Student Withdrawal Privacy Notice

Who is collecting the information?

Edinburgh College is the Data Controller. We have an appointed Data Protection Officer (DPO), who can be contacted by emailing: DataProtection@edinburghcollege.ac.uk.

Why are we collecting it, and what are we doing with it (Purpose)?

When you are withdrawn from College, we are required to report your destination to the Scottish Funding Council. By collecting the contributory reasons for a withdrawal, it assists College retention, helping the College identify barriers to a student's education and supporting students in overcoming them.

What personal data do we collect?

Personal data

• Name
• Date of birth
• Student ID
• Student destination (e.g. employment)
• Contributory reasons for leaving (e.g. financial)

Special category data (only where you provide this, or it is required by law*)

• Health (only if it is a contributory reason for their withdrawal)

The lawful basis for the processing

Under GDPR Article 6(1)(e), “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” It is the Post-16 Education Scotland Act 2013, which requires reporting student withdrawal reasons to the Scottish Funding Council.

Where special category (sensitive) personal data is processed, the legal basis is Article 9(2)(g) “processing is necessary for reasons of substantial public interest, based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.” Under the Data Protection Act 2018, Schedule 1 Part 2(6)(2)(b) Statutory etc. and government purposes, the College is required under the Post 16 Education (Scotland) Act 2013 to report withdrawal reasons to the Scottish Funding Council.

Who we share the information with

The College is required to report on student destinations to the Scottish Funding Council. Student destination reporting is conducted securely in accordance with the data-sharing agreement between the College and SFC.

How long do we hold the personal data? 

The data will be retained for 6 years after the end of the current academic year, in accordance with the data-sharing agreement between the College and SFC.

Individuals’ rights in relation to this processing

Under data protection law, you have a number of rights; some of these rights only apply if certain conditions are met. Your rights are: right to be informed (e.g. privacy notice), right of access, right of rectification, right of erasure (commonly known as the right to be forgotten), right to restrict processing, right to object, right to data portability and the right to know of any automated decision making (including profiling). It’s worth noting that you can exercise your rights either verbally or in writing, and the College would be required to process your request within one month.

The rights that apply to this particular processing are:

• Right to be Informed – i.e. a privacy notice.
• Right of Access – this means you have the right to access your personal information.
• Right to Rectification – this means you have the right to correct inaccurate or incomplete personal information.
• Right to Erasure – commonly known as the Right to be Forgotten (RTBF) – this means you can request that your personal data be deleted.
• Right to Data Portability – this means you have the right to request your information in a machine-readable format (e.g. a .csv file) to be provided to you or transferred in that format to another organisation.
• Right to Restriction – this means you can restrict the processing of your information and links with some of the other rights.
• Right to Object – this means you can object to how your data is used.
• Right to be informed of automated individual decision-making (including profiling) – we do not use this for OH purposes, and therefore this does not apply.

Some of the rights above have caveats and only apply in certain circumstances. You can exercise your rights at any time, and the College would be required to answer within a month upon receipt of your request. If you wish to exercise your rights or have any queries in relation to this, please contact the Data Protection Team at DataProtection@edinburghcollege.ac.uk.

Complaints to the UK Information Commissioner’s Office (ICO)

If you are concerned about how your personal data is being used by the College, in the first instance, please contact the College Data Protection Officer (DPO) at DataProtection@edinburghcollege.ac.uk. If you are not satisfied with the outcome, then you can complain to the regulator of data protection, the UK Information Commissioner’s Office (ICO). The ICO guides on the ICO website.

You can email them at casework@ico.org.uk, call them on 0303-123-113, or you can send a letter to them at the following address:

Customer Contact
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF