Across the Pond intends to fully comply with the UK Data Protection Act 1998 (‘DPA’) and from 25 May 2018, the General Data Protection Regulation (Regulation [EU] 2016/679) (‘GDPR’) in so far as it affects the Organisation’s activities.
The GDPR protects the rights of individuals by specifying certain rules regarding what organisations can and cannot do with information about people. A major component of this regulation is the principle that organisations process individuals’ data lawfully and fairly.
Throughout this policy “Across the Pond” “we”, “our" and “us” (or similar expressions) refer to the data controller, Across the Pond – Study in Britain, Ltd. “You” and “your” (or similar expressions) mean the person using our website, whether as a guest or registered user, an applicant, member of staff, contractor, or partnership organisation as outlined in our Terms and Conditions.
Across the Pond take our obligations under the DPA and GDPR very seriously and will always ensure personal data is collected, handled, stored, and shared in a secure manner.
The following statement will summarise what personal data we collect, how we use it, and who we share it with. It will also provide guidance on your own rights as an individual and how to lodge a compliant to the Information Commissioner’s Office, the regulator for data protection in the UK.
Our official contact details are:
Data Protection Officer
Across the Pond – Study in Britain, Ltd.
1 Rookery House
Grove Farm
Crookham Village
Hampshire
GU51 5RX
Great Britain
1. Introduction
Across the Pond – Study in Britain, Ltd. is committed to protecting your personal information when you are using our services. This Privacy Policy relates to our use of any personal information we collect from you via the following means:
- Any Across the Pond website that links to this Privacy Policy;
- Social media or official Across the Pond content on other websites;
- Live Chat platforms;
- In-person and online events.
It also relates to our use of any personal information you provide to us by phone, SMS, email, in letters or other correspondence, and in person. This includes personal information regarding Across the Pond staff, contractors, or partners.
In order to provide you with guidance related to studying in the UK, we may need to collect certain information about you.
This Privacy Policy explains the following:
- What information Across the Pond may collect about you;
- Where we store your personal information;
- How we use your personal information;
- When Across the Pond may use your details to contact you;
- Whether we will disclose your personal details to anyone else;
- Your rights regarding the personal information that you provide us;
- The use of cookies on the Across the Pond website and how you can reject this.
Across the Pond is committed to safeguarding your personal information. Whenever you provide such information, we are legally obligated to use your information in line with all applicable laws concerning the protection of personal information, including the GDPR and DPA.
This privacy policy only covers pages within the Across the Pond website. It does not extend to sites to which a link is provided from the Across the Pond site.
2. Who we are
Across the Pond provides quality educational advising services free from charge or obligation. We supply information about degree programs and our partner universities in good faith and make reasonable efforts to ensure all information is as accurate and as up-to-date as possible.
Neither Across the Pond, nor its associates, are responsible or liable for any loss or damage (including, but not limited to, actual, consequential, or punitive), liability, claim, or other injury or cause related or resulting from any information obtained from our clients.
THE APPLICATION PROCESS
Across the Pond are not liable for your application and process all applications to the best of our ability. It is your responsibility to check with Across the Pond and the relevant university/s that your application has been received.
Applicants must also ensure that all transcripts and test scores are their own and are genuine. Across the Pond does not guarantee acceptance to any of our university partners.
Across the Pond only works with our partner universities and submits applications exclusively via the British Universities and Colleges Admissions Service (UCAS) or specific university application form(s) or portal(s).
The final admissions decision lies with the university. You, the student, are not obligated to only apply to Across the Pond’s partner universities, but these are the only universities we can help you apply to.
3. Lawful Basis for Processing
It is necessary for Across the Pond to collect, process and use individuals’ data in order to perform the contract between the applicant and the Organisation in providing educational advisory services and a condition of staff employment that they agree to the Organisation processing certain personal information as part of the Organisation’s obligations.
Some processing activities may also be carried out under the following legal bases: a legal obligation, where it is necessary to protect the vital interests of an individual or another party, where it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, or where it is necessary for legitimate interests to be pursued by the Organisation or a third party. Where any of these legal bases do not apply, the consent of an individual to process their personal data will be sought.
4. Information we may collect from you
When you participate in, access, or sign up to any of Across the Pond’s services, activities or online content such as newsletters, blogs, study guides, live chats, events, or submit an enquiry or application form using our online forms, we may receive personal information about you.
The largest volume of personal data Across the Pond possesses is in relation to prospective students and applicants and includes:
- Information that you provide by filling in forms on our website, studyacrossthepond.com;
- Details of applications you make through our website;
- If you contact us, including via email, telephone and our online enquiry forms, we may keep a record of that correspondence;
- Details of your visits to our website and the resources that you access (for more information, please see our Cookies Policy);
- We may ask you to complete surveys that we use for research purposes, however you are not obligated to respond to these
If you submit personal information to us, for example by providing your name and email address, we may link this information to any other information we have collected about you.
Across the Pond also processes personal data in relation to staff. This is undertaken to facilitate recruitment activity and to administer the requirements the Organisation must meet as an employer in line with UK law.
5. How we use your personal information
Across the Pond is committed to protecting your privacy and ensures that your personal information is held securely. The information that you provide us will be stored on our systems and used in the following ways:
- To enable our advising staff to contact you about a submission/enquiry you have made via our website or other means of communication;
- To enable our advising staff to tailor information provided to match your academic interests and background;
- To submit applicants’ information and application materials to our UK University Partners, which includes providing your details to the universities to which you apply (see Section 2 – The Application Process), and to confirm offers, conditions, and later university enrolment;
- In order to keep you informed by email or other electronic means of the news, events, or services that may be of interest (provided you have opted-in to receive such communications). Existing applicants and Across the Pond alumni may be contacted under the purposes of legitimate interests;
- To improve the service to our clients and to analyse our website’s use without identifying you as an individual;
- We will use enquiry and application data to better inform our market activities. Additionally, we may ask you to participate in surveys which assist us in improving our services to existing and potential applicants;
- To carry out obligations to you, such as notifying you about changes to our terms and conditions.
6. When we will contact you
Across the Pond may contact you:
- In response to any correspondence or enquiry we receive from you or any comment or complaint you make about Across the Pond’s services;
- To invite you to participate in surveys about our services, our partner universities, or research into your activities and career progression after attending one of our partner universities (participation in these surveys is always voluntary);
- In relation to an application you have made via our service or to help you reset your password or troubleshoot any issues you may experience when accessing online content or within the online application portal;
- To notify previous applicants of opportunities for further study in the UK and/or vacancies within Across the Pond;
- For marketing purposes whereby you have opted-in to receive emails related to any of the following: Blog posts, upcoming events/webinars, scholarships, application; deadlines, specific course/subject information, or partner university news. You can OPT-OUT or UNSUBSCRIBE to these emails at any time by clicking on the link contained at the bottom of Across the Pond web communications, or alternatively by sending an email request to info@studyacrossthepond.com.
7. Sharing your information
Across the Pond will not sell or give your data to other organisations or universities for marketing purposes unless specifically authorised by you. By submitting an enquiry, you are agreeing to personal contact from an Across the Pond adviser.
When applying using Across the Pond’s services, we will share applicants’ personal information with the universities and colleges to which you have applied so that they can consider and process your application(s). Sharing of personal data will always be undertaken in line with the requirements of data protection law and will only be transferred via the Universities and Colleges Admissions Service (UCAS), individual university application service/agency portal, or by other secure methods as outlined by our university partners. The personal data that is actually shared will always be limited precisely to what the other organisation needs to meet its requirements or to deliver its services. If you object to your personal information being shared by Across the Pond, you can let us know at the time you apply or at any other time by emailing the Data Protection Officer: dpo@studyacrossthepond.com.
We may pass some of your data to other organisations if this is required by law, is necessary for the prevention or detection of crime, or is specifically authorised by you.
Please note that in most cases the Organisation is unable to disclose information about students in response to third party requests (including those made by parents for students over the age of 18) without the prior written consent of the individual concerned, unless it is necessary to do so in order to comply with legal requirements or to prevent or detect crime.
8. Where we store your personal information
The data that we collect from you is stored within our secure internal systems. This data may be processed by staff operating outside the EEA who work for us or one of our suppliers.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Where we have provided you (or where you have chosen) a password which enables you to access certain sections of our website, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone else.
9. How long will Across the Pond keep your information?
Across the Pond takes its obligations under the GDPR very seriously and endeavours to not hold onto any personal data longer than is necessary. The Organisation has a retention schedule in place for the different categories of data that it holds.
In some cases, there are good reasons as to why the Organisation needs to retain certain data about students and other individuals for a significant period of time. The most important reasons are as follows:
- For statutory reporting purposes in order to confirm and monitor applicants’ enrolment at our partner universities;
- For alumni services and ongoing relations/opportunities with the Organisation;
- For careers and employability services and surveys;
- To produce references on request from previous employees; and
- In order to meet pension obligations
Personal and confidential information will be disposed of using methods that protect the rights of those individuals (e.g. shredding, confidential waste disposal, secure electronic deletion).
10. Your rights
Under the DPA, an individual has the following rights:
- To request access to information held about them, the purpose for which the information is being used and those to whom it is, has or can be disclosed to;
- To prevent data processing that is likely to cause distress or damage;
- To prevent data processing for direct marketing purposes;
- To be informed about the reasons behind any automatic decision made;
- To seek compensation if they suffer damage as a result of any breach by the Data Controller;
- To stop the use of, rectify, erase, or dispose of inaccurate information;
- To ask the Information Commissioner to assess if any personal data processing has not been followed in accordance with the data protection principles.
Under the GDPR, an individual has the following additional rights:
- To be forgotten – that is to have their details removed from systems that the Organisation uses to process personal data;
- To restrict the processing of personal data in certain situations;
- To seek compensation if they suffer damage as a result of any breach by a Data Processor;
- To object to the processing of personal data in certain situations, for example sending and receipt of direct marketing material;
- To data portability – to obtain a copy of their data in a commonly used electronic format in order to provide it to other organisations;
- To object to automated decision making and profiling – object to decisions made by automated means without human intervention in certain circumstances;
- To withdraw consent where that is the legal basis of the Organisation’s processing of personal data.
We will use reasonable efforts consistent with our legal duty to fulfil these rights, including to supply, correct, delete, or cease processing of personal information about you on our files. Requests should be submitted in writing via email to the Data Protection Officer or in a hard copy to the postal address provided above. Across the Pond reserves the right to ask you to provide proof of identification and for you to clarify your request if it is unclear in the first instance. You will receive a reply no longer than 40 calendar days from the date you make the request in writing.
If you are unhappy with the initial response to any of the above requests, you can ask the Organisation to undertake a further search if there is specific information you have good reason to believe exists but that has not been provided.
You also have the right to complain to the UK Regulator, the Information Commission’s Office (ICO), if you believe your request has not been dealt with appropriately or if you have a complaint to raise against Across the Pond or any other issue related to data protection. A complaint can be lodged via the ICO website or in writing at the following address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Great Britain
11. Your responsibilities
Any member of staff or other relevant individual who handles personal information for which Across the Pond is responsible must follow the requirements of this Privacy and Data Protection Policy.
This policy was last updated in May 2018. We will continue to adapt this policy to ensure Across the Pond remain compliant with GDPR and the forthcoming UK Data Protection Bill, which is intended to replace the Data Protection Act 1998 and supplement the GDPR.
