Alef Trust Privacy Statement
Alef Trust takes your privacy seriously and we will only use your personal information to maintain communications, to complete the process of course or programme registration and to maintain your enrolment as a student. Alef Trust deals with all personal information provided, in a responsible manner that respects personal privacy and is in full compliance with the Data Protection Act 1998 (DPA) and the General Data Protection Regulation (GDPR). Although the DPA/GDPR are UK and EU regulations, Alef Trust applies the same high standards for the protection of your privacy and personal information, regardless of where you are located. Additional information on the Alef Trust Privacy, Data Protection and other Policies can be found by visiting our Privacy & Data Protection Page. If you have any questions about how Alef Trust collects or uses your personal information, please use the form below to contact our Data Protection Officer.
This privacy statement explains how Alef Trust (“we”, “our”, “us”) collects, uses and shares your personal data, and your rights in relation to the personal data we hold. This privacy statement concerns our processing of personal data of past, present and prospective students of Alef Trust (“you”, “your”).
Alef Trust is the data controller of your personal data and is subject to the Data Protection Act 1998 (DPA) and the General Data Protection Regulation (GDPR). This Privacy Statement covers the following topics related to the protection of your information and privacy:
- Your Rights
- Who To Contact if You Have Any Questions
- How We Collect Your Information
- The Types of Information We Collect
- How We Use The Information We Collect
- The Basis for Processing the Information We Collect
- Sharing Information with Others
- International Data Transfers
- How Long Your Information is Kept
1. Your Rights
Under the DPA & GDPR you have the following rights:
- Right to Information (Art. 13) – to be informed of which data we collect, where, how it will be used, our legal basis for collecting this data, how you can rectify, access or delete your information, and how to contact our Data Protection Officer or to raise a complaint.
- Right to Access (Art. 15) – to obtain access to, and copies of, the personal data that we hold about you;
- Right to Rectification (Art. 16) – to require us to correct the personal data we hold about you if it is incorrect;
- Right to Erasure (Art. 17) – to require us to erase your personal data;
- Right to Restrict Processing (Art. 18) – to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- Right to Portability (Art. 20) – to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
- Right to Object to or Cease Collection (Art, 21) – to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights;
- Right to File a Complain – if you are not satisfied with how we are processing your personal data, you can make a complaint to our Data Protection Officer through the contact form below, or file a complaint with the Information Commissioner.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
If you have given your consent and you wish to withdraw it, please contact our Data Protection Officer using the contact form at the bottom of this page. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.
2. Who To Contact if You Have Any Questions
If you have any questions about how Alef Trust deals with your data or privacy, or if you would like to request to have your data updated, provided to you or deleted, please use the contact form at the bottom of this page to contact our Data Protection Officer.
3. How We Collect Your Information
We may collect your personal data in a number of ways, for example:
- from the information you provide when you contact us before joining, for example when you express your interest in studying at Alef Trust;
- when you apply to study at Alef Trust and complete the enrolment forms and when you complete other admissions processes and procedures;
- when you communicate with us by telephone, email or via our website, for example in order to make enquiries or raise concerns;
- in various other ways as you interact with us during your time as a student of Alef Trust, for the various purposes set out below;
- from third parties, for example from your previous or current school, sixth form college, university or employers who may provide a reference about you or who may sponsor your studies.
4. The Types of Information We Collect
We may collect the following types of personal data about you:
- your name, and contact information such as address, email address and telephone number, as well as your date of birth, national insurance number (or other tax identification number) and your passport number or national identity card details, country of domicile and your nationality. We will also allocate you a unique student number;
- information relating to your education and employment history, the school(s), sixth form college(s) and other colleges or universities you have attended and places where you have worked, the courses you have completed, dates of study and examination results. We will also keep records relating to assessments of your work, details of examinations taken, your predicted and actual examination grades and other information in your student record;
- information about your family or personal circumstances, and both academic and extracurricular interests, for example where this is relevant to the assessment of your suitability to receive a bursary or in order to provide you with appropriate pastoral care;
- sensitive personal data and information including:
- information concerning your health and medical conditions (e.g. disability or learning needs);
- information about your racial or ethnic origin; religion or similar beliefs; and sexual orientation.
5. How We Use The Information We Collect
The purposes for which we may use personal data (including sensitive personal data) we collect during a student’s association with us include:
- recruitment and admissions;
- degree certification, granting, validation and accreditation.
- academic matters, including:
- the provision of our core teaching, learning and research services (e.g. registration, assessment, attendance, managing progress, academic misconduct investigations, certification, graduation);
- maintaining student records;
- assessing your eligibility for bursaries and scholarships, etc.
- providing Learning Management System, IT and other technical services;
- administering finance (e.g. fees, scholarships and bursaries);
- other administrative purposes, including:
- carrying out research and statistical analysis;
- carrying out audits (e.g. to ensure compliance with our regulatory and legal obligations);
- promoting our services (e.g. providing information about summer/retreat programmes, student exchanges, research subject opportunities;
- dealing with grievances and disciplinary actions;
- dealing with complaints and enquiries.
6. The Basis for Processing The Information We Collect
We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following:
- to interact with you before you are enrolled as a student, as part of the admissions process (e.g. to send you a prospectus or answer enquiries about our courses);
- once you have enrolled, to provide you with the services as set out in our Student Agreement;
- to deal with any concerns or feedback you may have;
- for any other purpose for which you provide us with your personal data.
We may also process your personal data because it is necessary for the performance of our tasks carried out in the public interest or because it is necessary for our or a third party’s legitimate interests. In this respect, we may use your personal data for the following:
- to provide you with educational services which may not be set out in our Student Agreement but which are nevertheless a part of our academic and educational mission;
- to monitor and evaluate the performance and effectiveness of Alef Trust, including by training our staff or monitoring their performance;
- to maintain and improve the academic, corporate, financial, estate and human resource management of Alef Trust;
- to promote equality and diversity throughout Alef Trust;
- recovering money you owe to us;
- for fundraising purposes.
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data for the following:
- to meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws and safeguarding requirements;
- for the prevention and detection of crime;
- in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
We may also process your personal data where:
- it is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional);
- it is necessary to protect your or another person’s vital interests; or
- we have your specific or, where necessary, explicit consent to do so.
The legal basis for our collection of student data:
- is covered under Article 6 and Article 9 of the GDPR;
- the Education Act 1996;
- Regulation 5 of The Education (Information About Individual Pupils) (England) Regulations 2013
7. Sharing Information With Others
For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with certain third parties. You are given the opportunity to opt out of some of these data sharing arrangements, for example when you register with us. However, information sharing with our partner institutions is essential and unavoidable for degree programme registration, validation and completion.
Unless an opt-out is in place, we may disclose limited personal data to a variety of recipients including:
- our partner institutions (which include the Professional Development Foundation and its partner Middlesex University, as well as Liverpool John Moores University) for degree validation/accreditation.
- our employees, agents and contractors where there is a legitimate reason for their receiving the information, including:
- third parties who are contracted to provide IT or Learning Management System services for us;
- organisations operating anti-plagiarism software on our behalf (such as Turnitin®);
- internal and external auditors.
- those with an interest in tracking student progress and attendance, including:
- student sponsors (e.g. the Student Loan Company, research sponsors, Research Councils, NHS);
- current or potential education providers;
- current or potential employers (to provide references and, where students are sponsored by their employer and/or where you take part in a placement, to provide details of progress/attendance);
- professional and regulatory bodies (e.g. The Scientific and Medical Network, Professional Development Foundation, British Psychological Society, Solicitors Regulation Authority, Bar Standards Board, Association of Chartered Certified Accountants) in relation to the confirmation of qualifications, professional registration and conduct and the accreditation of courses;
- government departments and agencies where we have a statutory obligation to provide information (e.g. the Higher Education Funding Council for England (HEFCE), the Higher Education Statistics Agency (HESA), the Home Office (in connection with UK visas and immigration), Council Tax and Electoral Registration Officers at relevant local authorities (for the purpose of assessing liability for Council Tax and for electoral registration purposes));
- crime prevention or detection agencies (e.g. the police, the Department for Work and Pensions and Trading Standards);
- parents, guardians, and next-of-kin (where there is a legitimate reason for disclosure);
- third parties conducting surveys, for example the National Student Survey;
- we may also send you details of those products or services that we offer that we have identified as likely to be of interest to you. This will be in accordance with the preferences that you indicated when you completed the application form or the online form;
8. International Data Transfers
Some of the personal data we process about you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), for example where it is processed by staff operating outside the EEA who work for us or for one of our suppliers, or where personal data is processed by one of our suppliers who is based outside the EEA or who uses storage facilities outside the EEA.
In these circumstances, your personal data will only be transferred on one of the following bases:
- where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission);
- a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
- there exists another situation where the transfer is permitted under applicable law (e.g. where we have your explicit consent).
9. How Long Your Information is Kept
Subject to any other notices that we may provide to you, we may retain your personal data for a period of six years after your association with us has come to an end. However, some information may be retained indefinitely by us in order to maintain your academic record for archiving purposes.