Privacy policy

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
• how the law protects you

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.

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.

Contact details

Full name of legal entity: Cambridge Education Group Limited
Name or title of DPO: Lisa Tyler
Email address: [email protected]
Postal address: 51-53 Hills Road, Cambridge CB2 1NT

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.

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.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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 www.cambridgeeducationgroup.com 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.

If you do not provide us with personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with education services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

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 is sent to you
• apply for one of our courses
• apply for a job
• complete a survey
• give us some feedback.

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:
  1. analytics providers;
  2. advertising networks; and
  3. search information providers.

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.

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, for example, if you needed emergency medical treatment (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

5.1 Prospective students and agents

5.2 Enrolled Students

5.3 Employment Candidates

5.4 All visitors to website

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  

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 or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

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.

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.

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.

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above.

Internal Third Parties

CEG companies acting as joint controllers or processors and who are based in the UK, the Netherlands, Sweden, the US and China and provide (i) application and admissions services, (ii) core teaching and learning services, (iii) student administration services and (iv) student welfare services.

External Third Parties

• Educational agents
• Parents or parental approved representatives 
• UK Visas and Immigration (UKVI)
• Immigration and Naturalisation Service (Netherlands)
• US Immigration and Customs Authorities
• Swedish Immigration Agency
• Government and Corporate Financial Sponsors and Embassies 
• Taxi companies
• Accommodation providers
• ONCAMPUS university partners
• CEG Digital University Partners 
• Other university destinations
• Student insurance provider
• Approved test centres
• Exam boards
• Validating bodies for exam boards
• Medical or Public Health authorities (and where an emergency situation to any other organisations/individuals deemed necessary as assessed at the time)
• Providers of activities for students
• Local authorities
• Higher Education Statistics Agency (HESA) 

A copy of the HESA Student Collection Notice can be accessed here. 

• Office for Students (OfS)

The Office for Students is an official body which appoints designated quality bodies to enact educational oversight on its behalf.  For more information see https://www.officeforstudents.org.uk

• Quality Assurance Agency for Higher Education (QAA)

The OfS appoints QAA as a designated quality body.  We are subject to review by QAA in respect of ONCAMPUS for UKVI purposes. See www.qaa.ac.uk for more information.

• Local councils
• Transport for London
• HM Revenue & Customs, regulators and other authorities acting as processors
• Service providers worldwide acting as processors
• Cloud hosted VLE providers
• Professional advisers worldwide acting as processors or joint controllers.
• Local authorities
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

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_en
• Where 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. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA and the UK. 

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.

How long will you use my personal data for?

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. 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.

(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/).

In some circumstances you can ask us to delete your data: see Request erasure in Section 10 Your legal rights for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

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 of your personal data - 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 of your personal data – (commonly known as 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 of your personal data - 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 processing your personal data - 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 of your personal data – (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 consent.

Information for students studying with a CEG university partner in the US

Family Educational Rights and Privacy Act of 1974 (FERPA)
FERPA is a US federal law that aims to protect the privacy and sensitivity of student education records and gives certain rights to parents and guardians in respect of those records. These rights automatically transfer to you when you turn 18 years old. During your student registration process CEG’s university partners will ask you to sign a voluntary waiver form authorising disclosure of your records to your parent(s) or guardian(s). Further information on FERPA may be found at US Department of Education FERPA

Health Insurance Portability and Accountability Act of 1996 (HIPAA)
HIPAA is a US federal law that aims to protect individuals’ medical records and other personal health information. It gives you the right to access your health information and may apply if you are offered a health insurance plan by the CEG university partner. Further information may be found at US Department of Health HIPAA for individuals.

Additional information for students ordinarily resident in the state of California, US who are studying outside of California.

California Consumer Privacy Act of 2018 (CCPA)
CCPA is a Californian state law and is effective as of 1 January 2020. It creates new consumer rights relating to the access to, the deletion of and sharing of personal information that is collected by businesses (which includes CEG). Please note that if your place of study is located in the European Union then you will also have the rights detailed earlier in this section 10 under the GDPR. Further information may be found at California Consumer Privacy Act of 2018 (CCPA)

Data Protection Officer
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer, Lisa Tyler in writing with full details of your request.  You can send an email to [email protected] or write to us at:-

Lisa Tyler
Data Protection Officer
Cambridge Education Group Limited
51-53 Hills Road
Cambridge
CB2 1NT

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.

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.

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.

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.