Privacy policy

University of Portsmouth Online Ltd is a recognised affiliate college of the University of Portsmouth run in partnership with CEG Digital Ltd to promote and deliver a selection of its online programmes.

CEG Digital Limited is a subsidiary of Cambridge Education Group Ltd.

University of Portsmouth Study Online respects your privacy and is committed to protecting your personal data.

This privacy notice aims to give you clear and detailed information about:

• how University of Portsmouth Study Online collects and processes your personal data
• the legal grounds allowing us to do so
• how we look after your personal data
• your privacy rights
• your choices regarding the personal data we collect about you

1. Who is responsible for your personal data

University of Portsmouth Study Online will be responsible for your personal data as a data controller under data protection law.

We are registered with the Information Commissioner’s Office (ICO) with reference number ZA762833. You can contact us using the information below:

Full name of legal entity: Portsmouth Online Ltd

Name or title of DPO: Lisa Tyler

Email address: DPO@ceg-uk.com

Postal address: 51-53 Hills Road, Cambridge, CB2 1NT

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details above.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which they 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:

• Identity Data includes first name, last name, username, student ID number, marital status, title, date of birth, gender, photograph, curriculum vitae (CV), covering letter, academic record, employment history and references, complaints instigated by or made against you, disputes which involve you.
• Special Category Data includes details about your race or ethnicity, religious beliefs, information about your health, genetic and biometric data (we have in place safeguards for processing such data including confidentiality agreements and restrictions on access to such data).
• Criminal Conviction Data includes details about any unspent criminal convictions and offences (where not covered by Section 1 (1) of the Rehabilitation of Offenders Act 1974) (we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data).
• Contact Data includes your home address, email address and telephone numbers
• Financial Data includes payment reference and identification details
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• 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 when accessing our website or any of the websites of our subsidiaries accessed from that website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our websites and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data includes statistical or demographic data which we may collect, use and share for any purpose. Where Aggregated Data can directly or indirectly identify you, we will use it in accordance with this Privacy Notice.

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 provide you with education services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case.

3. How is your personal data collected?

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

a.  Direct interactions

You may give us your personal data by filling in application forms, by sending us your CV and covering letter or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• create an account on our website;
• request marketing information is sent to you;
• apply for one of our courses;
• apply for a job;
• complete a survey; or
• give us some feedback.

b. Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources such as those set out below:

• Educational agents (involves special category data)
• Universities (involves special category data)
• Named Referees
• Providers of technical, payment and delivery services
• Technical Data from the following parties:
  • analytics providers;
  • advertising networks; and
  • search information providers.

c. Automated technologies or interactions

As you interact with our website, 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our separate Cookies Policy for further details.

4. Our legal basis for using 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 it is necessary for us to perform a contract entered into with you or is necessary for us to take steps (at your request) prior to us entering into a contract (CONTRACT).
• Where we have a legitimate organisational interest and use your personal data in a way that you would reasonably expect, and which has a minimal impact on your privacy (LEGITIMATE INTERESTS).
• Where we need to comply with a legal or regulatory obligation (LEGAL OBLIGATION).
• Where you have given us your consent to process your personal data (CONSENT).
• Where there is an emergency situation, for example, if you needed emergency medical treatment (VITAL INTERESTS).

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the processing of Special Category Data or when sending direct marketing communications to you via email or text message.

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.

You have the right to withdraw your consent at any time by contacting us.

5. How we use your personal data

We will only use your personal data for the purposes for which we collected it, need to use it for another reason and that reason is compatible with the original purpose. If you wish to get more information on this 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.

a. Prospective Students and Agents

• To register you on our website, to subscribe you to our services and to correspond with you.
• To correspond with educational agents or representatives where they have submitted an application on your behalf.
• To provide your data to third-party online conversion service where you have started the application process but have not completed it.
• To monitor the quality of calls for training purposes and to support customer service during the recruitment process.
• To provide your data to cloud hosted virtual learning environment (VLE) services (e.g. Moodle or Canvas).

b. Enrolled Students

• To register you for our services as an enrolled student.
• To provide you with ongoing services after enrolment including:
  • provision of core teaching and learning services
  • administration including maintaining student records, processing fees
  • providing services including library, IT and information services and other student support services
• To provide you with ongoing services after enrolment in respect of student welfare.
• To check you are engaging with course content at an expected rate, to support your completion of the course.
• To provide you with reports on your progress and to process student complaints and grievances.
• To carry out internal research and statistical analysis to monitor and evaluate the performance and effectiveness of courses.
• To conduct lesson observations using sound and video recording software to monitor teaching quality for training purposes.
• To assure academic integrity through the use of electronic or cloud-based anti-plagiarism software.
• To take photographs and videos of students for marketing purposes. (including for use in brochures, on our website and in promotional videos)
• To use examples of students’ work in class for the improvement of teaching and learning practice. Some items may be named.
• To enable University of Portsmouth Online Ltd companies to provide
  • (i) application and admissions services
  • (ii) core teaching and learning services
  • (iii) student administration services and (iv) student welfare services.
• To provide your data to financial or government sponsors of a course and CEG Digital university partners.
• To provide your data to HM Revenue & Customs for reporting of financial processing activities.
• To provide your data to service providers worldwide who provide IT and system administration services and cloud hosted virtual learning environment. (VLE) services (e.g. Moodle & Canvas)
• To deliver and record lessons, lectures or webinars online using cloud-hosted sound and video. (e.g. Microsoft Teams)
• To provide your data to professional advisors subject to a duty of confidentiality. (e.g. lawyers, bankers, insurers, auditors)
• To provide your data to the relevant authorities regarding a safeguarding concern or in connection with the prevention or reporting of a crime.

c. All visitors to website

• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
• To use data analytics to improve our website, services, marketing, customer relationships and experiences and to make suggestions and recommendations to you about services that may be of interest to you.
• To provide your data to specialist service providers worldwide acting as processors who provide Finance, IT and system administration services that cannot be provided internally.
• To provide your data to third parties to whom we may choose to sell, transfer or merge parts of our business as our assets as part of our business strategy.

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.

6. Marketing and managing preferences

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased 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 Portsmouth Online Ltd for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing a service or other transaction.

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 further information on this, 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.

7. Third Party Data Disclosures

We may have to share your personal data with the parties set out below for the purposes set out in this notice;

Internal Third Parties

Cambridge Education companies acting as joint controllers or processors and who are based in the UK, the Netherlands, Sweden, the US and China and provide (i) application and admissions services, (ii) core teaching and learning services, (iii) student administration services and (iv) student welfare services.

External Third Parties

• Educational agents
• Government and Corporate Financial Sponsors and Embassies
• CEG Digital university partners
• HM Revenue & Customs, regulators and other authorities acting as processors
• Service providers worldwide acting as processors
• Cloud-hosted VLE providers
• Electronic or cloud-hosted providers of anti-plagiarism software
• Professional advisers worldwide acting as processors or joint controllers
• 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 notice.

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.

8. International transfers

We share your personal data within the CEG Group. This will involve in some cases transferring your data outside the UK. We routinely transfer personal data within the CEG Group based in the UK and/or the European Economic Area (EEA).

There is an agreement (or adequacy arrangement) which permits the free flow of personal data between these territories. For further details of EEA countries, please contact DPO@ceg-uk.com.

Some of our external third parties are based outside the UK and the EEA so their processing of your personal data will involve a transfer of data outside the EEA and the UK.

Whenever we transfer your personal data out of the UK and EEA, 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 by the European Commission (as at the date of this Privacy Notice this applies to Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay).
• Where we use certain service providers, (including providers based in the US, we may transfer data to them lawfully by using specific contracts (Standard Contractual Clauses or SCC’s) [and a Transfer Impact Assessment] approved by the UK Information Commissioner and European Commission which gives personal data the same protection it has in the UK and the EEA.  

Please contact us if you want further information on the lawful basis used by us when transferring your personal data out of the UK and EEA.

9. Data security

The personal data that we collect from you will be stored by cloud providers or third-party services hosted in the Microsoft Azure UK or Western Europe regions. 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 any parties who have a business need to know. They will only process your personal data on our instructions and 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 legally required

10. Data retention

We will only retain your personal information 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. Where a legal requirement obliges the retention of personal data for a specific minimum period, we will retain data for at least that period. Once your personal information is no longer necessary or upon expiry of a specific retention period, we will dispose of it securely according to our data retention and deletion policies.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Details of retention periods for different aspects of your personal data are set out in our retention schedule. Please contact DPO@ceg-uk.com for further information.

11. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access - 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.
• Request correction - 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.
• Request erasure – (commonly known as the “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
• Object to processing - where we are relying on a legitimate interest (or those of a third party) you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms or where we are processing your personal data for direct marketing purposes.
• Request restriction of processing - This enables you to ask us to suspend the processing of your personal data. Please note that this right applies only under certain circumstances i.e. if the processing is unlawful or if you objected to the processing.
• Request transfer – (also known as the “right to data portability”) 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.
• Right to withdraw consent – If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

For further clarification and to invoke any of these rights, please contact us DPO@ceg-uk.com and for more information about your rights, refer to the ICO website: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You will NOT have to pay a fee to access your personal data (or to exercise any of the other rights) unless we deem you request to be clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific or further information from you to help us confirm your identity, ensure your right to access your personal data, to exercise any of your other rights and to speed up our response.

12. Complaints, changes to this policy and third-party links

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

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. When we issue a new version of this privacy notice we will post a message on our websites advising of this.

This website 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Last updated 16 January 2023