What is the purpose of this document?
This privacy notice outlines how we, Cambridge Occupational Analysts Ltd registered company number 02049351 (“COA”), collect, store and use the personal data that you or your school, provide to us in relation to the careers assessment programmes that we offer to students. The purpose of our assessment programmes is to give you feedback and guidance to help you make informed choices about your future educational choices and careers.
COA is committed to safeguarding your personal information. Whenever you provide personal information to us, including any information provided via your school, we are legally obliged to use it in accordance with all laws concerning the protection of personal information (we refer to these laws collectively in this privacy notice as the “data protection laws”).
This privacy notice applies to students participating in our careers assessment programmes and/or using our website or attending our events. We are required under data protection laws to notify you of the information contained in this privacy notice.
It is important that you read this notice, together with any other privacy notice or policy we may provide on specific occasions when we are collecting or processing personal information.
What information will we collect about you?
Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, store, and use the following categories of personal information about you:
- Identity details such as your name, gender and age / date of birth.
- Contact details such as your postal address and email address.
- Educational details such as your educational achievements (including past and predicted grades) and other related details which we may analyse in conjunction with any interest inventories and tests that you complete as part of our assessment programmes.
- Usage and technical data about to how you use our website and software services.
We may use the personal information that you or your school provide to us for both research purposes and improving our services although in these circumstances we will only use your information in an anonymised form.
We may, in limited circumstances, collect and use some information about your health such as your dietary requirements (if you are attending an event) or any medical condition or disability that you have (if you are participating in our assessment programmes). These are "special categories" of more sensitive personal information, which we explain in further detail in the next sections.
Unless we tell you otherwise, we will not collect and process any other “special categories" of more sensitive personal information (such as information about your race, ethnicity or nationality, religious beliefs and sexual orientation).
How will COA collect and use your personal information?
We typically collect your personal information in the following ways:
- We will often obtain your personal details from you directly when you participate in our careers assessment programmes (including the interviews you attend and the interest inventories and tests that you complete using our software).
- We may be provided with your personal details via your school in the course of their administering the careers programme with you.
- In limited circumstances, your school may give us sensitive personal information about you (known as “special categories” of data), namely: (i) information about your dietary requirements if we are holding events at your school; and (ii) any relevant medical condition or disability that may be relevant to the advice and guidance we will provide to you as part of our careers assessment programmes.
- We may also collect technical data about your browsing actions and patterns as you interact with our website and assessment software. We collect this personal data using cookies, server logs and other similar automated technologies.
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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
- where we need to comply with a legal or regulatory obligation.
We explain how we use your personal information in more detail below.
Purposes for which COA uses your personal information
Providing our careers services:
We will use your personal information primarily for the purpose of providing our assessment services to you. This will involve giving you feedback and guidance to help you make informed choices about your future educational choices and careers. We use the information that we collect about you to tailor our feedback and guidance to you and your specific educational background, interests and career preferences. We do not use the results of the assessments to make decisions for or about you.
COA’s legal basis for processing your personal information in this way is through your consent in agreeing to participate in the careers programme, and we ask the school or independent careers advisor to obtain your consent to share that data with us. The processing is also necessary for our legitimate interests, which are to hold our careers events and provide our assessment programmes to you as explained above. You are not obliged to provide your personal information to us but, without it, we are unlikely to be able to provide you with feedback and specific guidance on your future educational choices and careers.
In cases where your school gives us any “special categories” of personal data about you (in the limited circumstances explained above), we ask the school to obtain your consent to share that data with us. You are not obliged to give your consent for these “special categories” of data to be shared with us. However, if we do not know about your dietary requirements, we will not be able to accommodate your dietary needs at our events. Similarly, if we are not told about any relevant medical conditions or disabilities that you have, then the careers advice and guidance that we give to you may not be appropriately tailored to your situation.
Protecting and developing our business:
Where we collect usage and technical data relating to your use of our website and software, we use that data to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, hosting) and to improve our website, products, customer relationships and experiences. This is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to prevent fraud as well as to keep our website updated and relevant and to develop our business).
How will COA share and disclose your personal information?
We may share your personal information with third parties where required by law, where it is necessary to administer our working relationship with you or where we have another lawful basis for doing so.
We ensure that access to your personal information is subject to restrictions on use and confidentiality commitments. Your personal data will be treated as confidential and will only be accessible by and/or disclosed as follows:
- to our data processing staff and careers analysts/interviewers (who may be COA staff, consultants and/or sub-contractors);
- to our IT service providers for the provision of IT services including support, hosting and data analytics;
- to appropriate staff at your school (such as your careers teacher);
- to your parent or guardian;
- at your request or with your consent; or
- for the purpose of investigating or preventing fraud or if the law otherwise permits it.
We will not disclose the results of your careers assessment to your parent or guardian if you write to us and ask us not to (in which case, any such disclosure will be a matter for you to decide with your school).
Our staff, careers analysts/interviewers and third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our staff, careers analysts/interviewers and third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer (or permit our third party service providers to transfer) your personal information outside of the European Economic Area.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from us using the details in the “Contacting us” section below.
We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will COA keep your personal information?
We will not retain your personal information for longer than necessary but, in case you want us to provide follow-up services to you at a later date, we will keep your personal information for a certain number of years after you have completed the programme. The number of years that we will keep this information will depend on the programme you completed:
Period data is kept after testing is completed
Preview (including all variations)
If you would prefer that we didn’t retain your personal information over this period of time, please write to us to let us know (using the details specified in the “Contacting us” section below) and we will remove it from our systems.
We may, however, anonymise the results of your careers assessment and keep that information indefinitely for the purpose of researching and analysing educational and careers trends from time to time and for the purpose of improving our services.
Your data protection rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information. This may include the following rights:
- Request access to your personal information. Information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information. This right applies 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 personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party. (known as the “right to data portability”).
- Right to withdraw consent. In any circumstances where we have relied on your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. This will not affect the lawfulness of any processing carried out before you withdrew your consent.
If you wish to exercise any of the rights set out above, please contact us using the details in our “Contacting us” section below.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 and keep you updated.
Data Protection Authority
You have the right to make a complaint at any time to the UK supervisory authority for data protection issues. This is the Information Commissioner's Office (ICO) whose details can be accessed via the ICO website at https://ico.org.uk/global/cont...
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do get in touch using the details in our “Contacting us” section below.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please let us know using the “Contacting us” details below.
Our details are as follows:
Cambridge Occupational Analysts Ltd
Joseph King House
Abbey Farm Commercial Park
Horsham St Faith
Tel: +44 (0)1362 688395
COA Privacy Notice for Students May 2018 v0.3