This notice explains who we are, how and why we collect and use personal information about you, what personal information we hold, our lawful bases for processing, who we share your information with, relevant retention periods and how you can exercise your data subject rights.
If anything does not make sense or if you have any questions about our use of your personal information, please get in touch using the contact details provided.
The Manchester Metropolitan University International College (the International College) is an embedded college, which offers teaching, education and all associated student support services. Throughout this notice, ‘we’, ‘our’ and ‘us’ refer to the International College.
The International College is a joint venture between the following partners:
- Manchester Metropolitan University, a higher education corporation whose address is Ormond Building, Lower Ormond Street, Manchester, M15 6BX (the “University”);
- Manchester Met IC Limited, (company number 14729068) of The Lambourn, Wyndyke Furlong, Abingdon, England, OX14 1UJ to trade as Manchester Metropolitan University International College (the “College”); and
- Navitas UK Holdings Limited (company number 06009965), whose registered office is at The Lambourn, Wyndyke Furlong, Abingdon, Oxfordshire, OX14 1UJ (“Navitas”),
Unless indicated otherwise, the partners have determined that they are joint controllers, as defined under UK data protection legislation.
The personal data we process
We collect and use the following categories of personal data:
- About enquirers and prospective students: name, contact information, date of birth, study preferences. Information is processed by Navitas as an independent controller.
- About applicants: name, contact information, date of birth, qualifications, work experience, personal statement, programme applied for, references, financial evidence of ability to pay tuition fees and living expenses (such as a copy of a bank statement).
- About enrolled students: student ID, academic and English language assessment results, date enrolled, trusted contact information, assessment, study and programme information, attendance monitoring, engagement with student support services (where applicable), complaints, student case management, grievances and exceptional factors information.
- About students in accommodation: any issues or concerns relating to student accommodation.
- About trusted contact, parent and guardian information: name and contact information.
In addition to the above, the International College may need to collect, or you may choose to provide us with information which is classed as ‘special category’. We may ask for your consent to use this type of information. This includes:
- Information revealing your race or ethnicity, religious beliefs, and sex life or sexual orientation (whether or not indicated by your gender or gender identity). Such information will only be processed with your explicit consent and where we need to process it in order to meet our statutory obligations under equality and other legislation.
- Information about your health, including any disability or medical condition, and dietary requirements. We will collect and use this information where it is necessary to make reasonable adjustments and to monitor equal opportunities. Such information will only be processed with your explicit consent and where it is necessary to meet our legal obligations under equality legislation. There may also be situations where we ask for your explicit consent to use and share information about your health.
- The International College may hold information about unspent and relevant criminal convictions and offence information if you have self-disclosed as part of the admissions process or at re-registration. Our use of this information is explained within the University’s specific Criminal Conviction Information Privacy Notice.
- Passport information, visa status, immigration history information, about applicants and students requiring visa support.
Where do we get this personal information from?
We collect this information:
- From you when you express an interest in applying to study with the International College, such as when requesting a prospectus, registering to attend events or making contact with us.
- From you as part of your application to study with the International College, and when enrolling/registering and annual re-registration.
- As collected, entered or observed about you, such as tutor observations, as you engage with the International College during the course of your studies with us, and as we deliver our teaching and education services to you.
- From you as you register, access and engage with the different services or resources that we offer, such as careers advice, library services, IT services, counselling, disability and wellbeing services, pastoral care, and financial support services.
- From third parties in the course of the application and admissions process, for example referees, such as from your previous or current school, college, university or employer, and international agents.
Purpose of the processing
We collect and use your personal information so that we can function effectively as an international college and provide you with the support you require in order to undertake your studies, achieve academic success and meet certain legal requirements. Personal information is needed to provide you with the following services and to undertake the following activities:
- Recruitment and admission activities in relation to the International College.
- Fee and invoice management in relation to the International College.
- Facilitation of accommodation for International College students.
- Visa and immigration support in relation to the International College, including for the purpose of complying with UKVI regulations, such as: attendance monitoring, record-keeping, and reporting.
- To support compliance audits, whether conducted internally or by external entities, related to visa sponsorship.
- Enrolment in International College programmes.
- Provision of the International College pathway programme, teaching, education, and all related student services, such as: academic support and development, academic assessment and supervision, and student support and wellbeing services.
- Management of complaints, student case management and exceptional factors in relation to the International College.
- Management of student data that relates to the purposes of complying with applicable UK higher education regulatory requirements, such as requirements of the Office for Students (OfS), the Prevent duty and safeguarding activities; and
- Facilitation of progression onto the University’s undergraduate programmes following successful completion of an International College programme.
Our lawful bases for processing
We rely upon the following lawful bases in order to use your personal information for the purposes described:
GDPR article 6 Lawful basis for processing personal data
- UK GDPR Article 6(1)b – processing is necessary for the performance of the student contract and/or taking steps with a view to entering into the contract. E.g. recruitment and admissions activities, provision of teaching, education, and all related student services.
- UK GDPR Article 6(1)c – the processing is necessary for compliance with a legal obligation. E.g. applicable UK higher education regulatory requirements in relation to the OfS.
- UK GDPR Article 6(1)d – the processing is necessary in order to protect the vital interest of the student or another. E.g. disclosures in emergency situations.
- UK GDPR Article 6(1)f – the processing is necessary for the purposes of legitimate interests. E.g. disclosure of your personal data to the Students Union by the University.
GDPR article 9 Lawful basis for processing ‘special category’ data
- Ethnicity information - All applicants are asked to provide ethnicity data as a Higher Education Statistics Agency (HESA) requirement – UK GDPR Article 9(2)a – the student has given their explicit consent for the processing, and UK GDPR Article 9(2)g - processing is necessary for reasons of substantial public interest. The substantial public interest: Data Protection Act 2018, Schedule 1, Part2, 8 – Equality of opportunity or treatment.
- Visa support information - UK GDPR Article 9(2)g - processing is necessary for reasons of substantial public interest. The substantial public interest: Data Protection Act 2018, Schedule 1, Part 2, 6 – Statutory etc and government purposes relating to UKVI requirements under the Immigration Act 2014.
- Criminal offence information – UK GDPR Article 9(2)g - processing is necessary for reasons of substantial public interest. The substantial public interest: Data Protection Act 2018, Schedule 1, Part 2, 10 - preventing unlawful acts.
- Disability / reasonable adjustments information – UK GDPR Article 9(2)a – the student has given their explicit consent for the processing, and UK GDPR Article 9(2)g - processing is necessary for reasons of substantial public interest. The substantial public interest: Data Protection Act 2018, Schedule 1, Part 2, 6 – Statutory etc and government purposes – relating to the Equality Act 2010 and reasonable adjustment obligations.
International transfers
During the application process your personal data is captured in our student portal, this is software provided by a company called StudyLink. Your personal data, once in this system, will be hosted through Amazon Warehouse Services (AWS) in Australia, Canada and the UK.
We also use a system called Navigate for student management and Moodle as the virtual learning environment, and personal data is hosted in Australia.
Your financial information for payments uses a system called Oracle and it hosts your personal data in Australia. For day-to-day IT operations such as system profiles, emails, and sharing and storing files, we use Microsoft 365 and it hosts your personal data in Europe, the UK and metadata in Singapore.
Appropriate safeguards are in place to ensure your personal data is safe and secure and all software suppliers are subject to data protection contractual clauses as required.
The recipients or categories of recipients of the personal information
Your personal information is shared between the partners of the International College, in order to provide you with our teaching, education and all necessary associated student support services. Furthermore, your information may be shared with the following third-party recipients:
- Unless you opt-out, the University will disclose your information to the Students Union so you can be registered as a member of the Union and receive the Union’s benefits and services. For further information, please refer to the Union’s Privacy Policy. To opt-out, please contact: [email protected].
- To agents assisting the International College with admissions (limited to what is strictly necessary for the performance of the agent’s role), this may include the disclosure of personal data outside the European Economic Area.
- To the International College’s insurers and external regulators, such as the Health and Safety Executive in respect of accidents or incidents.
- Where applicable, to accommodation providers, on a case-by-case basis where concerns, complaints and grievances are raised.
- To your trusted/emergency contact and the emergency services in respect of emergency situations, for example where your physical or mental health or wellbeing, or safety is at risk.
- To potential employers and other educational institutions requesting a reference for a current or past student (consent is implied by providing the International College’s details as a referee). This includes confirmation of awards.
- To our IT providers supplying, supporting and hosting our IT services, and other data processors acting on behalf of the International College.
- To the Office for the Independent Adjudicator (OIA), if you raise a complaint.
- To our banking and online payment processing service suppliers.
- To suppliers offering plagiarism checking services, such as Turnitin and other academic institutions to identify instances of collusion in relation to plagiarism misconduct.
Where the International College uses third parties to support us and provide services on our behalf (acting as processors), a written contract will be put in place to ensure that your information will be held in accordance with the requirements of UK data protection legislation and that such data processors have appropriate security measures.
Parents, family members and other guardians are considered to be third parties and your information will not be disclosed to them unless you have given your consent for relevant information in certain circumstances to be shared, or we believe the disclosure is otherwise made in accordance with UK data protection legislation.
Your data subject rights
Unless indicated, the partners of the International College act as joint data controllers, as such you can submit your rights requests to any one of the partners and we will work together to service your request and provide you with a response. Under UK data protection legislation, you have the following data subject rights:
- The right to be informed – the International College seeks to collect and use your personal information in a transparent manner. We fulfil this right through the use of privacy notices, such as this main International College Privacy Notice and our other privacy notice information provided at the point of collecting your information.
- The right of access - Unless relevant exemptions apply, you have the right to be told whether we hold your personal information and, if so, to be given a copy of it. This is known as the right of access or subject access. The right exists to support individuals to be aware of, and verify, the lawfulness of the processing by organisations.
- The right to rectification - If you believe that the information we hold about you is inaccurate or incomplete, please contact us and we will investigate. If your information is inaccurate, we will rectify it. If it is incomplete, we will complete it. Once we have determined what we are going to do, we will contact you to let you know.
- The right to erasure - also referred to as the right to be forgotten. This right is not absolute and applies only in certain circumstances. If you submit a request, once we have determined whether the right applies and what we are going to do, we will contact you to let you know.
- The right to restrict processing – this right is not absolute and applies only in certain circumstances. If you submit a request, once we have determined whether the right applies and what we are going to do, we will contact you to let you know.
- The right to object – this right is not absolute and applies in certain circumstances. Where applicable, in the first instance, please use unsubscribe links in any of our communications or use the contact information we provided within the specific privacy notice used at the point of data collection. If you submit a request, once we have determined what we are going to do, we will contact you to let you know.
- The right to withdraw consent – where we collect, use and share your personal information with your consent you have the right to withdraw consent at any time. To do so you are encouraged to refer back to the specific contact information in the privacy notice that we provided to you when we collected your information or when we sought your consent to use your information in a specific way. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the use of your personal information conducted in reliance of other lawful bases. You may also use the contact information under the heading ‘How to contact us’ to withdraw your consent.
How long do we retain your information?
We will retain your personal data, in relation to the following categories of information, for the following retention periods:
- Information relating to unsuccessful and non-enrolled applicants of the International College - one year from the end of the academic year of application.
- Information relating to enrolled International College students: End of registered student relationship plus six years – for majority of information, includes engagement with student support services, programme progression information, complaints and grievances etc.
Please note – that the joint controller relationship ends upon the termination of the student relationship with the International College plus six years. Personal data may continue to be held by the University as an independent controller where the student enrols as an undergraduate student at the University. Please see the University’s Student Privacy Notice for further information.
- Retention of the core International College student record by the University as an independent controller: Indefinitely for the servicing of transcripts and reference requests.
How to contact us
You may contact the International College partners using the following information:
- Manchester Metropolitan University – [email protected], Address: Data Protection Officer, Data Protection, Ormond Building, Metropolitan University, Lower Ormond St, Manchester M15 6BX, United Kingdom.
- Manchester Met IC Limited and Navitas UK Holdings Limited – [email protected], Address: Data Privacy Manager, The Lambourn, Wyndyke Furlong, Abingdon, OX14 1UJ, United Kingdom
Right to lodge a complaint with the supervisory authority
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) as the supervisory authority for data protection. We would encourage you to use our internal complaints procedure through our Data Protection Officer and Data Privacy Manager, prior to contacting the ICO.
Please contact: [email protected] or 0303 123 1113. For any further contact information please see visit the ICO website.
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.
This privacy notice was last updated on 22 October 2024.