Ashridge Trust Privacy Notice
Data Collection and Privacy Notice
Ashridge (Bonar Law Memorial) Trust (“Ashridge 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”).
The Ashridge Trust Privacy Notice relates to information about you which will be collected by Ashridge (Bonar Law Memorial) Trust and processed as described below for Ashridge’s doctorate, coaching qualifications, and apprenticeship programs from our Hult Ashridge campus in Berkhamsted, Hertfordshire, HP4 1NS, UK. The most up to date version of this privacy notice is published on Ashridge’s program websites.
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 Ashridge 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):
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to access your personal information;
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to rectify inaccurate information;
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to restrict processing of your information; and
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to object to processing of your information.
If you wish to send a digital postcard or tell a friend about a particular program, we will ask for the recipient’s name, email address, and phone number. The information provided will only be used to confirm message delivery and it will not be shared with outside parties except to the extent necessary to confirm that message.
The information you provide to create a message is only used for that purpose and is only disclosed to the recipient.
Data transfers to other countries
Your personal data may be transferred to countries outside the European Union for the purposes described above. Ashridge Trust will only transfer personal data outside the European Union where adequate safeguards are in place.
The information you provide to create a message is only used for that purpose and is only disclosed to the recipient.
Prospective Applicants
Registration at Events
Attending events is the ideal way to visit Ashridge 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 Ashridge Trust. This processing is necessary on the grounds of our legitimate interest.
Participant Data
Ashridge (Bonar Law Memorial) 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
Ashridge Trust will process your personal data when it receives your application. We will also process your personal data from third party sources such as Government Departments and agents (if applicable). This is to assist us with the application process and understand key aspects of information which relate to your experience. If you are successful, your application will form the basis of your student record at Ashridge Trust. This processing is necessary on the grounds of our legitimate interest. The processing of Special Category Data is necessary on the grounds of our legitimate interest and for statistical and research purposes.
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.
Students
Enrolment at Ashridge Trust
Learning Analytics
Ashridge Trust wishes to improve the students’ experience and uses learning analytics to collect data to make Ashridge Trust progress. We will process your personal data to record attendance and use of Ashridge Trust's facilities. This processing is necessary on the grounds of our legitimate interest.
Student record
Anonymous Reporting
Ashridge 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 Ashridge Trust. You have the option of reporting your concerns anonymously or providing your contact details so that Ashridge 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 Ashridge 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 Ashridge Trust’s to assist you and to take any further action required under Ashridge 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 Ashridge 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 Ashridge Trust’s legitimate interest.
Digital Usage
Ashridge Trust will process your personal data when you use its digital facilities. This is to ensure that Ashridge 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 Ashridge 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. Ashridge 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. Ashridge Trust needs to ensure that it administers its policies and procedures in respect of appeals, complaints and disciplinary matters.
Reporting to Professional/Accreditation Bodies
Ashridge 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.
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 Ashridge Trust’s legitimate interest.
Additional Courses/Qualifications
We are keen to support your development and will process your personal data to ask you if you are interested in any further courses to obtain further qualifications at Ashridge Trust. This processing is necessary on the grounds of Ashridge Trust’s legitimate interest.
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
Ashridge Trust will process your personal data in the event that you have any specific requirements when visiting Ashridge Trust. This may include data regarding any disability and is used in order to allow us to assist you and your experience at Ashridge 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 Ashridge.
Emergencies
There may be circumstances where Ashridge 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 Hult Ashridge protecting your vital interests.
Security
Your safety and security are very important to Ashridge 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 Ashridge Trust so we will process your personal data when you complete surveys for experiences such as open days. Ashridge 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 Ashridge Trust. This processing is necessary on the grounds of our legitimate interest.
Students: It is important that Ashridge 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 Ashridge Trust provides has benefitted you. Some surveys are used to inform Ashridge Trust’s performance in rankings and league tables, so participation is important to Ashridge Trust, its students and its graduates.