BACKGROUND:

Dignity Health Global Education understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.dhge.org (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Through continuing to browse our website you accept our privacy policy.

 

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

 

2. Information About Us

Our Site is owned and operated by Dignity Health Global Education, a limited company registered in England under company number 11509180.

Registered address: Belmont House, Station Way, Crawley, West Sussex RH10 1JA.

Data Protection Officer Contact: legal@dhge.org

 

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data.

  2. The right to access the personal data we hold about you.

  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.

  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.

  5. The right to restrict (i.e. prevent) the processing of your personal data.

  6. The right to object to us using your personal data for a particular purpose or purposes.

  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

  9. Rights relating to automated decision-making and profiling.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first.

 

6. What Data Do We Collect?

Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see and our Cookie Policy

 

Data Collected

How we Collect the Data

Identity Information including name, title, date of birth.

Inquiry forms across various landing pages and applications forms. Social media sites, cookies and third-party analytics tools.

Contact information including address, phone number, email address.

Inquiry forms across various landing pages and applications forms. Social media sites, cookies and third-party analytics tools.

Business information including business name, job title, profession.

Inquiry forms across various landing pages and applications forms. Social media sites, cookies and third-party analytics tools.

Payment information including card details, bank account details.

Online payment forms.

Profile information including preferences, interests, purchase history, browsing history.

Inquiry forms across various landing pages and applications forms. Social media sites and cookies.

Technical information including IP address, browser types, operating systems.

Inquiry forms across various landing pages and applications forms. Social media sites, cookies and third-party analytics tools.

Data from third parties.

Third party websites, partners (see http://dhge.org/partners/ for our full list of partners) service providers, your employer.

Qualifications and educational background.

Inquiry and application forms across various landing pages and websites. Social media sites, cookies and third-party analytics tools.

 

7. How Do We Use Your Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data and our lawful bases for doing so:

 

What We Do

What Data we Use

Our Lawful Basis

To respond to your request for a call (or email) back, course inquiries, applications

Identity

Contact

Business

Performance of a contract with you (in our anticipation of entering into such contract with you)

To enrol/register you as a new candidate and provide student number

Identity

Contact

Business

Payment

Education

Performance of a contract with you

Direct marketing of or about student benefits and opportunities, University activities and events, services or career opportunities and professional and industrial bodies wishing to communicate with students about career opportunities.

Promotion of University or school via prospectus containing images of current students.

Identity

Contact

Consent

Equal opportunities monitoring (for some but not all of our institutions)

Identity

Legal obligation

Federal and state laws

Personalizing and tailoring our products and services for you

Profile

Technical

Data from third parties

Consent

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, phone, post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties whose content appears on Our Site may use third-party Cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

8. How Long Will You Keep My Personal Data?

We will retain your personal information for the length of time needed to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

 

9. How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some of your personal data within the European Economic Area (the “EEA”). We may also store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We may share your data with third parties that are based outside of the EEA. The following safeguards are applied to such transfers:

  1. We may transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.

  2. We may use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.

  3. Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

Please contact us for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following: 

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

 

10. Do You Share My Personal Data?

We may share your personal data with other companies for sales and marketing purposes globally

Recipient

Activity Carried Out

University partners

To fulfil our contracted responsibilities with the partner, including application processing, enrolment, student support, teaching and graduation

Service providers

We may share your information with our service providers that provide business, professional, or technical support functions for us. In particular, we use third-party providers of website hosting, maintenance, marketing services, courier services, certification services, business operations, payment services, and identity verification services.

Your employer

We may share your information with your employer, in the event that the employer is paying for your Course. Information disclosed in this case shall include Course performance information, unless otherwise expressly agreed in writing with DHGE.

Legal and Regulatory

We may access or share your information to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; as permitted by law; or otherwise as required by law. We may disclose your information to protect the security of the Course, the Websites, servers, network systems, and databases. We also may disclose your information as necessary if we believe that there has been a violation of our Terms and Conditions (including investigation of potential violations thereof), any other legal document or contract related to the Websites, or the rights of any third party.

Fraud and Security

We may access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.

Other

 

We may share information with third parties when we have your consent, or otherwise as described to you at the point of collection.


If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy. If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

11. How Can I Control My Personal Data?

  1. In addition to your rights under the Data Protection Legislation, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails or contacting us.

  2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.

 

12. How Can I Control My Personal Data?

You may access Our Site without providing any personal data at all.

You may restrict our use of Cookies. For more information, see our policy

 

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent via email to legal@dhge.org  

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

14. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact us at legal@dhge.org 

 

15. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated on 16th January 2019.