Privacy Policy

This Privacy Policy applies between you, the User of this Website, and Higher Ed Partners UK (HEP UK), the owner and provider of this Website. Higher Ed Partners UK takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: https://higheredpartners.co.uk/termsandconditions.

Please read this Privacy Policy carefully.

Definitions and Interpretation

In this Privacy Policy, the following definitions are used:

Data	collectively all information that you submit to Higher Ed Partners UK via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies	a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws	any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR	the UK General Data Protection Regulation;
Higher Ed Partners UK, we or us	Higher Ed Partners UK, a company incorporated in England and Wales with registered number 10905055 whose registered office is at Northgate House, Northgate Street, Wiltshire, SN10 1JX;
UK and EU Cookie Law	the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or you	any third party that accesses the Website and is not either (i) employed by Higher Ed Partners UK and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Higher Ed Partners UK and accessing the Website in connection with the provision of such services; and
Website	the website that you are currently using, https://higheredpartners.co.uk/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this Privacy Policy, unless the context requires a different interpretation:

the singular includes the plural and vice versa;
1. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
1. a reference to a person includes firms, companies, government entities, trusts and partnerships;
1. “including” is understood to mean “including without limitation”;
1. reference to any statutory provision includes any modification or amendment of it;
1. the headings and sub-headings do not form part of this Privacy Policy.
Scope of this Privacy Policy

This privacy notice aims to give you clear and detailed information about:

how HEP UK collects and processes your personal data
the legal grounds allowing HEP UK to do so
how HEP UK looks after your personal data
your privacy rights
how the law protects you

This Privacy Policy applies only to the actions of Higher Ed Partners UK and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Higher Ed Partners UK is the “data controller”. This means that Higher Ed Partners UK determines the purposes for which, and the manner in which, your Data is processed.

Data Collected
We may collect the following Data, which includes personal Data, from you:
- Full name;
- Date of birth;
- Gender;
- Work history – including employer, job title, responsibilities, location and dates in role
- Contact Information such as email addresses and telephone numbers;
- Demographic information such as postcode, preferences and interests;
- Nationality
- Disability Information
- Confirmation of whether English is first language
- Educational records and qualifications, including higher and further education institutions attended, dates of attendance, degree programme titles, subjects and grades
- Higher and further education transcripts and certificates
- Membership of professional or industry associations
- Profile Data, including purchases or orders made by you, your preferences, feedback and survey responses
- Usage Data, including information about how you use our website and services
- IP address (automatically collected);
- Web browser type and version (automatically collected);
- Operating system (automatically collected);
- A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

in each case, in accordance with this Privacy Policy.

If you do not provide us with personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with education services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

How We Collect Data
We collect Data in the following ways:
- data is given to us by you.
- data is collected automatically;
  - As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as those set out below:
  - Educational agents – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
  - Universities – Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial Data.
  - Named Referees – Identity Data and Contact Data
  - Providers of technical, payment and delivery services – Contact, Financial and Transaction Data.
- Technical Data from the following parties:
  - analytics providers;
  - advertising networks; and
  - search information providers.
Data That is Given to Us by You

Higher Ed Partners UK will collect your Data in a number of ways, for example:

when you contact us through the Website, by telephone, post, e-mail or through any other means;
1. when you register with us and set up an account to receive our products/services;
1. when you elect to receive marketing communications from us;
1. when you use our services;

in each case, in accordance with this Privacy Policy.

Data That is Collected Automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
1. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our Use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website or Services.

7.1 Generally, Data may be used by us for the following reasons:

Purpose	Lawful Basis (Reason)
To respond to your enquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or complaints.	Legitimate interest
To send you marketing related emails, with information about our services and other news about us.	Consent
Assessing your eligibility to be offered a place on one of our University Partner online academic courses and programmes	Necessary for a contract or entering into a contract
Making reasonable adjustments for disabilities and providing relevant support to students or applicants with ill health	Substantial public interest – specifically support for individuals with a particular disability or medical condition
To provide you with support and pastoral services throughout your course of study.	Necessary for a contract or entering into a contract
Administration of complaints, grievances and appeals	Necessary for a contract or entering into a contract
For audit purposes and to verify that our internal processes are compliant with legal, regulatory or contractual requirements.	Legal obligation
Fraud and security monitoring purposes, including to prevent cyber-attacks.	Legitimate Interest
Developing, enhancing, improving, or modifying our current services, identifying usage trends and determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.	Legitimate Interest
Undertake call recording monitoring, for the purposes of training and quality improvement	Legitimate Interest
To service providers worldwide acting as processors who provide IT and system administration services	Legitimate Interest

7.2 Specifically, for Prospective Students

Purpose	Data Type	Lawful Basis for Processing
To register you on our website and subscribe to our services	Identity, Contact Details, Marketing & Communications	Necessary for a contract or entering into a contract
To process your application form and correspond with you including: (i) processing deposits and course fees (ii) verifying exam and test results	Identity, Contact Details, Financial, Criminal Conviction, Special Category	Consent
To assess students’ eligibility for scholarship or bursary	Identity, Contact Details, Financial	Necessary for a contract or entering into a contract
Provision of personal data to Third Parties
To educational agents where the agent has submitted an application on behalf of a prospective student	Identity, Contact Details, Financial, Criminal Conviction, Special Category	Necessary for a contract or entering into a contract
To cloud hosted virtual learning environment (VLE) services (e.g. Canvas)	Identity, Contact Details	Legitimate Interest

7.3 Specifically, for Enrolled Students

Purpose	Data Type	Lawful Basis for Processing
To register you for our services as an enrolled student	Identity, Contact Details, Financial, Transaction	Necessary for a contract or entering into a contract
To provide you with ongoing services after enrolment including: (i) provision of core teaching and learning services (ii) administration including maintaining student records, processing fees, managing accommodation (iii) providing services including library, IT and information services and other student support services (excluding welfare and medical)	Identity, Contact Details, Financial,	Necessary for a contract or entering into a contract
To provide you with ongoing services after enrolment in respect of student welfare and medical services	Identity, Special Category	Necessary for a contract or entering into a contract
To provide you with reports on your progress	Identity, Contact Details,	Necessary for a contract or entering into a contract
To process student complaints and grievances	Identity, Contact Details, Special Category	Legitimate Interest
To carry out internal research and analysis, including call recording monitoring,	Identity	Legitimate Interest
Provision of personal data to Third Parties
To enable HEP UK companies to provide (i) application and admissions services (ii) core teaching and learning services, (iii) student administration services and (iv) student welfare services	Identity, Contact Details, Financial, Transaction, Special Category	Legitimate Interest
HEP UK University Partners	Identity, Contact Details, Financial, Transaction, Special Category	Necessary for a contract or entering into a contract
To service providers worldwide who provide IT and system administration services	Identity, Contact Details	Legitimate Interest
To local authorities or police regarding a safeguarding concern	Identity, Contact Details, Special Category	Legal obligation or Vital interests (as relevant)

7.4 Specifically, for Candidates for Employment

Purpose	Data Type	Lawful Basis for Processing
To assess your skills, qualifications and suitability for the role	Identity, Contact Details, Work History	Necessary for a contract or entering into a contract
To assess information about disability status to consider whether we need to make appropriate adjustments during the recruitment process	Special Category	Consent
Once an offer has been made to carry out background and reference checks, where applicable (excluding criminal record)	Identity, Contact Details,	Necessary for a contract or entering into a contract
Once an offer has been made to carry out a criminal record check where required by law due to the nature of the role applied for	Identity, Criminal Conviction	Necessary for a contract or entering into a contract
To communicate with you about the recruitment process	Identity, Contact Details,	Necessary for a contract or entering into a contract
To comply with equal opportunities monitoring and reporting requirements	Special Category	Legal obligation

in each case, in accordance with this Privacy Policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:

soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
1. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
1. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.

When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may use your Data to show you Higher Ed Partners UK adverts and other content on other websites. If you do not want us to use your data to show you Higher Ed Partners UK adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).

Who We Share Data With

We may share your Data with the following groups of people for the following reasons:

any of our group companies or affiliates – to ensure the proper administration of the website and business;
1. our employees, agents and/or professional advisors – to ensure business services can be provided to the user, including with the relevant University Partner if applicable, and to obtain advice from professional advisers;
1. third party service providers who provide services to us which require the processing of personal data – to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly;
1. relevant authorities – to facilitate the detection of crime, or the collection of taxes or duties;

in each case, in accordance with this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Keeping Data Secure

We will use technical and organisational measures to safeguard your Data, for example:

access to your account is controlled by a password and a user name that is unique to you.
1. we store your Data on secure servers.
1. payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@higheredpartners.co.uk.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data Retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

You have the following rights in relation to your Data:

Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
1. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
1. Right to erase – the right to request that we delete or remove your Data from our systems.
1. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
1. Right to data portability – the right to request that we move, copy or transfer your Data.
1. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@higheredpartners.co.uk.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers Outside the United Kingdom and European Economic Area

Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the UK or EEA or one of our service providers is situated in a country outside the UK or EEA. We also share information with our group companies, some of which are located outside the UK or EEA.

We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission as specified on their website https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Data Retention

Details of retention periods are;

Data	Retention
Enquiries from prospective students	Last communication with student + 3 years
Applications Not Progressed	Last communication with student + 1 year
Applications Completed	Original Course End Date + 3 years
Enrolled Students	Completion of course + 10 years
Call Recordings	Last communication + 1 year
Unsuccessful Employment Candidates	Last communication with candidate + 1 year
Successful Employment Candidates	End of Employment + 6 years

Links to Other Websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

Higher Ed Partners UK may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Higher Ed Partners UK. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

This Website may place and access certain Cookies on your computer. Higher Ed Partners UK uses Cookies to improve your experience of using the Website and to improve our range of services. Higher Ed Partners UK has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Higher Ed Partners UK to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following Cookies:

Type of Cookie	Purpose
Strictly necessary cookies	These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies	They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies	These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookie.
Targeting cookies	These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find a list of Cookies that we use in the Cookies Policy.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please see the help menu in your internet browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently.

You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to This Privacy Policy

Higher Ed Partners UK reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations.

  You may contact Higher Ed Partners UK by email at info@higheredpartners.co.uk. This Privacy Policy was created on 02 January 2024