What happens to your personal information

What does BPP do with my personal information?

The legitimate purposes for which we use your personal information will depend upon how you use the website. They may include the following:

• Internal record keeping and audits
• Administration of the Website and our relationship with you including to provide products to you which you may order from us and/or to provide our services to you and to monitor those services
• Dealing with and responding to any communication, enquiry or application which you submit to us and to provide you with appropriate services which may include sending your further information
• Contacting you for research purposes including market research and to help us plan and improve our products and services. We may contact you ourselves or ask outside research agencies to do so on our behalf (please refer to the section “Who do we share this information with” below)
• Conducting optional online surveys (e.g. to gauge our service, collect demographic information and other information that we may find useful)Analysing patterns and trends of use and the uptake of our educational courses and facilities(If you are a student or delegate on one of our courses) to administer tests and examinations in which you participate, to verify your results and to have the course and/or your papers and/or award internally or externally assessed and verified
• Sending you direct marketing about products and services (but only when we have the appropriate consent(s) from you - please refer to the section “Direct Marketing” below)Enabling BPP and its group companies, including the ultimate US parent company of all BPP companies, namely Apollo Group, Inc. and/or Apollo Global, Inc. of which it is a part (all of which are the Apollo Group Companies, as defined in the “Who do we share your personal information with” section below), to:
• provide information and marketing services related to our products and services
• carry out statistical analyses regarding the products and services offered by us or the Apollo Group Companies including analysing the profiles of customers, clients, students and staff together with the patterns and trends of use and the uptake of educational courses and facilities by and across BPP and its group companies including Apollo Group Companies based in the US; and
• improve efficiency, results, communications, marketing, processes, standards and procedures as a result of such information and marketing services and statistical analyses referred to above across BPP and its group companies and including Apollo Group Companies based in the US and/or for making use of additional expertise, experience, resource and facilities available from Apollo Group Companies based in the US.
• Fulfilling legal obligations to funding bodies
• Ensuring compliance with legal, regulatory and other good governance obligations (please see “Whistleblowing and Compliance with US SOX Law” section below).

This list is not exhaustive and it may change or be updated in accordance with the nature of our work and as legal, regulatory and other good governance requirements require. You personal information may be kept in paper files and/or held in electronic form (e.g. on our IT systems, in emails or in data bases).

What happens when I submit my personal information?

When your personal information is collected through a page on the Website it is directed into one or more IT systems.

It is then stored and used depending on which BPP company or training entity the information needs to go to in order for (e.g.) your request for information to be processed, for you to be registered on a training course or for your to receive related course materials.

Your personal information may be held on the IT system of the BPP group company (e.g. for the purpose of providing training or educational services to you) and/or on the system of another company (within or outside the BPP group of companies) outside the UK which is providing IT hosting or similar services, in accordance with a suitable contract in place with that company.

Who do you share my information with?

The BPP company to whom your personal information is directed through the Website may transfer your personal information to other companies in the Apollo group of companies which includes:

• Other companies in the BPP group of companies (including BPP Holdings Limited and its subsidiaries and affiliates); and
• Apollo Group, Inc. and/or Apollo Global, Inc. (and subsidiaries and affiliates of each of them) which are companies based in the US

(together “Apollo Group Companies”).

We may make your personal information available to other businesses which we engage to help us run our business, for example to provide services to us. This may include (this is not a definitive list) market research companies, providers of direct marketing services, training providers, suppliers of services relating to whistleblowing (please see the “Whistleblowing and Compliance with US SOX Law” section below) and IT hosting and maintenance providers.

In addition (if you are a student or delegate on one of our courses) we may make your personal information available to external awarding bodies and auditors which verify your test and examination results, in order to obtain accreditations for you.

We may also make it available to relevant central government departments or other external bodies which oversee the quality of the services we provide and the process of awarding qualifications and accreditations.

In accordance with the requirement of the Data Protection Act 1998 we would impose restrictions and standards in our written contract with them in order to ensure they keep your personal information secure and that they use it only for the purpose for which we provide it to them. If these businesses are outside the UK, the section “Will my personal information be transferred outside the UK?” below will be relevant.

We may be required by law or for tax or other purposes to disclose your personal information to local or central government authorities or official agencies. We may be required by law or legal process (i.e. by a court or tribunal) to release it to other external organisations. We may also release it to parties to which you authorise us to release it. In addition, there may be circumstances in which it is necessary for us to disclose your personal information to external companies or organisations in order to protect our customers or our own interests but this would be carried out in compliance with applicable privacy laws.

We will not sell your personal information to any third party except where necessary as part of our legitimate business processes (e.g. in the event that our management or administration is to be taken over by an external organisation). Should we do this we would ensure it was carried out in accordance with the Data Protection Act 1998.

Will my personal information be transferred outside the UK and/or Europe?

We may wish to transfer your personal information to the US or to other countries (for example, to an overseas service provider, training product manufacturer, agent or supplier) for the purposes described above. If you are using the Website from outside the UK other laws may apply to your personal information.

We are not subject to local laws applicable in your country and this privacy policy may not be compliant with those local laws. You should not submit your personal information to us unless you accept this position. We may transfer your personal information to the US to Apollo Group, Inc. and/or Apollo Global, Inc. for the purposes described above (including but not limited to the statistical analysis purpose described above).

The Website may be hosted on servers located outside the UK and/or Europe and maintenance and support services for the Website may be provided from outside the UK and/or Europe. This means your personal information may be stored in other countries.

All of this means that your personal information may be transferred to other countries which do not have the same privacy laws as are applicable in the UK and other parts of Europe. However, in order to prevent unauthorised access or disclosure, damage or loss of your personal information, we take suitable physical and electronic, organisational and technical measures to this end, in accordance with our obligations under the Data Protection Act 1998.

In addition, any transfer of your personal information to another country would be carried out in accordance with the Data Protection Act 1998.