This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain. The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects.
These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.
The Open College is strongly committed to protecting the privacy of its user and student community. The intent of this privacy statement is to detail the information The Open College may gather about individuals who visit its website and how that information is used.
What Information do we collect?
The Open College collects information to operate effectively and provide you with the best teaching experiences. Personal information is collected directly from you and other information is collected when you interact with our websites, products and services.
Personal information is any information about an identifiable individual and is collected directly from you. Personal information you provide us may include information such as your name, email address, billing address, telephone number, personal profile and PPS numbers (enrolled student only).
The Open College may collect personal information directly from you when you:
- create an Open College account
- participate in forum discussions
- purchase or subscribe to courses
- download our software or other content
- contact The Open College support teams
- visit our websites, and
- submit web forms on our websites
- communicate with us
You can always choose not to provide personal information to The Open College, but if you choose not to do so, in many cases we will not be able to provide you with our products or Service, or respond to any queries you may have.
The Open College may combine personal information with other information that does not, on its own, directly identify you (“non-personal information”).
For example non-personal information such as which parts of our websites you have visited may be associated with your Open College account. This allows The Open College to provide you with a more personalised experience such as keeping you up to date with relevant course releases, content and sales via marketing communications (with your consent). If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
Other information we collect
We also collect information when you interact with our courses, websites and services. The following are some examples of information we may collect when you interact with particular Open College Services:
The Open College Websites
We collect information when you use our websites. We may collect information sent by your browser to our servers whenever you visit The Open College’s website. For example your browser may tell us your IP Address as well as browser type and language, URLs of referring/exit pages, operating system, time/date stamp, system configuration information and documents and files that you downloaded. We also may collect information about how you use our websites, such as which parts of our website you have visited, by using cookies and similar technologies.
Open College Products
We collect information when you use our products. The following types of information may be collected:
- System information such as operating system, processor, and computer type
- General usage information such as features used, devices connected and length of time using the course.
Certain information that we collect when you enrol with us is absolutely necessary in order for us to provide you with our Service. You won’t be able to opt-out from the collection or processing of this information as it is mandatory for completion and certification on our courses.
Emails or Newsletters we send you may include technology that tells The Open College whether you have received or opened an email, or clicked a link in the email. Marketing emails we send you may be tailored based on your interactions with our websites and courses. If you do not want us to collect information from The Open College emails, or you don’t want to receive The Open College’s marketing emails anymore, you can unsubscribe by using the unsubscribe link within each email or by changing your notifications settings when logged into your Open College account.
The Open College Online advertising
The Open College does not store your credit card details
Any payment information, excluding name and contact details, provided by you is not stored by us. Enrolments from The Open College, either on The Open College’s websites or by phone, that require the inputting of credit card information use specialised credit card payment service Global Payments (formerly Realex) for the purposes of processing credit card data.
Cookies and Similar Technologies
More specifically a “cookie” is a small text file which is stored, either on your hard drive, or in memory until your browser is closed. Cookies are used by The Open College to enhance your experience of the site and facilitate ease of navigation through the website. We also collect statistical data via the website, which allows us to assess the number of visitors to the website and to identify what page is viewed most frequently.
- Google Analytics (Analytics)
- Cloudflare (Functionality & Analytics)
- We use this cookie to identify trusted web traffic. It does not correspond to any user id in the web application, nor does the cookie store any personally identifiable information. It is also used to analysis browsing activity across our website to establish user profile and to aid in user experience solutions.
- Zopim (Functionality)
We use Zopim Live Agent to enable us to live chat with you with on theopencollege.com. No personal data is retained by The Open College.
- Pubble Q & A (Functionality)
We use the Pubble Q & A tool to enable us to answer questions raised by you on our website. Users have the option before they ask any question to remain anonymous. No personal data is retained by The Open College from these sessions.
- Facebook (Analytics)
We use Facebook as a medium to talk to customers and to measure effectiveness of campaigns.
- LinkedIn (Analytics)
We use LinkedIn as a medium to talk to customers and to measure effectiveness of campaigns.
- Twitter (Analytics)
We use Twitter as a medium to talk to customers and to measure effectiveness of campaigns.
- DoubleClick (Analytics)
We use DoubleClick to help manage our digital marketing activities. These cookies set by a third party (DoubleClick) and are used for serving targeted advertisements that are relevant to you across the web. Targeted advertisements may be displayed to you based on your previous visits to this website. For example, advertisements about a topic you have expressed an interest in while browsing our site may be displayed t you across the web. In addition, these cookies measure the conversion rate of ads presented to the user. For more information, please visit www.google.com/policies/privacy/partners/. If you wish to disable DoubleClick cookies on your browser please visit this website.
How to control and delete cookies
By using our Website, you agree to us placing these sorts of cookies on your device and accessing them when you visit our Website in the future.
If you want to delete any cookies that are already on your computer, the “help” section in your browser should provide instructions on how to locate the file or directory that stores cookies.
Please note that by deleting or disabling future cookies, your user experience may be affected and you might not be able to take advantage of certain functions of our Website, and the complete Open College user experience that we pride ourselves on providing our customers. In addition, disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser.
How we use your information
Your information may be used by The Open College for purposes such as:
- Enabling us to provide you with our courses, websites, services, support or information you have requested.
- Sending you marketing, advertising, educational content, promotional messages and other information that may be of interest to you. These messages may be tailored based on your interactions with our websites and products.
- Sending you course information , administrative messages, reminders, assessment notices, updates, security alerts and information requested by you.
- Improving our courses and services and developing new courses and services.
- Diagnosing problems in our courses and websites.
- Registering and activating your Online Learning Accounts.
- Enabling you to participate in forum discussions.
- Enabling you to make purchases.
- Providing customer support.
- Conducting research about our customers and statistical analysis (on an anonymised basis).
- Protecting and/or enforcing our legal rights and interests, including defending any claim.
- For any other purposes authorised by you.
Who we share your data with
- QQI (Quality Qualifications Ireland)
QQI is the National Awarding body for Further Education & Higher Education awards in Ireland. After you have completed a QQI award with The Open College we must provide QQI with some of your personal information in order to finalise the certification and release of your QQI Award from QQI. Data such as your Name & PPSN number are entered onto the QQI awards system. The following link on QQI’s website will explain why such data is requested and returned. https://qhelp.qqi.ie/learners/gdpr—my-data/
Data is held in Ireland using different (multiple) servers. The Open College does not store personal data outside the EEA.
Securing your Data
The Open College takes technical measures as well as organisational security measures which are set out in law and by industry standards to ensure that we protect your personal data from unauthorised access, use or disclosure.
We will ensure that we use your personal information as set out in our privacy notice and to the choices that you have made regarding permission. The Open College only partner with reputable service providers who contract to provide the same level of security on information so that your data is at all times protected and used in accordance with our Privacy Notice.
Retention Policy & Retention of Learner Information
The Open College will process personal data during the duration of any contract and will continue to store only the personal data needed in accordance with our Data Retention Policy and as required by Law or Regulations.
Call Detail Records:
- Call detail records will remain for periods up to 1 year.
- By law we must retain call detail records for a period of 2 years. Records are located in a secure area.
Recorded Calls are stored for a period of up to 30 days.
Legally invoice details are required to be maintained for a period of 6 years and the current year.
Student / Customer Support:
The Open College maintains Learner files for a period of 2 years only. After 2 years all the student information is securely destroyed using Secured Shredding and Recycling companies. Learners files will not be accessible after 2 years and learners who have not completed their course at that stage will need to enrol again and pay the appropriate costs if applicable.
- Original learner files for all active participants will be maintained for a maximum two-year period, after this time has lapsed and in the instance of an incomplete programme all information will be destroyed securely and the learner may need to re-register.
- Original learner files for all participants who have successfully completed their programme/s will be destroyed pending the release of certificates to learners. Learners will be sent an email to inform them of this and they will be invited, if they wish, to collect any assessments in accordance with specific timescales agreed by the college.
- Learner information for both existing and new students will be securely maintained in a learner database for a period that the college deems appropriate and in line with the above. Soft copies of registration documents and copies of certificates will be maintained for all learners and archived for accessing as when/if needed.
No Financial Information is stored either hard or soft copy in any of the cases above.
Images are kept for 28 days, unless a request is made from the Police then it can be kept for 2 years which is stored locally.
- Session cookies are only stored on a per session basis to assist in the customers navigation of our web-sites, so that we offer personal content for you.
- Persistent cookies are only stored to assist in the customer’s navigation of our web-sites using the stored data to display related preferences.
- Customer can control cookies by changing the options on their own PC. For more See http://www.allaboutcookies.org/
Your rights as a data subject
At any point whilst The Open College is in possession of or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. This will not be possible while students are completing their courses.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the personal data we hold about you transferred to another organisation. This would exclude any Open College information for example – Course content ans Assessment Briefs etc.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that The Open College refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
The Open College at your request, can confirm what information it holds about you and how this information is processed.
You can request the following information:
- Identity and the contact details of the person or organisation (The Open College) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of The Open College or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (Data Protection Regulator).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required
The Open College will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If The Open College is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to the Data Protection Officer at firstname.lastname@example.org or writing to us at the address further below.
Link to Third Party Sites
Please note that this policy applies only to The Open College’s website and not to the websites of other companies or organisations to which we provide links. Any third-party websites are viewed at your own risk.
This Privacy Statement is governed by the laws of Ireland and you submit to the exclusive jurisdiction of the Irish Courts.
In the event that you wish to make a complaints about how your personal data is being processed by The Open College or its partners, you have the right to complain to The Open College. If you do not get a response within 30 days, you can complain to the Data Protection Regulator.
The details for each of these contacts are:
The Open College
Attention of the Complaints Department
Leopardstown Business Centre, Ballyogan Road
Dublin 18, Ireland.
Telephone +353 1 2061828 or email email@example.com
Data Protection Regulator
Canal House, Station Road
Co. Laois, R32 AP23
Telephone +353 761 104800 or email: firstname.lastname@example.org