BPP Privacy Policy

What is the purpose of this Privacy Policy?

BPP respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on how BPP collects and processes your personal data through:

a. your use of BPP websites or apps, including any data you may provide through BPP websites/apps when you make an enquiry or purchase a product or any course/programme (whether online, face to face or distance learning) and whether on behalf of yourself; as an employer client; as a third party training provider; or as a reseller (“Services”);

b. your registration for, purchase of or use of any BPP products and/or Services (including but not limited to courses, programmes or study materials (in any medium));

c. your use of any BPP social media channel; and

d. the provision of personal data to BPP by any other means.

This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

This Privacy Policy is provided in a layered format so, if you wish, you can select the specific areas of the Policy you are interested in, as set out below. We have also included a Glossary to help you understand the meaning of some of the terms used in this Privacy Policy.

Contents

1. Who we are
2. Important information about this Policy
3. Your personal data
4. How your personal data is collected
5. How we use your personal data
6. Disclosures of your personal data
7. Higher Education Statistics Agency/Jisc
8. Compliance with the Bribery Act and relevant legislation
9. The Hub and VLE
10. Online Learning and Assessment
11. BPP Futures
12. Alumni
13. International transfers
14. Data Security
15. Data retention
16. Your legal rights
17. Glossary

1. Who we are

Data Controller

The BPP Education Group is made up of a number of different legal entities  within the UK, Channel Islands and internationally, the details of which can be found here (the “BPP Education Group”). 

International Entities

In addition to its UK and Channel Island companies, BPP Education Group (via BPP Holdings Limited) is also the parent of companies in Poland, BPP Professional Education Sp z.o.o. (“BPP Poland”) and Romania, Business Training Romania Srl (“BPP Romania”). For further information on BPP Poland, and how it specifically processes personal data, please see BPP Poland’s Website and Privacy Policy.  For further information on BPP Romania, and how it specifically processes personal data, please see BPP Romania’s Website and Privacy Policy.

BPP Education Group (via BPP Holdings Limited) is also the parent of companies in Hong Kong, China, Malaysia and Singapore. For further information please see BPP’s Asia Pacific Website and Privacy Policy.

Other BPP Brands

The BPP Education Group also comprises a number of non BPP-branded entities, both in the UK, Ireland, Canada, North America and Australia. Each of these brands has its own privacy policy (a copy of which is linked below). As these brands are part of the BPP Education Group (which provides centralised operational support for each of its entities), some personal data provided to these entities will be processed in accordance with this Policy (further detail of which is provided throughout this Policy). Therefore this Policy should be read in conjunction with each entities individual policy.

BPP Education Group

This Privacy Policy is issued on behalf of the BPP Education Group, so when we mention “BPP”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the BPP Education Group responsible for processing your data. The table below sets out which BPP entity will be the data controller of your personal data when you use certain BPP websites.

This Policy shall apply to any BPP website including any subdomains that may be made available by us from time to time; including websites with the ending ‘.bpp.com’; and all BPP social media channels (“Website(s)”):

Contact details

We have appointed data protection officers (“DPO”) who  are responsible for overseeing our data protection compliance  If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the relevant DPO using the following details:

For any BPP branded entities, StaySharp Education Limited, Estio Training Limited or Buttercups Training Limited please use:

FAO of the Data Protection Officer
BPP Education Group (or select the relevant BPP entity from the list above)
Legal Team
1 Portsoken Street
London
E1 8BT

Email address: dataprotection@bpp.com

For Firebrand Training, please use:

FAO of the Data Protection Officer
Firebrand Training Limited
27 Old Gloucester Street
London
WC1N 3AX

Email address: privacy@firebrand.training

For Digital Marketing Institute Limited, please use:

Digital Marketing Institute Ltd
Duncairn House,
14 Carysfort Avenue,
Blackrock
Co. Dublin
A94 D4E1
Ireland

Email address: compliance@digitalmarketinginstitute.com

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);

•  the Data Protection Commission, the Irish authority for data protection issues (https://www.dataprotection.ie/);

•  the Office of the Data Protection Authority, the supervisory authority for data protection issues in Guernsey (www.odpa.gg); or

•  the Jersey Office of the Information Commissioner, the supervisory authority for data protection issues in Jersey (www.jerseyoic.org).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO (or other relevant authority) so please contact us in the first instance.

2. Important information about this Policy

Changes to the Privacy Policy and your duty to inform us of changes

This Privacy Policy sets out your rights under the Data Protection Act 2018 and the UK General Data Protection Regulation.

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.

We keep this Privacy Policy under review and may update it from time to time. This version was last updated on 31 July 2024.

If you reject the terms of this Privacy Policy

If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through the Website, apps or any other means.

Third-party links and products

The Website (and apps) 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 policies. When you leave our Website or app, we encourage you to read the privacy policy of every website you visit.

Through the course of your studies you may also be directed to use third party platforms (for example: Turnitin, Kahoot!, Wakelet – learning, Microsoft Co-pilot, LinkedIn Learning, Oracle or Gmetrix for the Microsoft Office Specialist programme).  We do not control these third-party platforms and are not responsible for their privacy policies or responsible for personal data which may be transferred by you to such third parties. When using these platforms, we encourage you to read their terms of use and privacy policy.

3. Your personal data

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:

•  Audio / Visual Data includes recordings from closed circuit televisions systems which are in place at some of our premises for security purposes; telephone recordings (for quality monitoring and training purposes) where you call any of our student facing or sales teams (although not all calls to BPP are recorded); photographs of you for use on ID cards or to be used on registers/your online accounts so BPP staff (such as tutors or exam invigilators) can identify you; audio/video recordings of meetings with Skills Coaches or other performance/progress calls on courses  or programmes (although not all of these types of calls are recorded); recordings (including video, audio and text) where any lecture, seminar, webinar or other interactive teaching session is recorded; video recordings from recorded exams/assessments (including mock exams/assessments); and any video recordings from any recorded interviews (such as credibility interviews and English language interviews for visa compliance purposes).  Please see Online Learning and Assessment for further information.

•  Contact Data includes billing address, delivery address, postal address, email address and telephone numbers.

•  Eligibility Data includes education/academic history, records of qualifications and/or training, personal statements and references and/or (where applicable) documents confirming your right to study in country. For apprentices this will also include national insurance number. For international students this may also include copies of bank statements or other financial information to ensure visa requirements are met.

•  Employment Data (this is relevant where your place on a course or programme is sponsored by your employer/future employer) includes name of employer, job title, line manager name and contact details, work contact details (email address, telephone number and postal address), National Insurance number and employment start and end dates (and for apprentices may include hours of work and job description).

•  Financial Data includes bank account, billing information, payment card details and information from any student loan organisation.

•  Identity Data includes first name, maiden name, last name, student reference number, usernames for BPP sites (including for BPP e-commerce sites, BPP’s Virtual Learning Environment, the Hub, the Alumni Network, other online learning environments (including Adobe Connect or Microsoft Teams), BPP IT accounts (including BPP emails), BPP’s BPP Futures, BPP’s Student Association and Athens) or similar identifiers (including any student registration number assigned to you by an external body who shares information with us such as ACCA/CIMA, UCAS/LawCabs/BarSAS, SRA/BSB), marital status, title, date of birth and gender. It may also include copies of identification documents (such as a passport, driving licence or national identity card) which are used to confirm your identity.

•  Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

•  Next of Kin Data includes the name and contact information of a friend or relative to be used in the event of an emergency involving you. This will also include (for international students) the details of any friend or relative with whom you are staying, as declared on any visa application. It may also include details of relatives you have authorised to communicate with BPP on your behalf or attend BPP events with you, such as graduation ceremonies.

•  Profile Data includes your usernames and passwords (for BPP platforms), purchases or orders made by you, your interests, preferences, feedback, reviews, survey responses and enquiries submitted to BPP.

•  Recruitment Data includes any information you have provided to us (or through a third party such as TribePad, Job Train, Zellis, Indeed, My First Job, LinkedIn or a recruitment agency) in your curriculum vitae, any covering letter, any application form (including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications and reasons for wanting to apply for the relevant position) and any information you provide to us during an interview.

•  Student Data includes the course or programme you are studying with BPP, your years of study, records of achievements on the course or programme (including exam, assessment and mock results), exam scripts, exam transcripts, attendance and progress information, feedback from lecturers or personal tutors (including student references), emails sent by you to BPP, emails sent/ received by you to or from your BPP email address or messages posted on any BPP forums or message boards (including on Teams, Adobe Connect, the Hub or VLE), information relating to your use of BPP’s library and library resources (including materials checked out and overdue items), information relating to your involvement in BPP’s student association (including membership of student groups or attendance of student events), information relating to your involvement in BPP’s mentoring or entrepreneurship schemes, information relating to your involvement in BPP’s alumni network, information relating to your registration for or attendance at any BPP hosted/advertised events, information relating to your use of or involvement with BPP’s BPP Futures, the Hub or Alumni Network, information provided to any BPP student facing Teams (such as Safeguarding, Learning Support or Independent Advice), information relating to allegations of academic misconduct or other matters of discipline/student conduct, information relating to any fitness to practice or fitness to study proceedings, information relating to any application for extenuating circumstances or an academic appeal, any application for deferrals or interruption of studies and any complaints made by you or about you to BPP.

•  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 to access this website or BPP app.

•  Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

•  Usage Data includes information about your visit to a Website or BPP app, including the Uniform Resource Locators (URL) clickstream to, through and from the Websites or apps (including date and time), products and/or services you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page and any phone number used to call our customer services numbers.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

The law requires that “special categories” of particularly sensitive personal information require higher levels of protection than other personal data.

In some circumstances we may also collect, store and use the following “special categories” of more sensitive personal information:

•  Information about your race or ethnicity – this information is collected for equality and diversity monitoring purposes.  We also collect this information on behalf of the Education and Skills Funding Agency (in relation to apprenticeship students) and the Higher Education Statistics Agency in respect of BPP University students (please see section 7 for further information). This information is voluntary.

•  Information about your gender identity – this information is collected in respect of apprenticeship students and BPP University students for equality and diversity monitoring purposes. We also collect this information on behalf of the Higher Education Statistics Agency (please see section 7 for further information). This information is voluntary.

•  Information about your sexual orientation - this information is collected in respect of apprenticeship students and BPP University students for equality and diversity monitoring purposes. We also collect this information on behalf of the Higher Education Statistics Agency (please see section 7 for further information). This information is voluntary.

•  Information about your religious beliefs - this information is collected in respect of apprenticeship students and BPP University students for equality and diversity monitoring purposes. We also collect this information on behalf of the Higher Education Statistics Agency (please see section 7 for further information). This information is voluntary.

•  Information about your nationality and immigration status

1) This information is required to ensure that, where relevant, prospective BPP students have the correct visa or right to study in the UK (or other country as applicable) in order to enrol onto a course or programme. Accordingly, we will collect information such as copies of passports, copies of visas and any relevant correspondence between you and the UK Visas and Immigration department of the Home Office. We cannot enrol any students onto a course or programme (which requires proof of right to study) without completing these checks.

2) This information is also collected in respect of apprenticeship students and BPP University students for equality and diversity monitoring purposes.  We also collect this information on behalf of the Higher Education Statistics Agency (please see section 7 for further information).  Where this information is collected under paragraph 2, it is voluntary.

•  Information about any disabilities or learning needs – 1) this information is collected so that any reasonable adjustments can be made to accommodate students with disabilities or learning needs (for example large print learning materials or exam papers) and also to ensure that any learning needs are supported (for example extra time in exams). This information is voluntary, but BPP will not be able to provide you with learning support/reasonable adjustments if you do not provide this information.

2) This information is also collected in respect of apprenticeship students and BPP University students for equality and diversity monitoring purposes.  We also collect this information on behalf of the Higher Education Statistics Agency (please see section 7 for further information).  Where this information is collected under paragraph 2, it is voluntary.

•  Medical information – this information may be collected where a medical issue is having an impact on your studies with BPP (for example, you may have a prolonged period of absence; or you make an application for an interruption of studies where an illness is preventing you from studying; or where a medical issue has affected your performance in an exam, you may make an application for extenuating circumstances) or if an incident occurs whilst on campus and such information is required for health and safety reporting. It may also include dietary requirements where you are attending a catered BPP event (this information may be provided to BPP via third parties such as Eventbrite). This information is voluntary.

Since the onset of the Covid-19 pandemic, we have also collected certain health information to assist in the prevention of the spread of Covid-19 and safeguard our students, staff and visitors. However, this information is no longer collected.

•  Information about criminal convictions and offences – this information will be collected where it is a legal requirement of the course or programme applied for (for example all student nurses must undergo an enhanced criminal records check in accordance with safeguarding legislation). You will be informed if the course or programme you are applying for requires a criminal records check and be given the chance to withdraw your application should you not agree to such a check being undertaken.

In addition, we will also ask you to provide confirmation of whether you have any unspent criminal convictions as part of the application process. Any declaration will not be an automatic bar to your application, but BPP will have to evaluate the details of such conviction for two reasons. Firstly, to ensure there is no threat to the safety of other students and staff at BPP and secondly to advise whether your conviction is likely to bar you from your chosen profession. Further details regarding how we process criminal convictions and special category personal data is contained in our Appropriate Policy Document.

If you fail to provide 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 enrol you onto a relevant course or programme or provide goods or services to you). In this case, we may have to withdraw your application or cancel/restrict a product or Service you have with us, but we will notify you if this is the case at the time.

4. How your personal data is collected

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

Direct interactions. You may give us your Identity, Contact, Eligibility, Employment, Financial and Marketing and

Communications Data by filling in forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you:

a.     apply for a course or programme;

b.     submit an online query or request a call back;

c.      purchase goods or Services from us;

d.     speak with one of our student advice or admissions teams;

e.     speak with one of our client or supplier services teams;

f.      speak with your tutor or other teaching staff;

g.     make a room (or desk) booking at one of our premises;

h.     sign in to a BPP centre or other venue (such as an exam/assessment centre);

i.       create an account on our Website (including the VLE and the Hub);

j.      download and use any BPP app (including the Hub app);

k.     subscribe to a service or publication;

l.       subscribe, register, take part in or view any BPP webinar or other distance learning session;

m.    are captured on closed circuit television when attending our premises;

n.     request marketing to be sent to you;

o.     enter a competition, promotion or complete a survey; or

p.     give us feedback.

Through your Studies. You may give us your Student Data throughout your time on a course or programme. This includes personal data you provide when you:

a.     attend lectures, seminars, webinars or other learning sessions (including where these are online);

b.     submit work for assessment (including mocks);

c.      take exams or other forms of assessment (including mocks);

d.     submit any applications or complaints relating to your studies (for example, extenuating circumstances applications);

e.     raise any issues or questions with your lecturer / personal tutor; or

f.      contact one of our student advice teams for support (including Safeguarding or Learning Support).

Automated technologies or interactions. As you interact with our Website or apps, 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. Please see our cookie policy for further details.

Third parties. We may receive personal data about you from various third parties as set out below:

•  Contact, Eligibility, Employment and Identify Data from your employer where your employer/future employer is sponsoring your place on a BPP course or programme (including apprenticeships and traineeships) ∆;

•  Contact, Eligibility and Identify Data from third party education applications providers (including UCAS, LawCabs, BarSAS etc.);

•  Student Data and Identity Data from any other education provider with whom BPP has subcontracted any element of the teaching of your course or programme (particularly relevant to apprenticeships) ∆;

•  Student Data and Identity Data from any other BPP entity within the BPP Education Group in order to refer you for different products/services or to assist in your academic progression (e.g. referring you from a level 4 Estio apprenticeship to a level 5 BPP apprenticeship); or to provide centralised support (e.g. apprenticeship recruitment/onboarding) ∆;

•  Contact, Eligibility, Employment, Identity, Next of Kin and Student Data from third party training providers/employers where BPP is acting as a subcontractor/main provider for any element of the teaching of your course or programme, from a third party training provider/employer.  This is particularly relevant to apprenticeships ∆;

•  Contact, Eligibility, Employment, Identity, Transaction and Student Data from third party training providers or resellers where such third party has purchased courses (including online courses) from BPP to resell ∆;

•  Contact, Eligibility, Employment, Identity, and Student Data from a third party which BPP collaborates with for the purpose of creating, and/or marketing, and/or delivering tailored programmes or courses (such as our Level 5 Coaching Apprenticeship) ∆;

•  Contact, Eligibility and Identity Data from third party apprenticeship/traineeship recruiters (including Get My First Job, LinkedIn, Job Train, the Princes Trust, Career Connect and Talent Match) ∆;

•  Identity, Contact, Eligibility, Transactional and Student Data from any external awarding bodies or professional membership bodies which you may be registered with in order to enrol onto or complete the course or programme you are studying with BPP (including ACCA, CIMA, CIPD, ICAEW, ICAS etc.) ∆;

•  Identity, Contact and Eligibility from any third party supplier we use in our student onboarding processes, such as Onifido.∆

•  Identity and Student Data from any third party assessment/examination centre (such as Pearson Vue), online exam provider (such as Panopto, Proctorio or Inspera), external exam marker or invigilator (for example where you request to sit a BPP exam abroad; or your course or programme requires an external assessment organisation to provide your final examination/assessment (including end point assessment organisations for apprenticeships); or any organisations which review assessment submissions for plagiarism such as Turnitin) ∆;

•  Contact, Identity, Marketing and Communications, Profile, Recruitment, Student, Technical and Usage Data from any third party portals which are used to provide you with student services, such as the student association (MSL Membership Solutions), student advice (AdvicePro), alumni service (Gravyty); careers service (BPP Futures), online learning (Adobe Connect), sports clubs (British Universities & Colleges Sport) and timetabling (Scientia) ∆;

•  Contact, Identity, Recruitment and Student Data from any BPP University Liaison Office or law society officer who operates at your university and has a contract of sponsorship with BPP and passes data to BPP at your request; ∆

•  Student Data from any freelance tutor, external presenter or third party platform engaged by BPP to deliver teaching/training to you as part of your course or programme.  This includes Gmetrix for the Microsoft Office Specialist (MOS) Programme and Pluralsight ∆;

•  Contact, Eligibility and Identity Data from student recruitment agents (engaged by BPP) who assist BPP in recruiting students and supporting students in submitting applications for courses or programmes to BPP ∆;

•  Identity, Contact, Transaction and Student Data from any third party survey/review organisation or portal provider, such as SurveyMonkey, Evasys, Qualtrics, Smart Survey, Eventbrite and TrustPilot ∆;

•  Data relating to criminal convictions and offences from the Disclosure and Barring Service (and any umbrella body company used to access DBS checks including Agenda Screening Services) ∆;

•  Data relating to any legal complaint or dispute you may have or be involved with from a solicitor acting on your behalf or the Office of the Independent Adjudicator ∆;

•  Technical Data from analytics providers such as Google, Sessioncam, Hotjar and Optimizely;

•  Identify and Contact Data from advertising networks; and search information providers (such as Companies House or LinkedIn);

•  Contact, Financial and Transaction Data from any third party student loan providers including Future Finance, The Student Loans Company, States of Guernsey, States of Jersey and Future Finance ∆; and

•  Contact, Financial and Transaction Data from providers of technical, payment and delivery/courier services (e.g. where you order hard copy study materials) such as SmartDebit, Worldpay, Sage Pay, CourseMerchant, CPG Logistics and Ricoh UK Limited ∆.

5. How we use 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 we need to perform the contract we are about to enter into or have entered into with you.

•  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

•  Where we need to comply with a legal or regulatory obligation.

•  Where we have your consent.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Where we are relying on your consent as a legal basis for processing your personal data, for example where we collect voluntary “special category” personal data (as set out in this Policy above) you may withdraw your consent to this processing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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.

Please be aware that, if you are a student with BPP, in the majority of cases we will have a contract in place with you in respect of the course or programme you are undertaking. Therefore, our lawful basis for processing your personal data will be to perform our contract with you.

However, in some instances we will have a contract in place with your employer or prospective employer. For example, some businesses will ask BPP to deliver a bespoke course or programme to a group of its employees. In these cases, BPP has a contract in place with your employer and not you as an individual. In these scenarios, BPP will process your personal data as necessary for our legitimate interests, i.e. the delivering of services to your employer under a contract in place between BPP and your employer.  This would also apply where you attend you attend BPP courses via a third party tuition provider or reseller, or where BPP acts as a subcontractor to your employer or main training provider.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

Less commonly, we may also process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent (for example if you suffer a medical problem whilst on BPP’s premises).

Consent

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations.

In limited circumstances (as set out above), we ask you for your written consent to allow us to process certain particularly sensitive data. When we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

You should be aware that it is not a condition of your contract/right to study with us that you agree to any request for consent from us. However, we may not be able to provide you with certain services (such as learning support) if you do not agree to provide such data to us.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent.

We will only collect information about criminal convictions if it is appropriate given the course or programme you are seeking to be enrolled onto. For example, students seeking to enrol on courses or programmes which relate to nursing or other medical professions are required to undergo enhanced criminal records checks as these courses will involve students being placed in hospitals, pharmacies and other healthcare environments.

Where appropriate, we will collect information about criminal convictions as part of the application process or we may be notified of such information directly by you in the course of you studying with us. We will use information about criminal convictions and offences in the following ways:

• To ensure our compliance with relevant safeguarding legislation in relation to clinical placements.

We are allowed to use your personal information in this way to comply with our legal obligations. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

•  Where we have notified you of the decision and given you 21 days to request a reconsideration.

•  Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

•  In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do use automated technologies and decision making when deciding what marketing messages you receive.  We also use automated decision making to validate your onboarding identification documents such as passports through the Onfido platform.

We do also use “bots” to automate some of BPP’s administrative services.  Bots are computer programmes made from a series of algorithms that allow them to carry out tasks without specific instructions.  These bots are used to carry out repetitive tasks and attempt to mimic human behaviours.  Therefore, they may be used to collect information for student registration or on boarding (or other administrative tasks). The personal data collected by these bots is processed in accordance with this Privacy Policy and is processed in the same way as if it had been collected by a member of BPP staff.

Artificial Intelligence (AI)

AI refers to computer systems that can perform tasks which require human intelligence. This includes complex functions such as problem-solving, reasoning, and decision-making. As an education provider, we’re constantly evolving to equip students with the skills they need to succeed in their career. This includes adapting to and incorporating new technologies into training and education. Programs such as BPP Adapt use machine learning to measure your strengths and identify focus areas to improve your knowledge.

As part of our initiative to raise awareness about the use of Generative AI and it’s use cases in an educational context, we encourage all students to undertake BPP’s new Generative AI awareness course which provides students and learners specific information relating to their studies and assessments that may incorporate the use of AI.

BPP will continue to incorporate AI, where appropriate, into our education and services (including AI used in third party services) but will ensure that it complies with applicable data protection legislation.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a preference centre where you can view and make certain decisions about your personal data use. If you agree to receive marketing from us, you will receive a link to the preference centre by email.

The preference centre is not available for some actuarial courses/programmes and in respect of some client bookings and customer purchases.  Where the preference centre is not available you will not receive a link to the preference centre.  Instead your marketing opt-in preferences will be collected when you register, book a course/programme or make a purchase.  You can opt out of receiving marketing at any time by replying to the sender of the marketing communication with the word “UNSUBSCRIBE”.

If you do not agree to receive marketing from us, but change your mind at a later date, you can contact us and update your marketing preferences.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or 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 BPP Education Group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time.  For BPP entities you can do this by logging into the preference centre and checking or unchecking relevant boxes to adjust your marketing preferences. Alternatively (and for all BPP Education Group companies) you may opt-out by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you entering into a contract with us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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.

Communications with BPP students

For some courses/programmes (typically BPP University courses/programmes), students will receive their own BPP email address (ending @bpp.com) or be granted access to the Hub or VLE (please see section 9 for more information).  Where you have a BPP email addresses or access to the Hub/VLE (and are a current student) BPP will use these to communicate with you, especially where we need to disclose personal information to you (such as exam results).  This is to ensure the security of your personal data. 

It is therefore important that you check your BPP emails and the Hub/VLE regularly.

You may choose to contact BPP using your personal email address, but please be aware that any responses containing personal data will then be sent to your BPP email address or via the Hub/VLE. 

Please be aware that BPP may monitor emails sent from or received to your BPP email address (or messages sent to or from your Hub/VLE account) and these may be used in relevant proceedings (including, but not limited to: evidence in formal university proceedings such as academic/non-academic misconduct hearings, formal complaints or appeals, academic appeals, extenuating circumstance boards or legal or other regulatory proceedings).  BPP may also delete emails/messages in limited situations (such as where an email/message constitutes a personal data or confidentiality breach).  

Please also note that to fulfil our data retention and minimisation obligations under data protection legislation your BPP email account will be disabled 12 months after you complete or withdraw from your studies. 

BPP may also monitor your use of BPP Wi-Fi (when on BPP premises) in line with its legal duties under safeguarding and Prevent legislation.

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.

•  Internal Third Parties as set out in the Glossary.

•  External Third Parties as set out in the Glossary.

•  Specific third parties marked with ∆ listed in paragraph 4 above (under the ‘Third parties’ heading).

•  Specific third parties listed in paragraphs 7 to 12 below.

•  Your parent or guardian if you are under the age of 18 (or if you specifically request us to liaise with your parent or guardian on your behalf).

•  Your parent or next of kin if there any immediate concerns regarding your physical health/safety or mental wellbeing.

•  External venues where some element of a course or programme (including assessments or graduations), or an event, is delivered (BPP may share Identity Data with the venue for registration and health and safety purposes).

•  Counselling services, where you make a specific request via the Student Advice Team (BPP may share Identity and Contact Data).

•  Turnitin, an academic plagiarism checker (BPP may share Identity and Student Data with Turnitin).

•  Any suppliers who organise ticketing, robes and photography for BPP University graduations (BPP may share Identity, Contact and Student Data with such suppliers).

•  Current/future employers or education providers where you specifically request that we provide confirmation of Identity or Student Data to those parties for reference purposes.

•  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 Policy.

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. Higher Education Statistics Agency/Jisc

We will send some of the information we hold about you to the Higher Education Statistics Agency, which merged with Jisc on 4 October 2022 (“HESA”). This information forms your HESA record, which does not include your contact details.

Your Contact Data may be passed to survey contractors to carry out the National Student Survey, the Graduate Outcomes Survey and surveys of student finances. These organisations and their contractors will use your Contact Data only for that purpose and will then delete your information.

After you graduate we may contact you to ask you to complete one or more surveys into the outcomes of higher education and your activities after graduation. These surveys may be undertaken by us or by another specialist organisation contracted for that purpose. If a specialist organisation is used that organisation will receive your Contact Data but will only use your details for the purpose of asking you to complete the survey, and will then delete them. You may also be contacted as part of an audit to check that we or any contracted organisation have undertaken these surveys properly.

If you do not want to take part in any of these surveys, please let us know.

Submission of your personal information to HESA

Every year we will send some of the information we hold about you to HESA. HESA is the official source of data about UK universities, higher education colleges, alternative higher education providers, and recognised higher education courses.

HESA is a registered charity and operates on a not-for-profit basis. Your HESA information is used for a variety of purposes by HESA and by third parties and full details of these are set out in HESA’s Student Collection Notice. A copy of HESA’s current Student Collection Notice (for the 2023/2024 academic year) is available here and updated versions are available here.

8. Compliance with the Bribery Act and relevant legislation

In this Privacy Policy, we have explained that your personal data may be used for the purpose of ensuring compliance with legal obligations and that it may be disclosed to BPP’s group companies’ service providers or governmental departments. This includes for the purpose of enabling BPP’s group companies to comply with the US Foreign and Corrupt Practices Act 1977 (“FCPA”) and enabling BPP to comply with its obligations under the UK Bribery Act 2010 (the “Bribery Act”), the Criminal Finances Act 2017, The Money Laundering, Terrorist Financing and Transfer of Funds(Information on the Payer) Regulations 2017, Proceeds of Crime Act 2002  and any other local laws or regulations relating to similar purposes which relate to fraudulent, illegal or unethical behaviour (the “Conduct Legislation”).

BPP’s group companies may appoint one or more service providers to assist them in managing a whistleblowing helpline and a webpage which acts as a reporting mechanism (“Helpline”) to ensure compliance with Conduct Legislation.

It is possible that a BPP staff member or student may report matters of concern through the Helpline and that your personal data may be used by BPP’s group companies, its service provider(s) which manage the Helpline and by BPP for the purpose of investigating any such report and taking remedial action thereafter. For example, if a BPP employee suspects that another employee is misusing company records for his own purposes or is committing fraud involving your personal data, they may report this through the Helpline.

Should this happen, your personal data will only be used for the purpose of ensuring compliance by BPP’s group companies with the relevant laws and regulations. Wherever reasonably possible, your personal data will be anonymised prior to use for the purpose of investigations and remedial action so that it does not relate to you. However, in some specific circumstances this may not be possible as it may prohibit a full investigation and prevent compliance with a relevant regulation or Conduct Legislation. Any transfers to BPP’s group companies and their service provider(s) which manage the Helpline and which may also be in the US or elsewhere in the world will be carried out in accordance with the law.

A limited number of specially trained employees from BPP’s group companies will only have access to your personal data which is disclosed through the Helpline where and to the extent that this is necessary for the purposes of carrying out their roles and for the purpose of compliance. In any event, their access will be limited, secure, controlled and justified as BPP considers is fair and necessary in the circumstances. These employees will be subject to appropriate confidentiality obligations.

We encourage our employees to use the Helpline in good faith and only for serious or substantial issues which cannot properly be reported via other means.

Provided reports are made through the Helpline in good faith, we try to protect the confidentiality of your identity as far as is reasonably possible. However, we cannot guarantee this (especially in subsequent court or tribunal proceedings) and we are required to inform the subject of the reports about the allegation(s). Those subjects have the right to request their own personal data, as do you, as set out under Your Legal Rights.

9. The Hub and VLE

BPP provides an online learning experience to students and to selected sponsoring employers through the Hub and a Virtual Learning Environment (“VLE”). These online learning platforms are also accessed by BPP staff in order to deliver courses and programmes to students. Within the platforms the following data sharing is in operation:

•  Your name, last log-in date, campus location and course or programme may be shared with other users of the platforms.

•  The above details will be searchable to other platform users, and you can be messaged through the platforms by other users based on your platform user name.

•  You may also elect to share your photo, a short biography and personal email address with other users (this is voluntary).

•  Your participation in online sessions (such as webinars, online teaching, forums or chatrooms), including your text, audio or video content may be recorded and shared.

•  The platforms may plug in to other software/platforms used by BPP (such as Panopto, Century Tech or Inspera) where these platforms/software are used to provide training or assessment services to you.

•  Third Parties chosen by BPP may review your interaction with the platforms to help BPP continuously improve the service.

•  Exam or assessment results (including mocks) in the platforms may also be combined to derive benchmarks of performance to allow students to assess their performance in their chosen programme. These will only be presented in aggregate and individual results will not be disclosed.

•  Any assignment or assessment uploaded or completed through the platforms will be shared with the appropriate BPP staff for the purposes of assessment. Assignments/assessments may be sent to third parties for the purpose of ensuring the work is original, attributes sources correctly and does not infringe on any existing copyright (see references to Turnitin in paragraph 6 above).

•  Platform data relevant to assessing your progress within the course or programme may also be shared with your sponsoring employer or third party tuition provider.

10. Online Learning and Assessment

BPP uses a suite of platforms and software to provide students with online learning and assessment services.  The most notable of these are Adobe Connect and Microsoft Teams (for teaching) and Inspera, Questionmark, Totara, and Panopto for assessments.

Online Learning

Students should be aware that, whilst taking part in online learning sessions your tutor and other students in the session will be able to see you (if you enable video), hear you (if you enable your microphone) and see any text that you have typed into the chat box.  Although it is optional to have these features enabled, some tutors may request that these are enabled to improve the experience of all students (to make it more like traditional classroom learning); or to ensure you are able and actively participating in the session (including any group work).

You should also be aware that online sessions may be recorded and shared via the Hub or VLE as a revision aid or so that students who have missed the session are able to catch up. In addition, some recorded sessions may be shared within BPP for training and monitoring purposes, including (where applicable) with specific regulators in the field of education as part of their monitoring/audit functions.

Online Meetings

Students should also be aware that there will be occasions when online meetings may take place between them and BPP staff. This is particularly relevant for apprenticeships where apprentices will have regular check ins with their apprenticeship coach (which may also be attended by their line manager) but also may apply when you contact other BPP departments for advice (such as Learning Support or Student Advice)

Where minutes of a meeting are required (which again will be the case for apprenticeship coaching meetings), BPP may record and/or transcribe these meetings for quality and monitoring purposes. In each case, you will be made aware of any such recording or transcribing at the outset of the call.

Through the course of your studies, information you disclose to Career Coaches/Consultants may be passed onto relevant programme staff, if deemed necessary to further progress your learning and development. An example of this is where a student or an apprentice learner sees a Careers Consultant or coach for a 1:1 careers appointment, and the Careers Consultant or Coach needs to discuss the meeting with a BPP coach/tutor where it is essential to advance the student or learner’s progress. This applies to both online and face to face meetings.

Online Assessments

Students should be aware that some online assessment platforms include remote proctoring (you will be made aware in advance where your exam will be proctored remotely and provided with further information and instructions for use).  This means that you will be filmed (video and audio) for the duration of your exam and will be required to provide a video of your surroundings at the start of the exam.  Therefore, please ensure you remove anything from view that you would not want recorded (such as personal photographs, documents or other members of your household).

You will be asked to show a form of photographic ID at the start of the online exam (this may also include end point assessments where you are an apprentice).  Where you have a BPP student ID you must use this as your ID document.  If you do not have a BPP ID you may use a passport, driver’s licence or other national ID card (which has a photograph).  Please be aware that any information contained in your form of ID will be captured so may include data such as your nationality and if applicable, biometric data.

Recordings of your exam may be used in formal university procedures (such as any allegation of academic misconduct, extenuating circumstance applications, academic appeals or formal complaints).

Your exam answers will be processed in the same way as hard copy exam scripts would be and as set out in this Policy.

11. BPP Futures

The BPP Futures Service offers services to students, learners, recent graduates and to selected employers.  Information on the services offered for BPP students is available here and for employers is available here.

In order to access some of the services you will need to create a BPP Futures account (“BPP Futures”).  The Careers Service webpages explain which services can be accessed via BPP Futures. Within the BPP Futures you can undertake the following activities:

Please be aware that, for the services marked with an *, this will involve accessing third-party websites and/or submitting your personal information to third parties.  For example, where you apply for a job with a third-party employer, any data you submit via BPP Futures will be passed to that third party so they may assess your application.

If you do not wish to share your information with third parties, then do not submit any information via BPP Futures in respect of the services marked with a * above.  If you have any questions regarding the use of your information or the relevant third party it is submitted to, please contact the Careers Service by email at careers@bpp.com.

For all other BPP Futures services (not marked with an *) any personal information you submit will be processed in accordance with this Policy.

12. Alumni

BPP offers an Alumni Network Service to university students (and for some students on longer professional qualifications courses).  Information on the Alumni Network is available here.

Students eligible for the Alumni Network will automatically be enrolled into the Alumni Network. BPP’s Alumni Network is operated via a third party platform provider, Gravyty.  In order to access some of the Alumni Network services you will need to create and access a Gravyty account. Please be aware that where you choose to sign up using a third party social media platform, personal information (including profile photos) from such platform may be used by Gravyty, and in newsletters, in accordance with their privacy policy (see further information below).

Within the Gravyty platform you can undertake the following activities:

Any personal data submitted via the Gravyty platform (such as Profile Data, Identify Data, Marketing and Communications Data, Technical Data and Usage Data) will be processed by Gravyty (in addition to BPP).  You can find out more information on how Gravyty processes your personal data (including a copy of their terms of use and privacy policy) by clicking on the “Info & Support” tab on the Gravyty platform.  Additionally, you are able to change what personal data is shared on the Gravyty platform under the “Settings” tab within the platform.

Please be aware that, for the services marked with an *, this will involve accessing additional third party websites and/or submitting your personal information to additional third parties.  For example, where you apply for a job or volunteering opportunity with a third party employer, any data you submit via Gravyty will be passed to that third party so they may assess your application. Please be aware that BPP may also use your information from Gravyty in marketing materials which may also be shared with third parties.

13. International transfers

As set out in this Policy, we share your personal data within the BPP Education Group (including outside of the UK).

However, we may also share your personal data with suppliers of IT services (including BPP’s IT support and third party software and learning platform providers).  Therefore, we will transfer some of your data outside the UK.

The Websites, apps and/or any products and/or Services may be hosted on servers located outside of the UK and maintenance and support services for the Websites, apps and/or those products and/or Services may be provided from outside the UK.  This means that your personal data may be transferred to, stored and processed in other countries apart from the UK and the Channel Islands.

Whenever we transfer your personal data out of the UK, 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;

•  We may use the UK extension to the EU-US Data Privacy Framework to send data to the US.

•  We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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

14. Data security

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.

As set out in paragraph 13 above, your personal data may be held on the IT system of BPP, BPP’s group companies (e.g. for the purpose of providing training or educational services to you) and/or on the IT system of another third party company (within or outside of BPP) within or outside the UK which is providing IT hosting or other data processing services, in accordance with BPP’s arrangement in place with that company.

All information that you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Websites or apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

15. Data retention

How long will you use my personal data for?

We will only retain your personal data 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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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.

Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request by contacting us.

As an education provider BPP will hold details of your transcript (i.e. your name, years of study, course or programme name, sponsoring employer, assessment and/or exam marks and final grade or award) indefinitely.

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.

16. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

•  Request access to your personal data

•  Request correction of your personal data

•  Request erasure of your personal data

•  Object to processing of your personal data

•  Request restriction of processing your personal data

•  Request transfer of your personal data

•  Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

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.

17. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal Third Parties

Other companies in the BPP Education Group acting as joint controllers or processors and who are based in and outside the UK and provide administration services and undertake leadership reporting.

External Third Parties

•  Your employer, acting as an independent controller, where your employer/prospective employer is sponsoring your place on a course or programme (or where your employer/prospective employer has arranged for a course or programme to be delivered to a group of its employees/prospective employees).  We will share information relating to your attendance, performance (including exam/assessment results and mock exam/assessment results and if applicable, recordings of coaching and performance calls) and general behaviour/performance on the course/programme.

•  Any other education provider/employer where BPP is the subcontractor or main provider for any element of the teaching of your course or programme. We will share information relating to your performance (including mock and actual assessment results), progress and attendance on the course/programme.

•  Any other tuition provider/reseller where BPP is providing training services to you through your contract with that third party training provider or reseller.  We will share information relating to your performance (including mock and actual assessment results), progress and attendance on the course/programme.

•  Any third party which BPP collaborates with for the purpose of creating, and/or marketing, and/or delivering tailored programmes or courses (including Grant Thornton).

•  Service providers acting as processors based outside the UK who provide IT and system administration services (including Endava, New Rocket, Administrate, Salesforce, Groove and Slack) and those within the UK (including Ellucian/Banner),

•  Service Providers providing identity and access management solutions (including OpenAthens and Sophos Connect).

•  Service providers which act as processors in respect of our telephone call recording operations (Vonage).

•  Service providers which act as processors in respect of providing security services, including monitoring of closed circuit television systems in place at our premises (Platinum Security) and security personnel (Kings Guarding Solutions).

•  Third party platforms which act as processors in respect of providing education and learning materials (including Pluralsight, Script, and Oxford University Press).

•  Other venues or assessment centres you may attend as part of your studies with BPP, including assessment (such as exam halls, placements or graduation centres).

•  Professional advisers acting as controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

•  Debt recovery agents (including Oriel Collections and High Court Enforcement Group) where you owe a debt to BPP.

•  HM Revenue & Customs, the UK Home Office, regulators and other authorities acting as independent controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

•  Specific regulators in the field of education, including the Education and Skills Funding Agency (for apprenticeships and traineeships), The Federation for Industry Sector Skills and Standards (for apprenticeships), Ofsted, The Office for Students, The Quality Assurance Agency (or any successor organisations to the preceding) acting as independent controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

•  Any professional body where this is relevant to the course or programme you have studied (for example, for students completing the LPC or BPTC/BTC (or any similar or replacement programme), BPP will confirm Student Data with the Solicitors Regulation Authority or Bar Standards Board.) Where relevant to the course or programme you have studied, this may also include the SQA (for more information on how the SQA may process your personal data, their Privacy Statement can be found via the following link www.sqa.org.uk). This includes providing professional bodies with annual data for their own statistics reports (including the BPTC Key Statistics Report) and may include special category personal data, where you have shared this with BPP.

•  The police or governmental body, where the police/ governmental body make a request for personal information (including recordings from closed circuit television) to BPP or as and when we consider necessary for the purpose of crime / fraud prevention.

•  The ambulance service if there is any immediate concern regarding your physical health or mental wellbeing.

GPs, dentists, local councils, Transport for London or the National Union of Students (NUS) wherever you request BPP confirm your student status to these bodies to allow you to register for their services/student discounts.

Your legal rights

You have the right to:

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.  Please note that your rights of data access do not extend to copies of exam scripts or question papers, and exam marks will only be disclosed upon such request where these have already been formally released. In addition, although BPP will provide access to personal data in accordance with its obligations under data protection legislation, BPP will not provide formal transcripts or certificates where students have not fulfilled their course requirements (including the payment of any fees).

Request correction

Request correction of the personal data that we hold about you. 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. Please be aware that this right does not apply to exam scripts or exam marks.

Request erasure

Request erasure of your personal data. 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. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks. It also does not apply to your student record where you have undertaken a University programme or apprenticeship with us.

Object to processing

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. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks. It also does not apply to your student record where you have undertaken a University programme or apprenticeship with us.

Request restriction of processing

Request restriction of processing of 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. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks. It also does not apply to your student record where you have undertaken a University programme or apprenticeship with us.

Request the transfer

Request the transfer of your personal data to you or to a third party. 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.

Withdraw consent

Withdraw consent at any time where we are relying on consent to process your personal data. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.