Privacy Notice for Higher Education Access Tracker (HEAT)

This privacy notice explains who we are, how and why we collect and use personal information about you, what personal data is collected and held about you for the Higher Education Access Tracker (HEAT), our purposes and lawful bases for processing, who we share your personal data with, relevant retention periods, and how you can exercise your privacy rights.

This notice provides information that compliments the information contained within the Destination Tracking Data Collection Form, which learners used to volunteer their personal data to the University for learner tracking activities. Please read this notice to understand our practices and if you have any questions please contact us using the contact details provided below.

Who we are

Throughout this notice, “University”, “we”, “our” and “us” refer to the Manchester Metropolitan University, an exempt charity under Schedule 2 to the Charities Act 1993 (amended by the Charities Act 2011). The University is the Controller in respect of the personal data you provide as part of this activity.

The University is registered as a Data Controller with the Information Commissioner’s Office (ICO). We manage personal data in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and the University’s Data Protection Policy.

The personal data we process

If you attended an outreach event or activity organised by the University and supplied us with your personal data using our destination tracking data collection form we will process the following personal data about you:

name
gender
date of birth
post code
school
links to the activities which you engaged with
links to Universities and Colleges Admissions Service (UCAS) and Higher Education Statistics Agency (HESA) data.

The purposes of the processing

As part of our activities to promote and widen access to higher education, we upload your personal data to the HEAT system so that it can be used for the following purposes:

monitoring and evaluating the effectiveness of our outreach and widening participation programmes
demonstrating the impact of our outreach and widening participation programmes
producing statistics, including event application and participation numbers, and participant outcomes
tracking future outcomes of event participants, including applications to the University and other higher education institutions
understanding the student journey through education and progression to Higher Education / future careers

If you contact us, we may also keep a record of that correspondence as part of our legitimate interests.

What is HEAT?

HEAT is the system supplied, hosted and operated by the University of Kent, which is used by over 80 higher education institutions to evaluate the effectiveness of their outreach and widening participation activities. The University has used the HEAT system for several years. The system links closely with government agencies such as the Office for Students (OfS), the Department for Education (DfE) and data custodians including the Higher Education Statistics Agency (HESA) to establish which learners engaging with the University have progressed into higher education.

The use of HEAT is a condition of being part of the OfS funded National Collaborative Outreach Programme (NCOP), which the University leads for the region through the Greater Manchester Higher collaborative partnership (GMH).

Lawful bases for processing

For all learners engaging from the start of the 2019/20 academic year – as a public authority acting in the public interest we rely upon the ‘public task’ lawful basis to process your personal data for these purposes. Our public interest is to: promote and widen access to higher education, particularly among underrepresented groups.

Our clear basis in law is the Higher Education (Access and Participation Plans) (England) Regulations 2018. S2(1)(f) which states that Higher Education Institutions shall monitor and evaluate their compliance of its provisions set out in its access and participation plans, and its progress in achieving its access and participation objectives. Furthermore, s2(1)(g) states that Higher Education Institutions shall provide the Office for Students with such information as it may reasonably require from time to time regarding the contribution that the institution has made towards furthering equality of opportunity.

For all learners engaging prior to the start of the 2019/20 academic year we obtained your written consent via our destination tracking data collection and consent form to process your personal data for the specified purposes.

The recipients or categories of recipients of the personal data

Once uploaded to HEAT your personal data is made available to the following third parties:

The University of Kent under the terms of a data processing agreement; as part of the HEAT service they provide for the University they support the HEAT system, and conduct monitoring and evaluation activities.

Other higher education institutions who also organise outreach activities and add HEAT data to the system.

HESA, UCAS, DfE and OfS to help determine whether our activities are helping participants move on from school into higher education and employment.

We use the services of GekoEngage to help us collect this information. For further information about GekoEngage, please see their privacy notice.

The right to withdraw consent, request erasure, opt out of the processing

You can ask for your personal data to be withdrawn from the HEAT system at any time by writing to [email protected] stating your name, date of birth and school you attended while participating in our outreach activities. If we relied upon your consent for our processing, withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.

Data retention

Your personal data will only be retained for as long as it is necessary in accordance with the University’s Retention and Disposal Schedule. Specifically, we will retain your HEAT personal data for:

Destination tracking data collection forms – for 12 months from the date you completed your form and volunteered your personal data to the University
On the HEAT system until you reach 30 years of age, or if you go to university in this time for 15 years after you graduate from university
Until you ask us to remove your personal data

Your rights in respect of the processing

As well as the right to withdraw consent (if provided), the right to erasure and the right to object as set out above. The GDPR provides data subjects with the following data subject rights:

The right to be informed – this privacy notice, along with the original privacy notice information contained within the destination tracking data collection form you completed assists with fulfilling these obligations
The right of access
The right to rectification
The right to restrict processing

Further information about your rights visit data subject’s rights. To exercise these rights please write to us using the contact information provided below.

Contact us

For questions or concerns about this privacy notice, or our use of your personal information, please contact [email protected] in the first instance.

Our data protection officer can also be contacted using [email protected], by calling 0161 247 3884 or in writing to:

Data Protection Officer
Legal Services
All Saints Building
Manchester Metropolitan University
Manchester
M15 6BH

Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint with the ICO as the supervisory authority in respect of the processing of your personal data.

We would encourage you to expend our internal complaints procedure through our initial contact and the University data protection officer, prior to contacting the ICO.

Updates to this privacy notice

We may update this privacy notice from time to time in response to changing legal, technical or business developments. When we update our privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.