SOAS University of London

Widening Participation Privacy Notice

  1. Who we are and how to get in touch
  2. What is this document and why should you read it?
  3. What is personal data, and what does processing mean?
  4. What personal data do we collect?
  5. How is your personal data used?
  6. Why do we process your personal data?
  7. Who do we share your data with?
  8. What is Special Category data, and why do we use it?
  9. How long is data retained?
  10. What are my rights?
  11. Updates to this notice

 

Who we are and how to get in touch

SOAS is a provider of higher education. When it comes to information about you, we are a “Data Controller”. That means we decide why and how we store and use your information.

We have appointed a Data Protection Officer whose role is to inform and advise us about, and to ensure that we remain compliant with, data protection legislation. The Data Protection Officer should be your first point of contact if you have any queries or concerns about your personal data.

Our current Data Protection Officer is the Information Compliance Manager, who can be contacted at dataprotection@soas.ac.uk or 0207 898 4817.

If the Data Protection Officer is unavailable, you can contact the Records Manager by email at dataprotection@soas.ac.uk, or by post at the address below:

Information Compliance Office, SOAS University of London, 10 Thornhaugh Street, Russell Square, London WC1A 0XG.

If you think SOAS is processing your data in a way which is unlawful, you can make a complaint to the Information Commissioner’s Office, which is the UK data protection regulator. More information can be found on the Information Commissioner’s Office website at https://ico.org.uk/

What is this document and why should you read it?

This notice explains how and why SOAS processes personal data about you if you take part or tell SOAS you intend to take part in our Widening Participation activities. Broadly speaking there are two types of activity overseen by our Widening Participation team. First, outreach events with groups of individuals who are not yet registered with the School or any other higher education provider, which we hope will encourage interest and applications from groups who are under-represented in higher education, and secondly, activities designed to support the successful continuation of students enrolled at SOAS who are from under-represented groups.

You should read this notice, so that you know what we are doing with your personal data. Please also read any other privacy notices we give you that might apply to our use of your personal data in specific circumstances in the future. These might be notices about how we use your data if you apply for one of our programmes of study, or if you enrol as a student at the School.

What is personal data, and what does processing mean?

Personal data is any information which can used to directly or indirectly identify a person. This includes information that could directly identify you such as name, age, and contact details, but also information that could be used to identify you even if your name is removed, if it is put together with other available sources of information.

The law says that some types of personal data are more sensitive and in need of additional protection. Please see the section below on Special Category Data for more information about this type of personal data. This notice will tell you what types of personal data SOAS needs to process to deliver its Widening Participation activities

Processing is anything that SOAS does with your personal data, including collecting, storing, organising, altering, using, sharing, or destroying the data. This notice will tell you all the different ways in which SOAS uses your personal data and why, who it is shared with, and for how long we keep it.

What personal data do we collect?

If you attend one of our pre-registration events, we will ask you directly for some information to help us understand your background. The types of personal data we could ask for include:

  • Full name
  • Date of birth
  • Home postcode
  • School or college name
  • Gender
  • Ethnicity
  • Disability
  • Care-experienced status
  • Caring responsibilities
  • Refugee status
  • Free school meals eligibility
  • Whether estranged from parents

The Widening Participation team will, if necessary, also use some information (known as “contextual admissions data”) you provide in your UCAS application to identify students who might be eligible for additional support in transitioning to university life.

The contextual admissions data we use to assess your application to study at SOAS comprises the following types of personal data:

  • Home postcode
  • First generation in HE status
  • Free school meals eligibility
  • Care-experienced status

How is your personal data used?

Our pre-registration outreach events are run in collaboration with schools, further education providers and third-party organisations and are designed to improve access and progression outcomes for individuals who go on to study at SOAS or other higher education providers. When you participate in an outreach activity, SOAS will store and use your personal data.

SOAS also works with the Higher Education Access Tracker (HEAT) service, which is led by the University of Kent, to maintain records of individuals who have attended our outreach events in a secure database. The HEAT service will receive data about individuals from the Higher Education Statistics Agency to create statistical reports which inform SOAS of participants who have gone on to study at SOAS and elsewhere. Individuals will not be identifiable from the reports, which will be used by SOAS to evaluate the effectiveness of its outreach activity.

After you have taken part in an outreach event, you will be asked to fill in a feedback form. This form will include some information which identifies you, such as your name, date of birth and postcode.  We use the information you provide to inform our work in improving access to university.  The information which identifies you will be entered into the secure HEAT database (see further information below), and will be stored there separately from the other information you provide.  We will put all the remaining data into a statistical form so that SOAS can understand the impact of the event on the participants, and how we might improve the content, format or structure of the event in the future. The information you provide in feedback forms will be held securely onsite at SOAS, with access restricted to authorised personnel only. You will not be identifiable from our statistical analysis of the feedback

If you have participated in an outreach activity run by SOAS’s Widening Participation team, we will use any personal data we collect for the following purposes:

  • To identify whether participants go on to study at SOAS, or other higher education providers
  • To identify whether outreach participants are more likely to go on to higher education than those who do not participate
  • To assess what SOAS can do to improve its outreach work

 
If you have applied for a course at SOAS, our Widening Participation team will use contextual admissions data which you have provided for the following purposes:

  • Monitoring its performance against our current Access Agreement, which can be found on the Widening Participation homepage: https://www.soas.ac.uk/widening-participation/
  • Provide access to bridging courses for first generation and mature students
  • Provide online mentoring through the first term of study

Why do we process your personal data?

SOAS needs a lawful basis for processing your personal data, and we need to tell you about it in this privacy notice.

When we process your personal data during pre-registration outreach activities, we do so because it enables SOAS to carry out research into the effectiveness of its Access Participation Plan, which is a requirement of the School’s registration with the Office for Students. Therefore, we consider this processing necessary to perform our public task.

When you apply to one of our degree programmes, we process your fair and contextual admissions data under the following lawful bases.

Whilst the School is deciding whether to make you an offer to study, we are processing your data in the legitimate interests of both you and the School. This means that you have the right to ask us to stop processing your data at any point i.e. by telling us you would like to withdraw your application.  

Once the School makes you an offer which you then accept, we consider that SOAS is taking steps to enter into a contractual arrangement with you at your request, and will need to assess whether you are eligible for support such as bridging course or online mentoring based on the contextual admissions data you provided. At this stage you can no longer ask us to stop the processing, although you do have the right to ask for access to your data, and to correct any inaccuracies.

Who do we share your data with?

SOAS’s Widening Participation team work with partners to support students from underrepresented groups in higher education through their student journey.

We share your data with the Higher Education Access Tracker (HEAT) Service, led by the University of Kent, which enables SOAS to monitor and evaluate the effectiveness of our education outreach activities. We will only share the following personal data with HEAT

  • Full name
  • Date of birth
  • Home postcode
  • School or college name
  • Gender
  • Ethnicity
  • Disability
  • Care-experienced status
  • Caring responsibilities
  • Refugee status
  • Free school meals eligibility
  • Whether estranged from parents

We have entered into a written agreement with HEAT which sets out the responsibilities of SOAS and the HEAT service in processing and protecting your personal data under Data Protection law.

Where we are required to do so, SOAS also shares data with the following third parties who will receive your data as a Data Controller:

  • The Office for Students
  • The Department for Education
  • England Skills Funding Agency
  • The Higher Education Statistics Agency
  • UCAS

If required, and only where necessary, SOAS will share your personal data when we are legally obliged to do so, for instance if we are asked to provide information to a court.

SOAS’s Widening Participation team will not transfer your personal data outside of the European Economic Area. Such transfers are known as ‘international transfers’, and are restricted by data protection law.

If it is necessary in the future to make this type of transfer, we will only do so with your explicit consent or in accordance with one of the other safeguards listed in Article 46 of the General Data Protection Regulation (GDPR).

What is Special Category Data, and why do we use it?

Special Category Data are types of personal data to which the law requires us to give extra protection. They include ethnic background, religious or philosophical belief, health, sexual life and orientation, political opinion, trade union membership, or biometric or genetic data.

We process data on your health and ethnicity as a participant in our outreach activities only with your explicit consent. We process the health and ethnicity data you provide in your course application where it is necessary to do so for reasons of substantial public interest, specifically to monitor equality of opportunity and treatment of applicants, and for statistical research purposes.

How long is data retained?

At SOAS we aim to continually improve our educational outreach activities to encourage more and more individuals from under-represented groups into higher education. To monitor whether our outreach has the effect of widening participation, we will have access to limited, relevant information through the HEAT tracking system to identify former participants over a long period of time, and we will use that data to create valuable statistics and reports for research purposes.

Retention periods for individuals who consent to tracking vary depending on your age when you participated in outreach, and a few other factors:

Under 18 when participating:

  • Tracked until 18 using Key Stage 4 and UCAS data, then using HESA data when reach 18.
  • If individual does not enter higher education (and therefore doesn’t appear in HESA data) for 10 years, record is anonymized
  • If enrolled in higher education and graduates/leaves within 7 years, individual’s record will be held for a further 15 years from the year of graduation. At the end of 15 years, the record is anonymized
  • If individual enrols in higher education but does not graduate within 7 years, their record will be anonymized.

18 or over when participating

  • Individual will be tracked from the date their record is created or their ‘HE Ready Year’, whichever is later, and record held for 10 years.
  • If HESA record shows individual has not entered higher education for 10 years, their record is anonymized.
  • If HESA record shows individual enrols in higher education and graduates/leaves within 7 years, the individual’s record will be held for a further 15 years from the year of graduation/leaving. At the end of 15 years, the record is anonymized.
  • If individual enrols in higher education but does not graduate within 7 years, their record will be anonymized.

If you do not consent to being tracked, your record will be held for a maximum of 10 years on the HEAT system and will then be permanently deleted.

What are my rights?

Data protection law gives you rights over your personal data. This means you can ask for access to a copy of your data, for your data to be corrected, you can ask us to restrict our use of your data, or you can object to our processing of your data. If you make this type of request, we have one month to respond. Some legal rights might not be available depending on the lawful basis under which we are processing your data, as shown in the table below.

As someone who has applied to or participated in an outreach event or provided us with contextual admissions data in their course application, the lawful bases we rely on to process your data are:

  1. Contract
  2. Legitimate interests
  3. Public task
The table below shows which rights are available to you under each lawful basis:

Lawful basis Individual's rights
Access Correction Restriction Erasure Portability Objection
Contract Y Y Y Y Y N
Public task Y Y Y N N Y
Legitimate interests Y Y Y Y N Y

Right of Access: You have the right to the information which the School holds about you. You will not have to pay a fee to access your personal information unless your request for access is excessive. Alternatively, we may refuse to comply with the request in such circumstances. A guide on how to make a ‘Subject Access Request’, including requirements for proving your identity, is available on our website here: Making a request for your data

Right to correct your data: If you believe data we hold about you is incorrect as to a matter of fact, or if your information changes, please write to us as soon as possible.

Right to restrict processing: If you believe SOAS is processing your data unlawfully, you can ask us to restrict the processing of your data whilst we investigate your complaint. When we restrict your data we will only store it securely to mark it as restricted.

Right to erasure: If we process data with your consent or in our legitimate interests then you can ask for your data to be completely deleted at any time.

Right to data portability: If you provide us with electronic data which we have your consent or a contractual reason to process, you can ask for a copy of the data in a machine-readable format, or you can ask us to transfer it to another IT environment on your behalf.

Right to objection: If we process your data with your consent or in our legitimate interests, you may object to the processing. For example, you might opt-out of receiving marketing communications.

If SOAS corrects, restricts, or deletes your personal data at your request and that data has been passed to a third party or third parties for the same purpose, SOAS is responsible for taking reasonable steps to ensure that those parties fulfil the terms of your request.

If you wish to exercise any of these rights, please contact our Data Protection Officer (contact details in the section Who we are and how to get in touch) in the first instance.

Updates to this notice

We will review this notice on an annual basis, and will make updates as necessary to reflect any changes to the type of personal data that we process and/or the way in which it is processed. The most recent version of this notice can always be found at the following page of the SOAS website: https://www.soas.ac.uk/infocomp/dpa/privacy-notices/widening-participation-privacy-notice/. If you would like to receive a copy of this notice, please ask the Data Protection Officer using the contact details at the top of this notice Who we are and how to get in touch.