BPP Privacy Policy  

What is the purpose of this Privacy Policy?

BPP respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on how BPP collects and processes your personal data through:

a)       your use of BPP websites, including any data you may provide through BPP websites when you make an enquiry or purchase a product or any course/programme (whether online, face to face or distance learning) and whether on behalf of yourself or as an employer client (“Services”);

b)       your registration for, purchase of or use of any BPP products and/or Services (including but not limited to courses, programmes or study materials (in any medium));

c)       your use of any BPP social media channel; and

d)       your sending of personal data to BPP by any other means.

This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

This Privacy Policy is provided in a layered format so, if you wish, you can select the specific areas of the Policy you are interested in, as set out below.  We have also included a Glossary to help you understand the meaning of some of the terms used in this Privacy Policy.

1.       WHO WE ARE

2.      IMPORTANT INFORMATION ABOUT THIS POLICY

3.      YOUR PERSONAL DATA

4.      HOW IS YOUR PERSONAL DATA COLLECTED

5.      HOW WE USE YOUR PERSONAL DATA

6.      DISCLOSURES OF YOUR PERSONAL DATA

7.      VIRTUAL LEARNING ENVIRONMENT

8.      INTERNATIONAL TRANSFERS

9.      DATA SECURITY

10.   DATA RETENTION

11.    YOUR LEGAL RIGHTS

12.   GLOSSARY

 

1.      Who we are

Data Controller

Business Training Romania SRL (trading as BPP Professional Education) is the data controller and responsible for your personal data so when we mention "BPP", "we", "us" or "our" in this Privacy Policy, we are referring to Business Training Romania SRL. 

This Policy shall apply to any BPP website including any subdomains that may be made available by us from time to time; including websites with the ending bpp.ro and all BPP social media channels (“Website(s)”).

Contact details

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details: gdpr@bpp.ro

You have the right to make a complaint at any time to The National Supervisory Authority For Personal Data Processing.  We would, however, appreciate the chance to deal with your concerns before you approach The National Supervisory Authority For Personal Data Processing so please contact us in the first instance.

2.      Important information about this Policy

Changes to the Privacy Policy and your duty to inform us of changes

On 25 May 2018 the data protection law in Romania. This Privacy Policy sets out your rights under the new laws.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We may update this Privacy Policy from time to time. This version was last updated on May 24, 2018.

If you reject the terms of this Privacy Policy

If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through the Website or any other means.

Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

3.      Your personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Contact Data includes billing address, delivery address, postal address, email address and telephone numbers.

Eligibility Data includes education/academic history and records of qualifications and/or training. For international students this may also include copies of bank statements or other financial information to ensure visa requirements are met

Employment Data (this is relevant where your place on a course or programme is sponsored by your employer/future employer) includes name of employer, job title and work contact details (email address, telephone number and postal address).

Financial Data includes bank account, billing information, invoicing details and payment card details.

Identity Data includes first name, maiden name, last name, student reference number, username or similar identifier (including any student registration number assigned to you by an external body who shares information with us such as ACCA, CIMA or CIA), marital status, title, date of birth and gender.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Profile Data includes your usernames and passwords (for BPP platforms), purchases or orders made by you, your interests, preferences, feedback, survey responses and enquiries submitted to BPP.

Student Data includes the course or programme you are studying with BPP, your years of study, records of achievements on the course or programme (exam, assessment and mock results), exam scripts, exam transcripts, attendance and progress information, feedback from lecturers or personal tutors (including student references), emails sent by you to BPP, emails sent/received by you to or from your BPP email address or messages posted on BPP’s VLE, information relating to your involvement in BPP’s alumni network, information relating to your registration for or attendance at any BPP hosted/advertised events, information relating to allegations of academic misconduct or other matters of discipline, information relating to any application for mitigating circumstances, any application for deferrals and any complaints made by you or about you to BPP.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, including records of any discount codes used.

Usage Data includes information about your visit to a Website, including the Uniform Resource Locators (URL) clickstream to, through and from the Websites (including date and time), products and/or services you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and any phone number used to call our customer services numbers.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

The law requires that "special categories" of particularly sensitive personal information require higher levels of protection than other personal data.

In some circumstances we may also collect, store and use the following “special categories” of more sensitive personal information:

Information about your nationality and immigration status – this information is required to ensure that, where relevant, prospective BPP students have the correct visa or right to study in order to enrol onto a course or programme.  Accordingly, we will collect information such as copies of passports, copies of visas.  We cannot enrol any students onto a course or programme without completing these checks.

Medical information – this information may be collected where a medical issue is having an impact on your studies with BPP (for example, you may have a prolonged period of absence; or you make an application for a deferral where an illness is preventing you from studying; or where a medical issue has affected your performance in or attendance of an exam).  It may also include dietary requirements where you are attending a catered BPP event.  This information is voluntary.

If you fail to provide 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 enrol you onto a relevant course or programme or provide goods or services to you). In this case, we may have to withdraw your application or cancel/restrict a product or Service you have with us, but we will notify you if this is the case at the time.

4.      How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Eligibility, Employment, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

a)       apply for a course or programme;

b)       submit an online query or request a call back;

c)       purchase goods or Services from us;

d)       speak with one of our teams;

e)       create an account on our Website;

f)        subscribe to a service or publication;

g)       subscribe, register, take part in or view any BPP webinar;

h)       request marketing to be sent to you;

i)         enter a competition, promotion or complete a survey; or

j)         give us feedback.

Through your Studies. You may give us your Student Data throughout your time on a course or programme.  This includes personal data you provide when you:

a)       attend lectures, seminars, webinars or other learning sessions;

b)       submit work for assessment;

c)       take exams or other forms of assessment;

d)       submit any applications relating to your studies;

e)       raise any issues or questions with your lecturer; or

f)        contact one of our teams.

Third parties. We may receive personal data about you from various third parties as set out below:

Contact, Eligibility, Employment and Identify Data from your employer where your employer/future employer is sponsoring your place on a BPP course or programme;

Identity, Eligibility, Transactional and Student Data from any external awarding bodies which you may be registered with in order to complete the course or programme you are studying with BPP, including ACCA, CIMA or CIA;

Identity and Student Data from any third party assessment/examination centre or external exam marker or invigilator ;

Student Data from any freelance tutor or external presenter engaged by BPP who has delivered teaching to you as part of your course or programme;

Identity and Student Data from any third party assessment/exam portal provider;

Identity and Student Data from any third party survey organisation or portal provider;

Technical Data from analytics providers such as Google; advertising networks; and search information providers;

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

5.      How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Where we have your consent.

Where we are relying on your consent as a legal basis for processing your personal data, for example where we collect voluntary “special category” personal data (as set out in this Policy above) you may withdraw your consent to this processing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Please be aware that, if you are a student with BPP, in the majority of cases we will have a contract in place with you in respect of the course or programme you are undertaking.  Therefore, our lawful basis for processing your personal data will be to perform our contract with you.

However, in some instances we will have a contract in place with your employer or prospective employer.  For example, some businesses will ask BPP to deliver a bespoke course or programme to a group of its employees.  In these cases, BPP has a contract in place with your employer and not you as an individual.  In these scenarios, BPP will process your personal data as necessary for our legitimate interests, i.e. the delivering of services to your employer under a contract in place between BPP and your employer.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

Less commonly, we may also process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent (for example if you suffer a medical problem whilst on BPP’s premises).

Consent

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations.

In limited circumstances (as set out above), we ask you for your written consent to allow us to process certain particularly sensitive data. When we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

You should be aware that it is not a condition of your contract/right to study with us that you agree to any request for consent from us.  However, we may not be able to provide you with certain services (such as learning support) if you do not agree to provide such data to us.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

Where we have notified you of the decision and given you 21 days to request a reconsideration.

Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do use automated technologies and decision making when deciding what marketing messages you receive.  However, we do not envisage that any other decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  We will only send marketing where you have agreed to receive marketing from us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or Services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the BPP group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you entering into a contract with us.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6.     Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

Specific third parties marked with ^∆ listed in paragraph 4 above (under the ‘Third parties’ heading).

Specific third parties listed in paragraphs 7 and 8 below. 

External venues where some element of a course or programme (or event) is delivered (BPP may share Identity Data with the venue for registration and health and safety purposes).

Future employers or education providers where you specifically request that we provide confirmation of Identity or Student Data to those parties for reference purposes.

Third parties to whom we may choose to sell