EMBT College’s Data & Privacy Protection Policy

This page sets out in outline form our data and privacy protection policies and over-arching approach to individual privacy.  More detailed documentation is held centrally in London, UK, on the organization’s central repositories.

Introduction

EMBT College takes its responsibilities with regards to the management of the requirements of the General Data Protection Regulation (GDPR) very seriously, by virtue of the fact that it offers accredited UK qualifications.

This policy document sets out how the Institution manages those responsibilities. EMBT College UK obtains, uses, stores and otherwise processes personal data relating to potential staff and students (applicants), current staff and students, former staff and students, current and former workers, contractors, website users and contacts, collectively referred to in this policy as data subjects. When processing personal data, the Institution is obliged to fulfil individuals’ reasonable expectations of privacy by complying with GDPR and other relevant data protection legislation such as  the data protection law.

This policy therefore seeks to ensure that EMBT College UK:

1. is clear about how personal data must be processed and the Institution’s expectations for all those who process personal data on its behalf
2. comply with the data protection law and with good practice
3. protect the Institution’s reputation by ensuring the personal data entrusted to us is processed in accordance with data subjects’ rights
4. protect the Institution from risks of personal data breaches and other breaches of data protection law.

Scope

This policy applies to all personal data processed by the Institution regardless of the location where that personal data is stored (e.g. on an employee’s own device) and regardless of the data subject. All staff and others processing personal data on the Institution’s behalf must read it. A failure to comply with this policy may result in disciplinary action. All Heads of Departments are responsible for ensuring that all Institution staff within their area of responsibility comply with this policy and should implement appropriate practices, processes, controls and training to ensure its compliance. The Institution’s Data Protection Officer is responsible for overseeing this policy.

Our Overarching Personal Privacy & Data Protection Principles

When the Institution processes personal data, it will be guided by the following principles, which are set out in the GDPR. The Institution is responsible for, and must be able to demonstrate compliance with, the data protection principles listed below:

Those principles require personal data to be:

1. processed lawfully, fairly and in a transparent manner (Lawfulness, fairness and transparency).
2. collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes (Purpose limitation).
3. adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data minimisation).
4. not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the personal data is processed (Storage limitation).
5. processed in a manner that ensures its security, using appropriate technical and organisational measures to protect against un-authorised or unlawful processing and against accidental loss, destruction or damage (Security, integrity and confidentiality).

Other Web-Specific Privacy-Related Information

Use of Comments

When visitors leave comments on the site, we collect the data shown in the comments forms, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

 If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Password Resets

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.