data are set out in the table below:
Type of data | Retention timescale | |||
STUDENT RECORDS | ||||
| ||||
Enquiries from prospective students (ONCAMPUS) | 1 year from creation of record | |||
Records of campaigns and events (ONCAMPUS) | 1 year from creation of record | |||
Enquiries from prospective students (CEG Digital) | Where we hold your personal information for marketing purposes, we will retain that information for a period of three years (or longer if you agree). | |||
Records of campaigns and events (CEG Digital) | 1 year from last sales activity | |||
2. Applications – Not Progressed (Closed) | ||||
Application form (incl scholarship applications) | 2 Years after date of closure | |||
Offer of place and related correspondence | 2 Years after date of closure | |||
Acceptance of place and related correspondence | N/A | |||
Details of criminal convictions | 1 Year after date of closure | |||
Passport Documentation/Previous Visas | 1 Year after date of closure | |||
Academic and English Documents | 1 Year after date of closure | |||
Centre-related Application and Registration Forms | 1 Year after date of closure | |||
3a. Applications – Registered Paid (Without a CAS, Not Arrived/Enrolled, where applicable) | ||||
Application form (incl scholarship applications) | 2 Years after date of Withdrawal | |||
Offer of place and related correspondence | 2 Years after date of Withdrawal | |||
Acceptance of place and related correspondence | 2 Years after date of Withdrawal | |||
Details of criminal convictions | 2 Years after date of Withdrawal | |||
Passport Documentation/Previous Visas | 2 Years after date of Withdrawal | |||
Academic and English Documents | 2 Years after date of Withdrawal | |||
Centre-related Application and Registration Forms | 2 Years after date of Withdrawal | |||
Copies of invoices | 7 Years after date of Withdrawal | |||
3b. Applications – Registered Paid (With a CAS, Not Arrived/Enrolled, where applicable) | ||||
Application form (incl scholarship applications) | Original course end date (as per most recent CAS) + 2 Years | |||
Offer of place and related correspondence | Original course end date (as per most recent CAS) + 2 Years | |||
Acceptance of place and related correspondence | Original course end date (as per most recent CAS) + 2 Years | |||
Details of criminal convictions | Original course end date (as per most recent CAS) + 2 Years | |||
Passport Documentation/Previous Visas | Original course end date (as per most recent CAS) + 2 Years | |||
Academic and English Documents | Original course end date (as per most recent CAS) + 2 Years | |||
Centre-related Application and Registration Forms | Original course end date (as per most recent CAS) + 2 Years | |||
Copies of invoices | 7 Years after date of Withdrawal | |||
Digital | ONCAMPUS | |||
Application form (incl scholarship applications) | Original course end date | + 3 years | + 6 years | |
Offer of place and related correspondence | Original course end date | + 3 years | + 6 years | |
Acceptance of place and related correspondence | Original course end date | + 3 years | + 6 years | |
Details of criminal convictions | Original course end date | + 3 years | + 6 years | |
Passport Documentation/Previous Visas | Original course end date | + 3 years | + 6 years | |
Academic and English Documents; Reports | Original course end date | + 3 years | + 6 years | |
Offer/offer pack Forms | Original course end date | + 3 years | + 6 years | |
Copies of invoices | 7 Years after date of Withdrawal | |||
Digital | ONCAMPUS | |||
Application form (incl scholarship applications) | Completion of course | + 3 years | +6 Years | |
Offer of place and related correspondence | Completion of course | + 3 years | +6 Years | |
Acceptance of place and related correspondence | Completion of course | + 3 years | +6 Years | |
Details of criminal convictions | Completion of course | + 3 years | +6 Years | |
Passport Documentation/Previous Visas | Completion of course | + 3 years | +6 Years | |
Academic and English Documents; Reports | Completion of course | + 3 years | +6 Years | |
Copies of invoices | 7 Years after date of Withdrawal | |||
Basic student record comprising student name, enrolment date, end date, institution, and transcript data | Permanently | |||
Accident/incident records of students | 3 years from the date of accident/incident 40 years in the event of exposure to asbestos | |||
Copies of filmed lesson observations | Completion of academic year + 1 term | |||
CANDIDATE RECORDS | ||||
Application forms, CVs, and interview notes (unsuccessful candidates) | Last communication to candidate + 6 months | |||
Application forms, CVs, and interview notes (successful candidates) | Part of personnel file 6 years after employment ceases. |
(Please note that CEG’s stated data retention periods may be affected by the terms of reference of the Independent Inquiry into Child Sexual Abuse (IICSA). CEG is obliged to retain all documentation regarding a safeguarding concern for the duration of the IICSA. For more information, please visit https://www.iicsa.org.uk/).
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data:
- Request access to your Personal Data – (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request Correction– This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request Erasure – (or the “Right to be Forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to Processing – where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request Restriction of – This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request Transfer – (also known as the “Right to Data Portability”) We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to Withdraw Consent – However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your Information for students studying with a CEG university partner in the US.
10.1.No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10.2.What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.3.Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10.4.Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.