Introduction
Welcome to the IBAT College Dublin (‘IBAT’) privacy notice. IBAT takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.
The EU General Data Protection regulation (GDPR) and the Data Protection Act 2018, gives people the right to know what information is held about them, and requires IBAT to ensure that personal information relating to living individuals is handled properly, held in confidence and is protected from inappropriate disclosure to third parties.
As part of our legal obligations we have published Staff, Student and General Privacy notices. Where required local privacy notices will be issued to inform individuals about what personal data is gathered, how it is used, stored and retained.
Data Controller
IBAT College Dublin (“IBAT “also referred to in this notice as “we” or “us”) and is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at: www.globaluniversitysystems.com .
IBAT registered address is: IBAT College Dublin, Wellington Quay Campus, 16-19 Wellington Quay, Dublin 2, Ireland.
Our Data Protection Officer
If you have any questions about IBAT’s privacy policies, please contact the Data Protection Officer at IBAT College Dublin, Wellington Quay Campus, 16-19 Wellington Quay, Dublin 2, Ireland.
E-mail DPO@ibat.ie
How to Use This Privacy Policy
IBAT holds and processes information about many different types of people such as its current, past or prospective employees, visitors to is website, applicants, students and alumni & supporters. It also processes personal information for a variety of reasons. IBAT may also be required by law to collect and use certain types of personal information to comply with statutory requirements. For each category of personal data process you will find the following headings:
• What types of personal data we collect?
• How we use your information?
• What we use your information for?
• Where we collect your information from?
• Who we share your information with?
• How long do we keep your personal information?
• How can you access, amend or take back the personal data that you have given to us?
• How do we store and transfer your data internationally?
• What are cookies and how do we use them?
• How to reject cookies
More information on how IBAT collects and uses personal information can be found in the relevant privacy notices below:
Types of personal information we collect
We collect, use and store different types of personal information about you, which we have grouped together as follows:
Types of personal information | Description |
Publicity Available Data | Details about you that are publicly available, such as on Companies House or elsewhere on the internet |
Marketing Data | Details about your preferences in receiving marketing communications from us |
Consents Data | Any permissions, consents or preferences that you give us |
Usage Data | Information about how you use our website, products and services |
How we use your information
Cookies
This website uses Cookies; for more information on our cookies use, please read our cookies statement on our website: https://www.ibat.ie/cookie-policy.html
Generally
The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.
What we use your information for | Our reasons | Our legitimate interests |
To provide you with information you may ask for | ConsentLegitimate interests | To fulfil enquires you might make of us |
To allow you to register for updates or for notifications of blog posts on our website | ConsentLegitimate interests | To provide you with information that you may request from us |
To allow you to register for events that we may be hosting | ConsentLegitimate interests | To hold events, such as seminars, webinars, open days or corporate hospitality to promote our business and its services |
To allow you to register as a member of our alumni network | ConsentLegitimate interests | To operate and develop our alumni network and the activities of our alumni programme |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Legitimate interests | To provide efficient client care and servicesTo ensure that our technology operates efficiently and without errorTo assess which of our services may be of interest to you and to tell you about themTo develop new products and services and improve existing ones |
To manage our relationship with you which will include notifying you about changes to our privacy notice and our website terms and conditions | Legitimate interestsContract performance | To provide efficient client care and servicesTo keep you updated about changes in the legal terms that apply to the use of our websiteFor record keeping and firm management |
To manage the systems that contain our marketing databaseTo manage marketing preferences and keep our records up to date | Legitimate interests | For data management for marketing and business development purposesTo improve our systems and servicesTo seek feedbackTo seek your consent when we need it to contact you |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Legitimate interestsConsent | To improve our marketing strategy and the services that we provide |
Sharing information with third parties – to facilitate data-gathering to improve our educational services, our website, and our marketing efforts. | Legitimate interests | For the purposes of IBAT’s legitimate business interests such as managing and developing its business |
Where we collect your personal information from
We may collect personal information about you from the following sources:
- Directly from you
- Cookies – see our cookie statement which can be accessed from our website
- Analytics providers, such as Google Analytics
Who we share your information with
We may share your personal information with the following third parties:
- Atlantic Technological University – enrolment and reporting purposes.
- Our agents and service providers who we use to help us with marketing.
- Event organisers (if we are organising an external event which you are attending)
- The police and other law enforcement agencies
- Relevant regulators, including the Data Protection Commission (DPC) in the event of a personal data breach
- Other companies owned or jointly owned by Global University Systems
How long we keep your personal information
Where we use your personal information for marketing purposes we will retain your personal information for so long as we have your consent to do so (where we use your personal information with your consent in order to send you marketing messages) or, in other cases, for so long as we have a legitimate business or commercial reason to do so (unless you ask us to stop).
Where you withdraw your consent to receiving marketing materials or otherwise ask us to stop marketing we will add your details to a suppression list which ensures that we remember not to contact you again.
To withdraw your consent e-mail studentsupport@ibat.ie
If you withdraw your consent to receiving marketing materials or ask us to stop our marketing activities, we will still communicate with you for other purposes in the normal course of any other relationship we may have with you.
International transfers
As a global company, we hold some personal information concerning our suppliers and their affairs within Ireland. We do work with agents and service providers who may process your personal information on our behalf outside the EEA. If your information is processed outside the EEA, we will ensure that it is protected to the same standards as if it were being processed within the EEA by putting in place a contract with our agents and service providers that provides adequate safeguards.
If you require more information or have any queries, please contact our Data Protection Officer at: DPO@ibat.ie
How long we keep your personal information
Your personal data is held securely on InterActive Pro’s alumni and supporter database, which is accessible by a limited number of staff and is secured.
We ensure we have appropriate data sharing agreements in place before sharing your personal data. We do not sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them. InterActive Pro is committed to working in a transparent, ethical, responsible and honest way.
Applicants and Students Privacy Notice
IBAT College Dublin (IBAT) takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.
When processing your Personal Data, IBAT is obliged to fulfil individuals’ reasonable expectations of privacy by complying with the General Data Protection Regulation (the GDPR), the Data Protection Act 2018 (DPA), and other relevant legislation and regulations (collectively “Data Protection Law”).
Purpose of this Notice
This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this notice at any time and we may supplement or amend this notice by additional policies and guidelines from time to time. We will notify you if this notice is amended.
IBAT also referred to in this notice as “we” or “us”) is a data controller (which means we are responsible for deciding how we hold and use your personal information) of your data and is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at https://www.globaluniversitysystems.com .
“Personal data” refers to information relating to a living, identifiable individual. It can also include “special categories of data”, which is information about your racial or ethnic origin, religious or other beliefs, and physical or mental health, the processing of which is subject to strict requirements. Similarly, information about criminal convictions and offences is also subject to strict requirements.
“Processing” means any operation which we carry out on your personal data e.g. obtaining, storing, transferring and deleting.
2. Your personal information
We hold a range of personal data about you, some of which you provide to us direct and some of which we receive from third parties, such as CAO, where relevant. See below for further details of personal data we receive from third parties. Examples of categories of personal data which we hold are: your contact details, prior educational experience/attainment, immigration information (e.g. passport details, language proficiency), where relevant, health information (including any disabilities) and other equality-monitoring data you provide to us. In addition, if you come to study with us, we process data about your academic performance, attendance and progression, and where relevant, breaches of our policies (e.g. academic or other misconduct concerning IBAT -related activities).We also process contact and educational details after you have completed your programme or your activities with us are otherwise terminated.
The purposes for which we process your personal data and the legal basis
When you are an applicant, we process your personal data for the purposes of assessing your eligibility to be offered a place on one of our academic or professional programmes.
If you take up a place at IBAT, we process your personal data for the purposes of providing our academic or professional programmes and related services.
If you are unsuccessful or do not take up a place at IBAT, we will retain your personal data in line with our retention schedules for statistical and audit purposes or in the event of a complaint or an appeal.
We only process data for specified purposes and if it is justified in accordance with data protection law. The table below lists the various purposes for which we process personal data and the corresponding justification for it. Some processing of your personal data is justified on the basis of contractual necessity. In general, this applies to personal data you provide to us to process your application and if enrolled, to monitor academic performance. Without that information, we would be unable to provide you with your chosen academic programme and related support services. Some personal data is also required to fulfil our legal obligations regarding immigration. A failure to provide that information would prejudice your application for a student visa.
No | Purpose | Legal basis/ justification |
1 | Assessing eligibility to undertake our academic or professional programmes. | Processing is necessary for the purposes of taking steps prior to entering into a contract with us |
2 | Supporting applicants through the application process and providing further information on the services we can offer | Necessary for negotiating to enter into a contract and legitimate interests in providing support to applicants |
3 | Provision of academic programmes and related services (including IT and library services). | Necessary for performing a contract, i.e. to provide your chosen academic programme. This can be a contract with us or a contract between you and your home institution (“contractual necessity”) |
4 | Identifying students and assisting them in trying to succeed in their learning via the dashboard system. | Contractual necessity and legitimate interest in assisting our students to succeed in their studies |
5 | Assessment of academic progress and performance (including attendance), and where necessary providing support | Contractual necessity |
6 | Financial Administration (including provision of loans and bursaries) | Contractual necessity |
7 | Administration of extenuating circumstances procedures. | Contractual necessity |
8 | Administration of complaints, academic appeals, interruption and withdrawal, fitness to study and fitness to practice procedures. | Contractual necessity |
9 | Immigration matters. | Necessary for us to comply with our legal obligations in relation to students who hold student visas. Such processing may also be in the public interest. |
10 | Making reasonable adjustments for disabilities and providing relevant support to students with ill health and providing wellbeing support.This includes processing special category information. | Explicit consent. |
11 | Employability Support | Contractual necessity and our legitimate interest in assisting our students and alumni to progress in their careers. |
12 | Regulating IBAT’s community (including dealing with misconduct under our procedures for academic and other misconduct including disciplinary procedures) | Contractual necessity and our legitimate interest in maintaining academic standards and the good order of IBAT community. |
13 | Obtaining payment of fees. | Contractual necessity and our legitimate interest in obtaining payment for the services we provide. |
14 | Protecting our property and assets (e.g. by dealing with misconduct) | Necessary for our legitimate interest in safeguarding our property and assets. |
15 | Providing appropriate I.T. and other infrastructure facilities e.g. a virtual learning environment | Contractual necessity: legitimate interest in providing a proper infrastructure to support the provision of academic or professional programmes and related student services. |
16 | Communicating with students | Contractual necessity and our legitimate interest in marketing IBAT and promoting student welfare. |
17 | Registering alumni to maintain an alumni network | Necessary for our legitimate interests in maintaining an alumni network, and marketing |
18 | To facilitate data-gathering to improve our educational services, our website, and our marketing efforts. Recorded lectures and webinars maybe used for training and marketing purposes at the college’s discretion to improve customer service and experience. | IBAT’s legitimate business interests such as managing and developing its business |
There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter.
Where the basis of processing your personal data is contractual necessity and you fail to provide the personal data in question, IBAT may not be able to process your application or provide you with the programme for which you have applied. A failure to provide immigration-related data may result in failure to obtain a student visa for those students who require it.
Personal data received from third parties
No | Data | Source |
1 | Contact details and attainment. | CAO, call agents |
2 | Your immigration status. | The Irish Naturalisation and Immigration Service (INIS) |
3 | Transcripts – details of programmes undertaken or being undertaken at another institution; attainment. | Another institution and/or secondary/high schools. |
4 | Medical, mental health, accessibility-related and similar information. This is special category personal data. We only obtain this information from third parties if you give us consent to do so or if it’s a matter of life and death. | Another institution, medical practitioners and/or family members |
5 | Your financial status. | Student Loans Company. |
6 | Details of any IBAT -associated complaint | Office of the Independent Adjudicator, and/or Competition & Consumer Protection Commission. |
7 | Information required to assess eligibility for courses i.e. from employers or sponsors. | Employers or sponsors. |
8 | Details as to how you are performing in your apprenticeship job. | Your employer if you are an apprentice |
9 | Details as to how you are performing on placement. | Your placement provider |
10 | Details of performance at a partner institution including attendance and disciplinary issues. | International study abroad or exchange programme partner or collaboration partner. |
Recipients of personal data
On occasion we may need to share your data with third parties. The following table lists what information we may share with whom
No | Recipients | Data which we may share with them |
1 | Companies within the group | Contact details, Course information where students and graduates are interested in entrepreneurship activities and relevant employability activities |
2 | Placement providers | Your CV as well as any accessibility and assistance requirements and related information. |
3 | Co-curricular and/or extracurricular excursion providers | Accessibility and assistance requirements and related information. |
4 | Your employer if you are an apprentice. | Details as to how you are performing in the academic part of your apprenticeship. |
5 | Your employer or sponsor if you are a sponsored student. | Details as to how you are performing and attendance in your course. |
6 | External examiners. | Identification details and exam papers. |
7 | Turnitin. | Identification details and assessment papers in order to detect plagiarism |
8 | Education and Skills Funding Agency if you are an apprentice. | Student details including course and employer information and academic progression. |
9 | End point assessor if you are an apprentice | Identification details and assessment details. |
10 | The Irish Naturalisation and Immigration Service (INIS) | Passport details; contact details; programme details including attendance, placement details and work experience; fees and housing details |
11 | Data processors i.e. third parties who process personal data on our behalf e.g. software providers or marketing service providers | Application details; attendance records or contact details which are not retained by the third party |
12 | Local Authority (including the electorate office). | Contact details and course details where there’s a legal basis. |
13 | Student Loans Company. | Contact details and course details including progression. |
14 | IBAT’s insurers and internal and external auditors, Health and Safety Executive in respect of accidents or incidents connected with the company. | Student details and details in relation to any incident. |
15 | Regulatory bodies, where you are on a professional programme | Contact details, attendance and progression information and potentially disciplinary or fitness to study or fitness to practice issues |
16 | Government agencies i.e. The Revenue Commissioners* | Contact details and potentially other information if requested where there is a legal basis. |
17 | Police*. | Contact details and potentially other information if requested where there is a legal basis. |
18 | Potential employers or other companies requesting a reference or confirmation of qualifications(Your explicit consent will be requested) | Attendance, progression and performance details including disciplinary or academic misconduct issues or breaches of the IBAT’s regulations. |
19 | Close family, next of kin and emergency services where there is an emergency situation such as illness or serious injury | Personal data including potentially special category data if necessary |
20 | UK and international educational institutions which IBAT partners or collaborates with to deliver placements, study abroad programmes, dual awards, franchised or validated awards or any articulation or progression agreement. | Contact details, attendance, progression and performance details and details of any disciplinary or academic misconduct issues or breaches of IBAT’s regulations |
21 | Higher Education Authority (HEA) and Government Departments such as the Department of Education and Skills for analysis of student data or to carry out statutory functions | Personal details, progression and performance details, details of the Destination of Leavers’ Survey.The privacy notice for the Department of Education and Skills can be found herehttps://www.education.ie/en/Privacy_Information_and_Disclaimer/The privacy notice for HEA can be found here https://hea.ie/about-us/data_protection/ |
22 | External debt collection agencies, in relation to student debts where IBAT’s own recovery attempts have proven unsuccessful | Contact details and details of debt |
* This will only be shared on request and where there is a legal basis for doing so.
Overseas transfers of personal data (i.e. outside the European Economic Area (EEA)
Where possible, we aim to hold personal data relating to students within the EEA. Where any of your personal data is transferred outside the EEA it will be subject to a legally binding data sharing agreement and to an adequacy decision by the European Commission (country, territory or specified sectors), or other appropriate safeguards as set out in Article 46 of the GDPR.
Retention of data
The length of time that we keep your personal data for is set out in the College Data Retention Schedule, please contact DPO@ibat.ie for more information.
Your rights as a data subject
As a data subject, you have the following rights in relation to your personal data processed by us:
• To gain access to your personal data;
• To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
• To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
• To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
• To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
• To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
• To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.
Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month.
Exercising your rights, queries and complaints
For more information on your rights, if you wish to exercise any of the above rights or for any queries you may have or if you wish to make a complaint, please contact;
Written: FutureLearn DPO, 30 Holborn, London EC1N 2LX.
E-mail: dpo@futurelearn.com
Complaints to the Data Protection Commission
The Data Protection Commission is the national independent authority which oversees compliance with tData Protection Legislation. You have a right to complain to the Data Protection Commission (DPC), about the way in which we process your personal data. You can make a complaint on their website https://www.dataprotection.ie/