1. INTRODUCTION
This Data Protection Notice sets out how King’s Evangelical Divinity School (”we”, “our”, “us”) processes the personal data of students and alumni.
King’s Evangelical Divinity School is a Data Controller and is located at Kent Innovation Centre, Millennium Way, Broadstairs Kent CT10 2QQ, UK.
Any queries relating to this notice can be directed to office@kingsdivinity.org
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, voicemail, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Student Billing Data includes data relating to any purchases of courses, materials, teaching or other goods and services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details or other transaction information. We process this data to supply the teaching materials or goods / services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services such as the student eCampus. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and eCampus, to administer the website and enable our teaching and operations to support you and other students, and to deliver relevant website content. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and eCampus.
Fundraising and Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as special offer pricing on courses or books, and to deliver relevant website content to you and measure or understand the effectiveness of this outreach. Our lawful ground for this processing is consent or our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our school community and to decide our marketing and fundraising strategy.
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. However you can still opt out of receiving marketing emails from us at any time
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including website display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our school. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Student teaching and learning data that includes information about your grades, academic performance, academic progression, teaching and learning statistics, teaching and learning feedback, subject choices and preferences, academic interests, academic preferences and goals including career aspirations. We process this data to deliver our teaching and support services to you either as part of a degree programme or as part of our unaccredited internal courses. For degree courses, our validating university is a joint Controller or Controller. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Admissions data includes information you submit in the application form when you apply for a place at our institution. It also includes any information provided by your references or recorded by us as part of our admissions review process. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Special Category Data
We may collect the following sensitive data about you in order to handle your application to our institution (note that you are not required to provide this information as part of your application):
- Health and medical information or special education needs that may be relevant or pertinent to your expectations or requirements as a student. This is necessary for the purposes of health or social care or to meet our legal obligations in providing our services.
- Religious or philosophical information such as the background or circumstances relating to your faith. This may be necessary as part of our legitimate activities involving our philosophical or religious aims as a not-for-profit body.
Note:
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
3. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below:
- Our partner university who validate our degree-level courses. They act as Controllers or Joint Controllers in aspects pertaining to the provision, grading and awarding of degrees and assessment.
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Note on Joint Controllership:
KEDS considers itself to be a joint controller for the processing of personal data of people studying for University of Chester awards. This means that personal data is disclosed or shared with the University for the purposes of registration, portal access, assessment, technical support, academic provision, awards, graduation and general administration necessary for the provision of University of Chester degrees and courses. The University’s privacy notices can be found here.
4. INTERNATIONAL TRANSFERS
We may transfer your personal data outside the UK such as when we use an IT cloud service provider for hosting data or providing email services. Where such transfers are restricted transfers under the UK GDPR, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
We may transfer your personal data to countries identified by UK Authorities as providing an adequate level of protection for personal data; or
We may use specific contracts (e.g. IDTA or SCC), codes of conduct or certification mechanisms approved by the UK Authorities which give personal data appropriate protection.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
5. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a genuine need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
6. DATA RETENTION
We will only retain your personal data 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.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at the website of the UK Data Protection Supervisory Authority:
If you wish to exercise any of the rights set out above, please email us at office@kingsdivinity.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
8. COOKIES AND THIRD-PARTY LINKS
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
This 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Last updated: May 2023