Privacy statement

1. Introduction

This Privacy Statement forms part of the Terms of Use and Terms and Conditions of Booking of Trinity College London.

This Privacy Statement provides information about the different types of personal data that we collect and the ways in which we use it. It applies to all those who visit our Sites and interact with us online through our websites:

(our “Sites” and each a “Site”).

This Privacy Statement also applies to personal data collected in connection with exam booking process by means of a printed form which you (or the person who fills it on your behalf) has downloaded from the Sites or has obtained by participating in a Trinity event or webinar.

Access to each Site and the use of information contained in each Site is governed by the relevant Terms of Use. If you book an exam, order products or register for training you will also be subject to specific terms and conditions of booking which are for the protection of both you and Trinity College London, so we advise that you please take the time to read them carefully. In addition, you are advised to read our Data Protection Policy. The contents of the Sites, including their terms and conditions, are subject to change by us without notification to you. We accept no responsibility or liability for keeping the information in the Sites up to date or for any failure to do so.

We are not responsible for the content or privacy practices of other websites. Any external links to other websites are clearly identified as such.

2. Our role

Trinity College London is the data controller in respect of any personal information we collect about you.

As a data controller, we are committed to protecting your privacy at all times in accordance with all applicable laws and regulations governing the use or processing of personal data, including (where applicable) the General Data Protection Regulation (“GDPR”) and any subsequent data protection legislation, whichever is in force in the UK at the relevant time.

By simply visiting our Sites, you do not disclose, nor do we collect, personal data about you.

3. When and what personal information do we collect?

(a) When you visit our Site(s)

The information collected about your visits to our Site(s) is limited to technical data such as for example:

(i) the Internet address (or IP address) of the device you used to access the Sites;

(ii) whether you reached the Sites using a search engine or if you clicked a link on another website;

(iii) the type of web browser you used; and

(iv) the type of device you used to access the Internet.

We use this data for administrative and statistical purposes as well as to help us improve our Sites. More information about the technical information we collect about your visits to our Sites and the purposes for which we collect it can be found in our Cookie Policy.

Most websites use cookies in order to improve the visitor experience by enabling that website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’). Cookies may be set by the website you are visiting (‘first party cookies’) or they may be set by other websites who run content on the page you are viewing (‘third party cookies’). For further information on Internet browser cookies please see our Cookie Policy.

(b) Information you give to us directly

We will collect certain personal information about you when you interact with us, for example when you complete an online form on one of our Sites (including our online “Contact Us” forms and/or when you subscribe to our newsletter), or a printed form which you (or the person who fills it on your behalf) have downloaded from the Sites or obtained by participating in a Trinity event or webinar, when you respond to a survey, when you register as a user on our Site(s), where you post entries on our online forums and every time you send us an email of contact us by other means.

We may collect the following information from you:

  • Your full name and contact details, including email address, postal address, telephone number;
  • Other information about your application provided on your application form;
  • Information necessary to verify your identity, such as the details and/or a copy of your passport, driving licence or other identity documentation;
  • Profile information if you register on our Site(s);
  • Information about your communication preferences;
  • Payment information, when you make a payment through our Site(s), by telephone or, if via an app, through the App Store and Google Play;

If you take one of our Secure English Language Test exams, for example for visa and immigration purposes, private hire licences or for university admission, we will collect your photo, full name, candidate ID, date of birth, nationality, ID type, ID number, gender, exam name, exam date, certificate issue date, exam centre, result, unique electronic reference number, agent name and address, and the pdf certificate of award. We will also record and store information about your personal identity using biometrics and voice identification verification equipment to help verify your identity. We do this to prevent examination fraud. We will use CCTV recording equipment to record the exams. We do this to confirm the identities of exam participants, for examiner and centre staff training and standardisation purposes and to combat examination malpractice. We retain all footage and recordings for up to 24 months after which they will be destroyed.

(c) Information we obtain indirectly

Your personal information may be shared with us by third parties. For instance, we may receive it from your training provider.

4. Special categories of data

Data protection law recognises certain categories of personal information as sensitive and therefore requiring more protection. These categories of data include information about health, ethnicity, and political opinions.

We may collect and/or use special categories of data in connection with the provision of our services, for example in order to make adjustments for any disabilities you may have. We may also collect ethnicity data from you (should you choose to provide it) to identify and keep under review the existence or absence of equality of opportunity or treatment. As explained above, if you take one of our Secure English Language Test exams, we will collect biometric and/or voice recognition data about you in order to verify your identity. We will only process these special categories of data if there is a valid reason for doing so and where the data protection laws allow us to do so.

5. Children’s Privacy

The Sites are not intended for use by individuals under 13 years of age and so, if you are under 13, you must not use our Sites or provide any personal information to us without the express consent of your parent or guardian.

If you are under 13 years of age, we may need to verify your parent or legal guardian’s consent for your use of the Sites and/or your registration for an exam.

6. How we use your personal information

We may use your personal information for one or more of the following purposes (depending on the nature of our relationship, and whether you are just visiting our Sites, interacting with us online or booking an exam):

  • providing, improving and personalising our services and our Sites;
  • providing you with information and news about our exams, products and programmes of events, such as our syllabuses, publications, webinars or conferences, if you have requested to receive our newsletters or if you are our existing or former customer.
  • dealing with your enquiries and requests or those made on your behalf by anyone who booked your exam or bought one of our products on your behalf;
  • considering and processing your application for one of our exams, and communicating with you in connection with your registration and examination results, including by providing you a copy of your exam certificate if you successfully pass your exam. This may also include updating your national learner record where relevant or necessary;
  • carrying out necessary checks to verify your identity, as may be necessary as part of our exam registration process;
  • fulfilling an order you make to purchase any products from us
  • providing booking services when you register for our events;
  • retaining a record of incoming and outgoing communications (e.g. e-mail, telephone call). Information in the e-mail we receive and send will not be disclosed to any third party without the permission of the sender unless otherwise in accordance with the applicable data protection laws;
  • providing you access to downloadable support resources (if available on the relevant Site);
  • inviting you to participate in marketing and academic surveys, if you have specifically consented to receive such communications or if you are our existing of former customer;
  • administering registered user records;
  • verifying and carrying out financial transactions in relation to payments made by you;
  • administering our online forums (when such functionality is available on our Site(s));
  • generating anonymous reports about the use of our Sites and our services (including about qualifications);
  • to further our charitable aim in general;
  • to satisfy legal obligations which are binding on us;
  • for the prevention of fraud or misuse of service; and
  • for the establishment, defence of enforcement of legal claims.

7. Marketing communications - Opt-in and Opt-out

Trinity College London operates a strict ‘opt-in’ policy for individuals. That means we will not send you any information unless you have requested to receive e-mail/text/social media message updates from us.

For legal entities, such as companies, limited liability partnerships and other incorporated organisations, Trinity College London operates, in compliance with the relevant data protection laws, an ‘opt-out’ policy. This means that we will continue to contact such businesses with news and information of our goods and services until we are informed that this communication is no longer required.

If you (whether an individual or a legal entity) wish to be removed from our direct marketing list and do not wish to receive any further information from us (opt-out) you can inform us of this by clicking on the link at the bottom of each email communication you receive from us, or by emailing us at unsubscribe@trinitycollege.com. Once this information is received we will remove you from our direct marketing database.

8. Lawful processing

We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. The following are applicable, depending on the context:

(a) Consent

Where you have provided your consent for our use of your personal information in a certain way, for example where we ask for your consent to send you our newsletter.

(b) Legal obligation

Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject e.g.to comply with our obligation to provide reasonable adjustments to candidates with disability.

(c) Contractual relationship

Where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract), for example to provide our examination services to you.

(d) Legitimate interests

We rely on this basis where applicable law allows us to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced, and does not unduly impact your rights. For instance, it is in our legitimate interest to process personal data of any person who contacts us with an enquiry, in order to respond to such enquiry.

9. Sharing your Personal Data

We will not sell, rent or lease your personal information to others.

We will only share personal information we collect from you with:

  • our national and local representatives who deliver information and services in relation to our exams in your locality;
  • the schools, colleges, education centres, local authorities and any other entity that provide training courses preparing for a qualification awarded by us, to the extent necessary to provide them with information about your results;
  • those persons or bodies contracted by us to carry out the roles of examiner, marker, advisor, moderator, tutor, consultant, representative or other similar roles on our behalf in the context of our provision of qualifications;
  • the service providers we engage to process results data and produce qualification certificates on our behalf;
  • our marketing automation tool service providers, for the purpose of managing email lists and issuing communications on our behalf;
  • as required by law any government bodies or agencies, for example we may share it with the Home Office in connection with the verification of your test results for visa and immigration purposes, with Transport for London in connection with the grant of private hire driver licences, with a university or the University and Colleges Admissions Service (UCAS), for admission purposes. We may be required to share certain information with the Department of Education for statistical purposes.

For Arts Award advisers and prospective advisers registering via artsaward.org.uk, some of the information you supply will be used by:

  • training agencies, trainers, moderators and Bridge organisations who advocate and deliver Arts Award training and support, and engage with you as an Arts Award adviser.
  • Arts Council England and the Bridge organisations, for the purpose of monitoring and reporting information about our Arts Award activities including adviser, candidate and supporter engagement with the programme;
  • Upstart Projects for the purpose of profiling and consulting with young people who have achieved an Arts Award or Trinity qualification.

For Arts Award supporter organisations registering via www.artsawardsupporter.com, some of the information you supply will be publicly available or shared with:

  • Arts Award centres or advisers, Arts Council England, Bridge organisations and Upstart Projects for the purposes of managing registrations and communicating with Arts Award supporters, promoting supporter offers and for monitoring and reporting engagement in the programme

For learners in England and Wales only:

  • some of the information you supply will be used by the Skills Funding Agency to fulfil its statutory functions, issue/verify your Unique Learner Number (ULN) and update/check your Personal Learning Record.


We may disclose your personal information to selected third party processors (such as agents and our suppliers) but only in connection with our own processing purposes, as outlined above in paragraph
6. Any such third party will be required to use any personal data they receive from us in accordance with our instructions and the applicable data protection laws.

We reserve the right to disclose your personal information to third parties:

  • in the event that we buy or sell any business or assets, in which case we will disclose your personal information to the prospective buyer or seller or such business or assets;
  • if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
  • for auditing purposes e.g. finance audits where we employ chartered accountants;
  • if we are under any legal or regulatory obligation to do so (for example as required by our regulator, Ofqual, or the Information Commissioner’s Office); and
  • in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.

10. Payment transactions

Credit card online payment transactions from SELTbooking.trinitycollege.co.uk, musicbooking.trinitycollege.co.uk and www.trinityrock.com are either handled via Paypal or Barclaycard SmartPay. We are not responsible for the contents of their privacy policies, which can be found at:

Paypal: www.paypal.com/en/webapps/mpp/ua/privacy-full

Barclaycard SmartPay: www.barclaycard.co.uk/content/dam/barclaycard/documents/business/top-nav/Barclaycard-Business-commercial-payments-privacy-notice.pdf

Downloads and payment transactions relating to the app showcased on www.trinityrock.com/app are either handled by Apple via the App Store, or by Google via Google Play. We are not responsible for the contents of their privacy policies, which can be found respectively at www.apple.com/uk and policies.google.com/privacy.

11. International data transfers

As we sometimes use third parties to process personal information, it is possible that personal information we collect from you will be transferred to and stored in a location outside the UK or the European Economic Area (EEA).

Please note that certain countries outside of the UK or EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred, stored, and/or otherwise processed outside the UK or EEA in a country which does not offer an equivalent standard of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information. If you have any questions about the transfer of your personal information, please contact us.

12. Security of Data

Trinity College London takes seriously its security obligations in respect of your personal data under the data protection laws in order to prevent unauthorised access to, or alteration or destruction of personal data in our possession.

We will endeavour to take all reasonable steps to protect your personal information. All the personal information we collect is stored securely on servers and we use secure internet protocols and secure networks to protect data collection and processing.

Any payment transaction from our Sites will be encrypted. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see paragraph 15 below for our contact details).

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

13. How long do we keep your personal information?

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Information which is necessary to verify or confirm exam results may be kept by us indefinitely. For further detail about the periods for which we retain personal data and the criteria determined for setting these periods, please see our Data Retention Policy.

14. Your rights

Where we rely on your consent to use your personal information, you have the right to withdraw your consent.

Under certain circumstances, by law, you have the right to:

(a) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it.

(b) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

(c) Request erasure of your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

(d) Object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object if we are processing your personal information for direct marketing purposes.

(e) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.

(f) Request the transfer of your personal information to another party.

If you decide you do not wish to receive any further emails from us, please tell us and we will remove you from the mailing list. At any point you can request to unsubscribe from our mailing by contacting us using the details listed at paragraph 15.

If you would like to exercise any of the above rights, please:

  • email, call or write to us (see paragraph 15 below);
  • let us have proof of your identity (a proof identity). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
  • let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

15. Contact us or the ICO

Please contact us if you have any questions about this privacy policy or the information we hold about you.

If you wish to contact us, please contact:

The Data Protection Officer
Trinity College London
dpo@trinitycollege.com

You can also contact the Information Commissioner’s Office on 0303 123 1113.

16. Changes to this Privacy Statement

From time to time we may update this Privacy Statement. When we do, we will publish the changes on the Sites. If material changes are made to this Privacy Statement we will notify you by email or by placing a prominent notice on the Sites.

Trinity College London trusts that you appreciate that we respect and value your right to privacy, and that our honesty and integrity shall mean that you will continue to trust us with your personal data, knowing that we will not use it for any inappropriate purpose.

 

Version

Details of amendments

Date

0.1

Arts Award details updated

25 July 2018

  

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