APPENDIX 1 – ADDITIONAL RIGHTS FOR INDIVIDUALS LOCATED IN THE EU
What personal information is relevant?
How we process personal information
We will rely on performing a contract to process your personal information where we are preparing to enter into a contract with you, or we are carrying out our obligations under a contract with you (such as to provide an educational course to you).
We will rely on a legal obligation to process your personal information where we are subject to a legal obligation, such as when carrying out our government reporting obligations.
We will process your personal information for our legitimate interest to allow you to access and use our website, to send you marketing content we think may be of interest to you, to contact you if you leave your contact details with us or if you otherwise initiate contact with us. You can object to the processing of your personal information for our legitimate interests at any time. See the section below on ‘Objecting to processing’.
If we need to rely on consent, we will ask for consent to process any of your personal information for that specific purpose before we process your personal information for that reason. If we rely on consent and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.
On your written request, we will provide you with a list of third parties we use to process your personal information.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, you can ask us to delete your data: see ‘Access, erasure and data portability’ below for further information.
In some circumstances, we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes, in which case we may use this anonymised information indefinitely without further notice to you.
Extra rights for EU individuals
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal information.
Restricting processing: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Access, erasure and data portability: You may have the right to request details of the personal information we hold about you or to request that we erase the personal information we hold about you or that we transfer this information to a third party.
Rectification: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.