Data Collection and Privacy Notice

This privacy notice relates to information about you which will be collected and processed by The Ashridge (Bonar Law Memorial) Trust (“the Trust”). Hult International Business School Inc. and the Trust are separate legal entities that have merged operations under the common brand “Hult International Business School”. The most up to date version of this privacy notice is published on the Trust’s website.

The Trust processes personal data as a “Data Controller” as defined in the Data Protection Act 2018 (the “DPA”) and the GDPR as retained in UK law by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (“the UK GDPR”).

What we collect

The personal data which we process includes your personal and contact details and information about you which is relevant to your relationship with the Trust. It may also include information about your disability status, ethnicity, sexual orientation, gender reassignment or religion, which is classed as Special Category Data under the DPA. We will process criminal records data where a course requires us to carry out a DBS check or where a relevant disclosure has been made.

Your rights

The DPA and the UK GDPR give you the right to know what information is processed about you and how it is processed. You also have the following rights (limited in certain circumstances):

  • to access your personal information;

  • to rectify inaccurate information;

  • to restrict processing of your information; and

  • to object to processing of your information.

Data transfers to other countries

Your personal data may be transferred to countries outside the European Union for the purposes described above. The Trust will only transfer personal data outside the European Union where adequate safeguards are in place.

Prospective Applicants

    Enquiries to Study at the Trust

    We will process your personal data in order to respond to any enquiry you may have about the Trust such as requesting a prospectus or finding out more about our courses. This processing is necessary on the grounds of our legitimate interest.

    Registration at Events

    Attending events is the ideal way to visit the Trust, experience it and obtain further information on the courses which may be of interest to you. We will process your personal data when you register to attend an event at the Trust. This processing is necessary on the grounds of our legitimate interest.

    Participant Data

    The Trust will process your personal data to assess and evaluate how well its outreach initiatives are operating. This will include information regarding your studies, where you live and extra-curricular participation. This processing is necessary on the grounds of performing a public task. The processing of Special Category Data is necessary on the grounds of performing a public task and acting in the public interest.

    Applicants

      Applications to Ashridge Trust programs

      We will process your personal data to respond to any enquiry you may raise about the Trust which

      includes any financial matters such as scholarships. This processing is necessary on the grounds of

      our legitimate interest.

      UK Visas and Immigration (“UKVI”) Exports/Imports

      Ashridge Trust is required to meet its obligations set out by UKVI and will need to adequately report on applications. We will process your personal data in respect of your applications as part of our reporting obligations (as appropriate). Where relevant, this processing is necessary on the grounds of our obligation to perform a public task as this processing is required for Ashridge Trust to meet its obligations set out by UKVI. The processing of Special Category Data is necessary on the grounds of our obligation to perform a public task and for reasons of substantial public interest.

      Financial Assistance and Enquiries

      We will process your personal data to respond to any enquiry you may raise about Ashridge Trust which includes any financial matters such as scholarships. This processing is necessary on the grounds of our legitimate interest.

      Students

        Enrolment at the Trust

        We will process your personal data when you enrol at the Trust. This is to assist us with the enrolment process and understand the key aspects of information which will relate to your study at the Trust. This processing is necessary on the grounds of our legitimate interest.

        We will process your personal data when you enrol at Ashridge Trust. This is to assist us with the enrolment process and understand the key aspects of information which will relate to your study at Ashridge Trust. This processing is necessary on the grounds of our legitimate interest.

        Events

        The Trust may ask you if you want to attend events to assist with your learning experience. We will process your personal data to ensure that you are signed up to events and run reports on the attendance of events. This processing is necessary on the grounds of our legitimate interest.

        Learning Analytics

        The Trust wishes to improve the students’ experience and uses learning analytics to collect data to make the Trust progress. We will process your personal data to record attendance and use of the Trust’s facilities. This processing is necessary on the grounds of our legitimate interest.

        Student record

        The Trust will process your personal data as part of your student record. This will contain the essential information that you will need throughout your academic career. The Trust will process your personal details in respect of your award, your attendance and dates studied at the Trust. It is fundamental that the Trust retains this data permanently and it is unable to erase this information. This processing is necessary on the grounds of the Trust performing its obligations under our contract with you. It is also necessary on the grounds of performing a task in the public interest and also on the grounds of the Trust’s legitimate interest.

        Anonymous Reporting

        The Trust works with an external service provider, Syntrio Lighthouse which is a global compliance organisation to provide a safe, confidential, and anonymous platform, which allows you to report concerns about harassment, bullying and sexual misconduct to the Trust. You have the option of reporting your concerns anonymously or providing your contact details so that the Trust can contact you about your concern. Reporters can remain anonymous and will be able to track feedback through unique log-in. If you choose to report anonymously, we will retain the details of your report for statistical purposes and to identify trends and areas for improvement. We will process this information on the grounds of the Trust’s legitimate interests. If you choose to provide your personal details and you include information about the nature of your complaint, this is likely to constitute sensitive personal data. We will use this information in order to direct your complaint to the most appropriate team within the Trust to assist you and to take any further action required under the Trust’s policies and procedures.

        By making the choice to include your contact details in your report to Syntrio Lighthouse, you are providing your consent to the processing of your personal data, including sensitive personal data, for this purpose.

        Mentoring

        Dependent on your program, you may sign up to be involved in mentoring sessions when enrolled at the Trust. We will process your personal data to record mentoring participation and evaluate the success of mentoring schemes. This processing is necessary on the grounds of the Trust’s legitimate interest.

        Digital Usage

        The Trust will process your personal data when you use its digital facilities. This is to ensure that the Trust ensures its systems are secure and they are being used appropriately in accordance with its Information Security and Acceptable Use Policy. This processing is necessary on the grounds of our legitimate interest.

        Appeals/Complaints/Disciplinary

        Although the Trust does not envisage incidents involving appeals and complaints, it needs to ensure that it administers its policies and procedures in respect of students and considers appeals, complaints and disciplinary matters seriously. This also includes matters related to cheating and plagiarism. The Trust will therefore process your personal data to ensure that it deals with these procedures accordingly. This processing is necessary on the grounds of our legitimate interest. The Trust needs to ensure that it administers its policies and procedures in respect of appeals, complaints and disciplinary matters.

        Reporting to Professional/Accreditation Bodies

        The Trust may be required to process your personal data to professional or accreditation bodies. In these instances, we will process your personal data to the relevant bodies. This processing is necessary on the grounds of performing a task in the public interest.

        Reporting to Government Bodies

        The Trust may be required to process your personal data in order to report to UK Visas and Immigration to ensure compliance with visa conditions. This processing is necessary on the grounds of performing a task in the public interest.

        Virtual Graduation Ceremonies

        The Trust reserves the right to stream its graduation ceremonies on its social media channels. Graduations are public events and this processing will be on the basis of the Trust’s legitimate interests.

        Staff as students

          Performance and Progress

          We will process your personal data in respect of your performance and progress on a program. This will include sharing your personal data with your line manager in respect of your performance. This processing is necessary on the grounds of the Trust’s legitimate interest.

          Additional Courses/Qualifications

          We will process your personal data for reasons related to our statutory and/or public functions, including funding, regulation and policy-making purposes. This may also include data processing for statistical and research purposes. We may also need to process your data, including Special Category Data, for the purposes of law enforcement and fraud detection. We will process criminal records data where a course requires us to carry out a DBS check or where a relevant disclosure has been made. This processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

          All students and applicants

            Public and Administrative Functions

            We will process your personal data for reasons related to our statutory and/or public functions, including funding, regulation and policy-making purposes. This may also include data processing for statistical and research purposes. We may also need to process your data, including Special Category Data, for the purposes of law enforcement and fraud detection. We will process criminal records data where a course requires us to carry out a DBS check or where a relevant disclosure has been made. This processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

            Specific Requirements

            The Trust will process your personal data in the event that you have any specific requirements when visiting the Trust. This may include data regarding any disability and is used in order to allow us to assist you and your experience at the Trust. We will process Special Category Data (e.g. information relating to health, disability or mobility requirements) if you have made us aware of such information. This information will be used to enable us to provide the appropriate services and assistance during your time at the Trust.

            Emergencies

            There may be circumstances where the Trust needs to contact an emergency contact that you have specified or the emergency services in the event of an accident or illness. We will process your personal data on the grounds of vital interests. The processing of Special Category Data is necessary on the grounds of the Trust protecting your vital interests.

            Security

            Your safety and security are very important to the Trust. We will process your personal data, including images captured by CCTV, to ensure the safety and security of you and your possessions, and to secure Ashridge House and its surroundings. This processing is necessary on the grounds of our legitimate interest.

            Surveys

            Prospective Applicants and Applicants: It is important that we understand your views about the Trust so we will process your personal data when you complete surveys for experiences such as open days. The Trust wants to ensure that it continues to develop and improve what it offers to potential students so participation in such surveys is important to the Trust. This processing is necessary on the grounds of our legitimate interest.

            Students: It is important that the Trust understands whether it is providing a satisfactory service so it will process your personal data when you complete surveys. This allows us to see whether any improvements can be made. We will also process your personal data when you complete surveys to assess how the student experience and the services the Trust provides has benefitted you. Some surveys are used to inform the Trust’s performance in rankings and league tables, so participation is important to the Trust, its students and its graduates.