Privacy notice

The United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 require institutions to inform their students and other stakeholders about how data about them is used and who it is shared with.

How we use your data

The University of Kent is registered as a ‘Data Controller’ under registration number Z6847902. View the full entry on the register 

The University as the Data Controller of your personal information is subject to the Data Protection Act 2018, the UK GDPR and (where applicable) the European General Data Protection Regulation (EU GDPR). The Student Enrolment Privacy Notice for the University of Kent can be found on the Assurance and Data Protection webpage. 

This Privacy Notice outlines how the University of Kent’s Careers and Employability Service (CES) uses and shares your personal data and outlines your rights in relation to the personal data we hold.

How we collect your personal information

The CES obtains, holds and processes data relating to students and graduates including data received:

·       directly from you, through online or paper forms, email or by telephone

·       from our student data system Kent Vision and through Empower Tracking

·       from organisations who provide students and graduates with work and volunteer placements or who provide mentoring.

Categories of information we collect

Personal data we collect about you in connection with the Empower Scheme:

·       your first and last name

·       your contact details (address, email, telephone/mobile number)

·       your emergency contact’s details

·       job titles and dates of employment

·       employer name and place of work

·       placements undertaken

·       training undertaken

·       employment interests, career and further study ideas. 

We also collect:

·       education and training records, applications and forms relating to schemes, programmes and bursaries administered by the CES including Convention de Stage agreements, Study Plus, mentoring schemes, the Empower Bursary and Employability Points

·       employment, work placement and volunteering information including Empower Scheme applications and contracts of employment

·       your career and further study ideas

·       CVs/applications/practice interviews etc. and any feedback given on them

·       careers and employability event and appointment attendance

·       financial details (for example bank details for wage payments for the Empower Scheme or for Empower bursary payments)

·       student ID (for the Empower Bursary)

·       course, school and year of study (where relevant for Empower bursary or for Scholarship applications)

·       your photo (with your permission for marketing purposes).

Personal data we collect about you in connection with the Graduate Outcomes (previously Destination of Leavers from Higher Education) mailshot:

·       Your name and address

·       Your course completion date.

Special category data we will collect about you:

·      racial or ethnic origin for the purposes of your right to work check

·      physical or mental health data for the purposes of providing you with any necessary relevant support (if applicable)

·      disability, sexual orientation, race or ethnicity information in order to provide you with information about specific opportunities that may be relevant to you.

For employers, professional bodies and professional mentors who engage with the Careers and Employability Service, including the Employability Points Scheme, we will collate and hold the following information:

·       organisation name and business registration information

·       financial details

·       first and last name

·       role

·       contact details (email address, telephone number, social media profile)

·       information in respect to any work, placement or volunteering opportunities.

How we use your personal information

The CES holds the personal data of its students and graduates to:

• manage our processes and services
• offer individuals support that is tailored to their needs
• enable advisers to prepare for and deliver meaningful first and follow up appointments.

The CES will use student and graduate personal data to administer the careers service offered to you including:

• provision of support services in relation to careers development
• monitoring of attendance
• provision of references (where a student or graduate has been employed by us or through us e.g. via the Empower Scheme)
  
• submission of applications within the University and to external employers and other third parties on request of the individual
• providing details of support, mentoring, career opportunities and events available within and outside the University
• maintenance of student records
• financial transactions (e.g. invoices, bursaries and scholarships).

We will also use your data for other administrative purposes, for example where we need to undertake statistical analysis, carry out compliance audits, promote services or answer enquiries.

Information from employers, professional bodies or professional mentors is collected to:

·       provide careers services such as vacancy, opportunity and mentoring promotion, events, careers fairs, presentations and workshops.

Employers, professional bodies and mentors associated with the Careers and Employability Service will receive regular email communication in relation to further opportunities for engagement, whilst other University of Kent departments may contact you in relation to further business-orientated opportunities.

Only information required for these purposes is obtained and processed, and without it the CES may not be able to provide its services to you or to students and graduates.

Our lawful basis for processing your data

We rely on the following lawful basis as allowed by the UK GDPR for processing both student and graduate personal data and employer and third party personal data as this is necessary for providing the careers and employability service:

·      the performance of a task carried out in the public interest or in the exercise of official authority - Article 6(1)(e)

·      a legal obligation – Article 6(1)(c)

·      the purpose of our legitimate interests or those of a third party – Article 6(1)(f)

·      your consent - Article 6(1)(a) (for specific processing activities such as sending you emails about our promotional activities).

The legal basis underpinning our processing of this information includes the Equality Act 2010 and the Higher Education and Research Act 2017 (in particular the requirement to comply with conditions imposed by the Office for Students).

Our legitimate interests are: promotional activities such as running competitions via social media for student engagement purposes (we will ensure your fundamental rights are not overridden).  You may opt out from announcements made on social media or the website.

Where we also use your special category data where it is necessary to provide students and graduates with relevant support, we rely on:

Reasons of substantial public interest– Article 9(2)(g).

Our substantial public interest reason(s) (as defined under the Data Protection Act 2018 are:

o   statutory purposes

o   equality of opportunity or treatment 

·      when you have given your explicit consent for specific processing - Article 9(2)(a)

·      For statistical purposes (when this involves special category data we will pseudonymise the data) – Article 9(2)(j)

We have a Special Category and Criminal Offence Data Appropriate Policy document in place throughout the time that we use your data and for 6 months after we cease to use it.

Who your information will be shared with

For purposes referred to in this privacy notice we may share your personal data with other staff from the University of Kent, Kent’s Student Union and The Hub Medway, and appropriate external trainers, where there is a legitimate reason. Examples include staff who approve and produce documents relating to convention de stage/training agreements, staff who collate or process attendance or employability engagement information for awards such as the Global Skills Award, trainers delivering workshops etc.

We use third party organisations (known as data processors) who carry out services on the University’s behalf under contract. We will ensure that only the minimum amount of relevant personal data necessary for the purpose is transferred. We will ensure that contractual agreements exist to ensure compliance with data protection regulations and that data is used solely under our instruction. In these circumstances personal data shall be deleted after the contract has terminated.

·      Software provider Group GTI who provide our customer relationship management system, Target Connect, where some of the student and graduate personal data mentioned in this privacy notice (personal details, education and training records, employment, work placement and volunteering information, career and further study ideas, CVs, applications, practice interviews etc and any feedback on them, Graduate Outcomes data) is stored securely. If you set your occupational and opportunity type interests within your profile you may be sent communications and opportunities relevant to you, but you can unsubscribe at any time. 

·      Graduates First Shortlister / Career Set / GoinGlobal that students / graduates may choose to access. Students may choose to share their email address if single sign on (sign on using Kent credentials) is enabled and students choose to access the systems. Each system has a privacy notice and if students and graduates are required to provide email addresses or any other information when they use these systems, then they may choose whether to proceed or not.

Data is shared as part of the statutory Graduate Outcomes Survey, co-ordinated by HESA (Higher Educations Statistics Agency).

For more information please see HESA’s privacy notice.

The CES would not share special category data with third party employers or education providers for the purpose of job applications without your agreement.

Sometimes it is necessary for your personal information to be shared:

·      with competent authorities (such as the police, NCA) or Action Fraud for law enforcement purposes (for substantial public interest reasons – Article 9(2)(g) – for preventing or detecting unlawful acts, safeguarding or fraud purposes

·      with our professional advisors where it is necessary for the establishment, exercise or defence of legal claims – Article 9(2)(f).

Occasionally the University may, if appropriate, legitimate and necessary, rely on relevant exemptions to UK GDPR provisions as are allowed under the Data Protection Act 2018 (in relation to crime and taxation, management forecasts, negotiations, confidential references and exam scripts and exam marks).

Transfer of your information outside of the UK

When it is necessary for us to transfer your personal information across national boundaries to a third party data processor, such as one of our service providers, we will ensure this safeguards your personal information by requiring such transfers are made in compliance with all relevant data protection laws.

How long your personal data will be kept

Information will be kept for 6 years (3 years after a student’s graduation).

Security

We will ensure that security measures are in place to prevent the accidental loss of, unauthorised use of or access to your data. Access is given to staff on a ‘need to know’ basis. Our staff are required to keep your data safe and complete data protection training.

We have procedures in place to deal with any data security incidents and will notify you and the ICO in the event of a data breach where we are required to do so.

Your rights

Please be aware of the following rights which can be accessed free of charge by contacting dataprotection@kent.ac.uk:

·      know how we are using your personal information and why (right to information)

·      access the personal data held by us (subject access request)

·      ask for correction of any mistakes (rectification)

·      to object to direct marketing

·      to complain to the ICO.

In some circumstances you also have the right to:

·      object to how we are using your information

·      ask us to delete information about you (the right to be forgotten)

·      have your information transferred electronically

·      object to automated decisions which significantly affect you

·      restrict us from using your information.

For further guidance regarding your rights please see the ICO website.

Your rights- if you have given consent for a specific use of your personal data or explicit consent for a specific use of your special category data

You can withdraw your consent at any time.

You can do this by contacting us at employabilitypoints@kent.ac.uk or by clicking on the ‘unsubscribe’ button within an email we have sent you.

This does not affect the lawfulness of the processing based on consent before its withdrawal.

Your right to complain to the Information Commissioner

You have the right to lodge a complaint with the Information Commissioner's Office.

Their helpline telephone number is: 0303 123 1113.

Contacts

If you have any questions or concerns about the way the University has used your data, or wish to exercise any of your rights, please consult our website.

The University’s Data Protection Officer can be contacted at: dataprotection@kent.ac.uk

 Document review date

This privacy notice will be reviewed at least annually.