Privacy Policy
Who we are
University of the Commonwealth Caribbean (‘The University’, ‘we’ or ‘us’) are a ‘Data Controller’ and are responsible for, and control the processing of your Personal Data.
You can contact us at email dataprotection@uccglobal.co , UCC Global, 17 Worthington Avenue, Kingston 5, Jamaica. Tel. 876-906-3000. Our Data Protection Officer can be contacted at dataprotection@uccglobal.co
This privacy notice is for the UCC Global’s Online Distance learning Programme. We have partnered with an external organisation, Higher Education Partners (HEP) to carry out this function. The notice explains how we collect and process your personal data, whether it be for general enquiries or personal data for applications or enrolment.
How We Use Your Data
We will collect and process your personal data for a number of related reasons. Please see all of our purposes listed below:
| Purpose | Lawful Basis (Reason) |
| To respond to your enquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or complaints. | Legitimate interest |
| To send you marketing related emails, with information about our services and other news about us. | Consent |
| Assessing your eligibility to be offered a place on one of our online academic courses and programmes | Necessary for a contract or entering into a contract |
| To complete your transactions, and provide you with related assistance in relation to your application. | Necessary for a contract or entering into a contract |
| Provision of your course of study during your period of enrolment. | Necessary for a contract or entering into a contract |
| Making reasonable adjustments for disabilities and providing relevant support to students or applicants with ill health | Substantial public interest – specifically support for individuals with a particular disability or medical condition |
| Assessment of academic progress and performance (including attendance) | Necessary for a contract or entering into a contract |
| To provide you with support and pastoral services throughout your course of study. | Necessary for a contract or entering into a contract |
| Administration of complaints, grievances and appeals | Necessary for a contract or entering into a contract |
| Obtaining payment of fees | Necessary for a contract or entering into a contract |
| Communication directly to students for the purposes of student experience and to communicate updates to documents such as terms and conditions and policies | Legitimate Interests |
| For audit purposes and to verify that our internal processes are compliant with legal, regulatory or contractual requirements. | Legal obligation |
| Fraud and security monitoring purposes, including to prevent cyber-attacks. | Legitimate Interest |
| Developing, enhancing, improving, or modifying our current services, identifying usage trends and determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users. | Legitimate Interest |
| Automated decision making and profiling for business reporting and providing personalised services to you tailored to your interests. | Legitimate Interest |
| Market research and surveys | Necessary for the legitimate interests of planning and developing the University’s operations. |
| External Reporting including to OfS and its agencies | Legal Obligation |
We will always highlight areas where we need to ask for your consent as the lawful basis and will give you the choice to opt-in. If you do consent or opt in, we will let you know how you can opt out in the future. We will not process your personal data for any other purpose other than those stated above without informing you first.
We may use your data for reporting purposes to improve targeting, personalisation and overall effectiveness of marketing activity. If we do this we will either aggregate your data or anonymise it to ensure you cannot be identified.
Information We Collect
The vast majority of information that we process about you will be provided by you, typically by one of the following methods including:
when you submit your details on the request information form on our website or paid traffic landing pages, by applying for admission via our online application form; and when you contact us by phone and provide information to one of our enrolment advisors. All our phone conversations are recorded for training and quality purposes.
We may get additional information from your referee or employer where one is required.
Information provided by you will include details such as:
- First Name
- Last Name
- Other names used
- Postal address
- Email address
- Telephone number
- Mobile number
- Nationality
- Country of residence
- Second Nationality
- Gender
- Date of birth
- IP Address
- Financial data
- Disability
- Educational records and qualifications, including higher and further education institutions attended, dates of attendance, degree programme titles, subjects and grades
- Higher and further education transcripts and certificates
- Work history – including employer, job title, responsibilities, location and dates in role
- School type of data subject
- Confirmation of whether English is first language
- Membership of professional or industry associations
We are required to collect your personal data in order to provide the requested services to you and facilitate your application process. If you do not provide the information requested, we may not be able to provide our services or consider you for admission. If you disclose any personal data relating to other people to us or to our service providers in connection with our services, you represent that you have the authority to do so and to permit us to use the information in accordance with this privacy notice.
Who We Share Your Personal Data With
Information is shared with relevant departments within the University for the purposes outlined above. In addition, specific data may be obtained from and shared with the following parties for the purposes specified:
| Recipient or Source | Purpose and type of data | Lawful Basis |
| Third parties such as auditors or legal entities | Other third parties may include auditors to facilitate auditing purposes, or parties which may assist us to enforce our terms and conditions. | Legal obligation |
| External Statutory Reporting | Transparency Return including identifiable personal data and special category data. | Statutory requirement |
| Educational Institutions | Verification of qualifications – Grades and transcripts of grades achieved | Necessary for a contract or entering into a contract |
| Student Loans Company/Other funders | To facilitate the payment of funds – Contact and payment details | Necessary for a contract or entering into a contract |
| Organisations with enforcement powers. | To comply or assist with requests in accordance with their enforcement powers | Legal obligation |
We will ensure that we have a robust data processing agreement in place with any third-party data processor we use. We will only share the minimum amount of personal data with any of the above and will always do so in accordance with the law.
Higher Ed Partners uses third parties for services such as website hosting, contact centres, information technology and data analysis.
We will ensure that Higher Ed Partners have robust data processing agreements in place with any third parties within the EEA, as well as Standard Contractual Clauses or Binding Corporate Rules with any third parties based outside the EEA.
Retention
- Successful application data will be retained for six years from the end of the current academic year.
- Unsuccessful application data will be retained for one year.
- Enquiry data will be retained for three years.
- Telephone recordings will be retained for one year.
- Enrolment data will be retained for ten years following the end of your course.
Your Individual Rights
As an individual, you have a number of rights available to you. To find out more about how you may exercise those rights, for example, The Right of Subject Access: obtaining a copy of your information which we may hold; The Right to Rectification: correcting any mistakes or completing the information we hold about you; or The Right to Object to Automated Individual Decision-Making please see our Data Protection web pages available here or the ICO website for more information.
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions contained in each such email or by contacting us at dataprotection@higheredpartners.co.uk.
How to Complain
If you have any queries, concerns or believe that your Personal Data is being handled in a manner which is contrary to statutory requirements, you may wish to contact the University of The Commonwealth Caribbean’s Data Protection Officer via dataprotection@UCCGlobal.co
You also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.
Changes to Privacy Notice
We regularly review our privacy notice and will review it at least annually. This privacy notice was last updated on 10 November 2021.
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