INFORMATION AND DATA MANAGEMENT
County Roscommon Disability Support Group CLG Flexible Learning College (“RSG FLC”) values learner privacy and recognises the need to process learner personal data in a fair and lawful manner in accordance with the legal obligations as set out in the General Data Protection Regulation (GDPR) and the Irish Data Protection Acts 1988- 2018. This privacy statement is intended to provide you with information about the personal information we collect and how that information is used and shared. We respect learner privacy and take every appropriate measure to secure personal data processed by the RSG FLC.
DATA protection Principles
The GDPR sets out a number of principles with which organisations processing personal data must comply. In compliance with these principles, we will ensure that:
- Processing is lawful, fair and transparent
- Data is collected for specified, explicit and legitimate purposes
- Data collected is adequate, relevant and limited to what is necessary for the purposes of the processing
- Data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
- Data is not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which it is processed
- Data is processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical and organisational security measures.
THE INFORMATION WE PROCESS ABOUT YOU
The types of personal data processed by RSG FLC include, inter alia:
Personal data: means any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
Special categories of personal data: are those which reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural’s person’s sex or sexual orientation.
Examples of data held:
RSG FLC processes a number of categories of data regarding learners, including:
- Name and contact details, including personal email address, College email address, postal address and telephone numbers;
- Interaction details such as text/instant message, emails and hard copy correspondence;
- Date of birth;
- Emergency contact details;
- Medical card holder or in receipt of social welfare;
- Modules and programme of study;
- Examination and assessment results;
- Course application details;
- Assignments, portfolios and examination scripts;
- Details previous learning;
- Level of experience;
- Academic Assistance or any other special needs;
- Medical issues;
- Records arising from investigations carried out under College policies, including disciplinary;
- Training Records;
- Complaints and grievances;
- Records arising from the vetting process;
- Images in CCTV footage/photography, filming;
- Stripe (online payment service);
- Financial information bank details including IBAN, BIC, name of bank/building society credit card details (processed in real time but not stored by RSG’S FLC), details on payments and outstanding fees.
HOW does the college OBTAIN LEARNER PERSONAL DATA
We process learner personal data at various points in learner relationship with RSG’S FLC. Much of the learner data that the College holds is collected directly from the learner or is generated by the College during your learning. This information is provided by you, either directly or indirectly.
In certain circumstances, this information may also be provided by third parties like the Department of Social Protection and Quality and Qualifications Ireland (QQI). Please refer to their individual privacy policies available on www.welfare.ie and www.qqi.ie.
Personal data provided by you about others
Learners may provide us with personal data about other individuals, for example, next of kin/emergency, contact details and information about your family circumstances and dependents. The learner must notify the relevant person that they are providing his/her contact details to us as the next of Kin/emergency contact.
Purposes of processing LEARNER PERSONAL INFORMATION
The purposes of processing learner data include:
- Replying to expressions of interest about our programmes of learning
- Organising classes, assessments, examinations and conferring of awards
- Administering financial payments, for example, programme fees
- Monitoring and evaluating the learner feedback
- Promoting RSG Flexible Learning College
- Organising and assessing work placement
- Monitoring learner attendance
- Ensuring the safety and security of learners, employees, visitors and our premises
- Generating of reports for management in order to plan and improve services
- Obtaining legal advice for the establishment, exercise or defence of legal claims
- Providing references for future education and employment
HOW the RSG Flexible Learning College communicates with learners
RSG FLC needs to communicate with learners from time to time in relation to their learning, operational and other matters. The College strives to use the most effective and efficient method when communicating with learners. We may communicate with learners by personal email, telephone call, text message, instant message (WhatsApp, Facebook Messenger) or post to learners home.
RSG FLC utilises a text/instant messaging system to communicate urgent information to learners, for example, regarding the cancellation of classes or change in schedules.
Where the College urgently requires contact with a learner and we have been unsuccessful in contacting learner directly or it is not possible to contact learner directly, we may contact learner designated emergency contact using the contact details provided at registration. We will only disclose the minimum amount of personal data necessary during such communications.
Disclosing information about learners to family or third parties
It is the responsibility of the learner to communicate and engage with RSG FLC. In normal circumstances, the College will not disclose the personal data of learners to family, other relatives or third parties. However, the College may disclose personal data at the learner’s request. This is communicated personally or by email by the learner to the Quality and Training Officer stating that the College may disclose personal data to a named person about a particular matter (mcooney[at]rsg.ie)
In an emergency situation RSG FLC will act in the learner’s best interest and may contact learners designated emergency contact using the contact details provided by the learner.
LEGAL BASIS FOR PROCESSING LEARNER PERSONAL INFORMATION
Data protection law permits us to process personal data only when we can identify a legal basis. A number of legal bases apply to the processing of learner data. These include:
- Where you give your consent for the processing
- Processing is necessary for the performance of a contract or take steps prior to entering into a contract
- Processing is necessary for compliance with a legal obligation to which the controller is subject
- Processing is necessary in order to protect the vital interests of the data subject or another Person
- 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 controller
- Processing is necessary for the legitimate interests of the controller or third party
Recipients of learner data
RSG FLC may disclose learner data to other organisations, including the following:
- Regulatory and accreditation bodies, such as Quality and Qualifications Ireland
- Funding bodies such as Department of Social Protection;
- Third party service providers, who are under contract to the College, including external examiners, insurers, potential employers/recruitment companies for verification of qualifications, An Garda Síochána to assist in the prevention or detection of crime, Stripe (online payment service) legal advisors and auditors;
- The public at large, for example, in the course of conferring ceremonies where learner graduate status or another award is announced publicly, and where learners contribute to promotional materials, including the College website;
- We may disclose your data to any recipient with your consent;
- We will act in your best interests in an emergency situation, for example, disclose medical data to the emergency services in a life-threatening situation;
- Public authorities and bodies where required or permitted by law, for example, the Department of Employment Affairs and Social Protection, Department of Education and Skills; and An Garda Síochána in connection with the prevention, investigation or detection of crime.
Where special categories of personal data are processed, we have to be able to apply a further legal basis to the processing. The usual bases which apply are:
- Your explicit consent for the processing;
- Processing is necessary to protect the vital interests of the data subject or another person;
- Processing relates to personal data which are manifestly made public by the data subject;
- Processing is necessary for the establishment, exercise or defence of legal claims;
- Processing is necessary for reasons of substantial public interest.
INDIVIDUAL DATA SUBJECT RIGHTS
Data subjects have the following rights, subject to a number of restrictions which are set out in data protection legislation:
- The right to information about how we process your data;
- The right to access the personal data we hold about you;
- The right to request the rectification of incorrect or incomplete data;
- The right to request the erasure of data;
- The right to restrict the processing of data;
- The right to object to the processing of data, including where the College relies on its legitimate interests to process personal data;
- The right to data portability, that is, the right to receive your personal data, which you provided to us, and to require the College to transfer it to another controller;
- The right not to be subject to a decision made solely on automated processing, including profiling;
- The right to complain to the Data Protection Commissioner.
In order to exercise any of the above rights please contact us using the contact details set out below.
RSG FLC will not hold learner data for any longer than is necessary. RSG FLC only retains learner personal data for purposes described in this notice, or to comply with relevant legal obligations imposed on us. RSG FLC will hold some of learner data indefinitely in support of learner lifelong relationship with us, or unless you ask us to do otherwise. RSG FLC keeps details of marking for assessment, until the period for potential appeal has lapsed. All learner scripts are shredded after the next certification run at least once a year. A record of shredded assessment evidence is maintained. More information on our retention schedule is available on request.
RSG FLC is committed to ensuring that learner personal data is secure with us and with the data processors who act on our behalf. We have a range of measures in place to protect the integrity and confidentiality of personal data, and to secure it against unauthorised access, loss, destruction or damage.
RSG’S Data Protection Policy (https://rsgcollege.ie/privacy/) explains how data may be gathered about users of the RSG’s FLC’s website.
HOW RSG FLC WILL CONTACT YOU
We contact learners by telephone, email or post. In addition, we may instant message you with information related to learner studies e.g. exam information, room changes, rescheduled classes, appointment reminders, placement arrangements, etc. This contact is to enable us to fulfil our contractual obligations to you.
With learner consent, we may contact you by email or instant message with messages of a marketing nature, for example to promote events, new programmes, etc.
QUESTIONS & COMPLAINTS
If you are not satisfied with the RSG’s FLC’s handling of learner personal data, or believe that the requirements of the Data Protection Acts or GDPR may not be fully complied with, you should contact the RSG’s FLC’s Data Protection Office in the first instance. You also have the right to submit a complaint to the Data Protection Commissioner.
HOW TO CONTACT US
Please contact us if you have any questions about the information we hold about you or to request a copy of that information:
- By email: mcooney[at]rsg.ie
- In writing:
Training & Quality Officer
RSG Flexible Learning College
Co. Roscommon F42 WK60
RSG’s Data Controller is IT and Information Security Officer Shane Browne.
Tel: +353 (0)90 66 25852 (Ext. 800).
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