This privacy policy describes how we collect and use your personal data, including data you provide, data collected automatically (potentially including location data), and data we obtain from third party sourcesin accordance with the General Data Protection Regulation (GDPR)
We use the personal data that we collect to carry on various business, institutional, and educational activities. The ways in which we collect and use your data vary depending on the relationship between you and us, as well as Constructor entity with which you interact.
The following section describe in further detail how we collect and use personal data in various circumstances.
Glossary
Where we refer in this policy to your 'personal data', we mean any recorded information that is about you and from which you can be identified. It does not include anonymous data where your identity has been removed.
Where we refer to the 'processing' of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure, deletion or retention.
We and our third party vendors may collect the following personal data:
Contact information, such as your name, home address, email address, phone number and social media usernames.
Cookies and similar technologies that automatically collect information
Location information
Mobile device sensor information, in order to provide you with additional functions and features
Websites and mobile applications
When you use one of our websites or mobile applications certain data is gathered automatically such as your IP address, browser type, and device. Certain web-based forms also collect personal data you provide. We and our third-party vendors collect personal data for the primary purposes of conducting analytics, responding to your requests, and providing you with relevant information. This may include:
To assist in responding to online requests and interactions
To conduct analytics and create custom contact lists in order to operate our website and applications
To collect data about you and your activities online for marketing purposes
The sections below will provide additional information about how we collect and use your data.
Who is using your personal data?
Constructor is the 'data controller' for the information that we obtain from you.. This means that we decide how to use it and are responsible for looking after it in accordance with the GDPR.
We collect the information directly from you. Access to your data will be provided to the staff, who need to view it as part of their work in carrying out the purposes set outherein.. We also share it with the third parties as further described herein.
Admissions and financial aid
We collect and use your personal data when you apply for admission to a program or course offered by us, whether it be in person or online, and when you seek financial aid. The primary source of the data collected is your application. We may request additional data, as example, from available sources when identifying potential candidates for admission in connection with recruitment. The personal data collected by us, or on our behalf, is collected for the primary purpose of considering your application for admission to the relevant program or course, financial aid program, or, if you are admitted and enroll, to enable your education.
Information we collect may include:
Contact information
Demographic information
Educational history and test scores
Personal information
Employment history
Personal financial information
Family information - Payment information
Your personal data may also be shared as necessary to administer your education with other person or entities including faculty and staff, governmental authorities, and third party entities as reasonably necessary to provide you with educational services.
Employees and job applicants
We collect your personal data when you apply for a position with us. We also collect personal data at the start of and throughout the course of your employment. The personal data collected by us or on our behalf is for the primary purpose of facilitating employment, HR-related administrative procedures, and to satisfy legal and contractual obligations.
Information we collect may include:
Contact information
Payment information for purposes of payroll processing
Tax information
Lawful immigration/work visa status
Personal information and history
Employment history
Education history
Family information
Demographic information
Health information
Additional uses of personal data
In addition to the foregoing we may use your personal data for the following purposes:
Conducting our ongoing operations
Administering fellowships, scholarships, grants and other programs
Contacting you to respond to general inquiries
Sending you promotional and marketing materials, newsletters, announcements, event invitations, and other information related to Constructor, its partners and affiliates as we believe may be of interest or relevance, either directly or through third parties
Requesting donations and gifts
Conducting research and surveys to help us improve our services and offerings -Meeting requirements of accreditation, licensing, and other relevant regulatory authorities
Actions related to responding to security and technical or other violations, such as criminal activity, fraud, spam, and intellectual infringement
Meeting and enforcing legal obligations
What is the legal basis of data processing?
Constructor processes the personal data in accordance with the applicable laws and regulations on data protection.
After the submission of an application, we will use your information based on the following legal bases:
performance of our contractual obligations to consider your application and preparing for a future contractual relationship with you (e.g. assess your application to study at Constructor);
compliance with a legal obligation (e.g. monitoring of equal opportunities);
performance of tasks carried in the public interest (e.g. admission research);
pursuit of legitimate interest of Constructor or third-party (e.g. survey invitations).
Where we rely on legitimate interests as a legal basis for the processing of data, we have considered whether those interests are overridden by the rights and freedoms of the applicants and concluded that they are not.
Data sharing with third parties
In order to perform our contractual and other legal responsibilities or purposes, we may, need to share your information with the following types of organisation:
colleges;
external organisations providing services to us, for example our enquiry management and plagiarism detection systems;
external organisations offering sponsored services including but not limited to student surveys, marketing services, event registration and coordination;
the governmental departments or agencies responsible for immigration and student loans;
third parties including your former employer(s) or educational establishment(s) to obtain a reference or to verify the accuracy of a reference or other information you have submitted with or in support of your application;
if you have or are seeking a particular relationship with a third party, for example, because of an exchange scheme;
sponsors or benefactors of funding and financial support;
other Higher Education institutions as part of formal partnerships, cross-registration for courses and events with other universities, research and study arrangements with other educational institutions. Where information is shared with third parties, we will seek to share the minimum amount necessary;
all third-party service providers that process data on our behalf are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.
Transfer of your data outside of the European Economic Area (EEA)
There may be occasions when we transfer your data outside the EEA, for example, to obtain a reference or to verify information in your application. Such transfers will only take place if one of the following applies:
the transfer has your consent;
the transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract or the transfer is governed by approved contractual clauses;
the country receiving the data is considered by the EU to provide an adequate level of data protection;
the organisation receiving the data is covered by an arrangement recognised by the EU as providing an adequate standard of data protection e.g. transfers to companies that are certified under the EU US Privacy Shield.
How long is your data kept?
We will retain your data only for as long as we need it to meet our purposes, including any relating to legal, accounting, or reporting requirements.
If you are admitted as a student, we will retain the personal data collected during the admissions process for 10 years after the start of the academic year in which you were admitted to Constructor. We do this so we can respond to any queries you or third parties may have about your application or studies, qualifications or student experience, to prepare references, to respond to any concerns or complaints and as part of our assessment of any future application you make for further studies at Constructor. We are required by law to retain some data for longer, for example, if you require a Tier 4 student visa to undertake your studies, we will retain your information in order to meet the audit requirements of the Home Office.
If your application is unsuccessful, or you decline an offer of a place at Constructor, we will retain your personal data for 3 years after the start of the academic year for which you applied. We do this so we can respond to any queries you or third parties may have about your application, to respond to any concerns or complaints and as part of our assessment of any future application you make for further studies at Constructor.
If you defer an application from one academic year to the next the above schedules will apply from the start of the academic year to which your application was deferred.
Your core application record (see 'What personal data will be processed?' above) is retained indefinitely to carry out statistical analysis in relation to applicant groups and student population or for historical or research purposes or to meet such reporting obligations as may be imposed on Constructor by relevant authorities, for example the Office for Students. Information held for these purposes will not be used to make decisions about you or to contact you with any marketing or other materials.
Your rights in relation to your data
Under certain circumstances, by law you have the right to:
Request access to your data (commonly known as a "subject access request"). This enables you to receive a copy of your data and to check that we are lawfully processing it.
Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate data we hold about you.
Request erasure of your data. This enables you to ask us to delete or remove your data in certain circumstances, for example, if you consider that there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing.
Object to processing of your data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your data for direct marketing purposes.
Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your data to another party.
Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. However, where you have consented to the processing (for example, where you have asked us to send you certain types of communication), you can withdraw your consent at any time, by emailing us at data.protection@constructor.tech. In this event, we will stop the processing as soon as we can. If you choose to withdraw consent it will not invalidate past processing and it may impact our ability to provide particular additional services to you.
If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, please contact us at data.protection@constructor.tech. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Changes to this Privacy policy
This Policy is effective from 01 March 2019. We reserve the right to update this privacy policy at any time and will seek to inform you of substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
Questions / contact
If you have questions about the processing of your personal information, please feel free to contact our Data Protection Officer by using the following contact details: privacy@constructor.tech