Privacy for access and participation

Privacy for access and participation – Bath Spa University

How we process your data is governed by the General Data Protection Regulation and associated data protection legislation.

This information applies to the use of your personal information when you participate in activities with the University’s Access and Participation Office.

The Access and Participation Office works collaboratively with schools, colleges and community groups in Bath and North East Somerset, Wiltshire, Swindon, Bristol, South Gloucestershire and North Somerset. Therefore, if we collect and process data about you, you may be a pupil, school staff member, teacher, parent, guardian or care giver. You may also be a Bath Spa University student employed by the Access and Participation Office.

This explains how Bath Spa University collects, uses and shares your personal data, and your rights in relation to the personal data we hold.

How do we obtain your personal data?

If you are aged 13 years old or above, we receive your data:

At our events, when you provide your information in one of our ‘Data Tracking Forms’.

If you are younger than 13 years old, we receive your data:

From your school, after your parent or legal guardian has signed a form to consent to the school providing us with your information.

When your data is obtained from a third party, such as your school, we ensure that this third party has lawful authority to provide us with your personal data, through the provision of signed consent forms.

If you are a parent / legal guardian we will have collected your data via the consent form you sign, which would have been sent to you by the school your child attends, or you would have completeed the form in-person at one of our events.

If you represent or work at a partner institution, school, college, education group or other organisation(s) we will have collected your data via:

A staff cover sheet completed by you at one of our events
Your employer/organisation when you/they provide us with the information, or from a public domain such as your employer/organisation’s website
Our own monitoring information following, previous engagement with your school, college or organisation

If you are a Bath Spa University student employed by us, we will have collected your data via:

The application form you completed when you applied to work for us
The working agreement you signed when you started your employment with us
Our online confidential medical questionnaire
A data consent form completed by you during your employment with us
Bath Spa University's HR department.

What data do we hold?

If you are a participant on one of our outreach activities:

Your name
Your date of birth
Your home postcode
The school/college you attend or have attended
Outreach activities you have participated in with us.

If you are the parent or legal guardian of a participant on one of our outreach activities:

Your name.

If you are an individual with whom we correspond within partner institutions, schools, colleges, education groups and other organisations:

Your name
Contact details, numbers, email address and postal addresses.

If you are a Bath Spa University student employed by us:

Your name and student number
Your payroll number, employment start date and job role
Your contact phone number and email address
Your course and course end date
Details relevant to your work for us, including whether you have access to your own transport to travel to events, and any relevant medical conditions that may require reasonable adjustments.

Why do we process your personal data, and what is the legal basis for that processing?

Bath Spa University is committed to supporting progression and widening participation into higher education, and undertakes outreach activities with schools, colleges and communities in support of this. Our regulatory body, the Office for Students (OfS), requires the University to gather and report on evidence showing how effective these outreach activities are.

In order to show the impact of our activities, we have subscribed to the Higher Education Access Tracker (HEAT). This is a secure online database used by many universities to evaluate their outreach programmes.

If you take part in our outreach activities, we collect your details for the following reasons:

To plan our activities
To monitor participation in our activities
To evaluate and report on the effectiveness and impact of our activities.

Under the GDPR, if you are aged 13 years old or above, we are able to process this data because it is necessary for a task carried out in the public interest.

If you are below 13 years old, we are able to process this data when we have received explicit consent from your parent or legal guardian for us to do so.

If you are a Bath Spa University student employed by us, we collect your details so we can fulfil our contractual obligation to you as your employer.

We will process data in accordance with the GDPR and data protection law and only for the purposes specified to you at the point of data collection, or within a reasonable period of when we receive the data from third parties. More details are available below.

Data supplied directly by you

Purpose, legal basis and justification

Planning our activities, monitoring your participation in our activities, and evaluating and reporting on the effectiveness and impact of our activities

Legal basis: Public task

Correspondance, provision of information regarding our outreach activities and events, information we believe will be relevant based on previous engagement.

Justification: To enable us to inform you of new workshops and events we are running, invite you to on-campus events and facilitate our workshops or fairs at your institution. Also in order for us to be able to report on the number and types of activities we're providing to schools and colleges in accordance with our remit to promote equality of access to higher education for the Office for Students (OfS). So we can provide you with reports on the number and types of activities we are providing you with for your use with your regulatory body, the Office for Standards in Education (Ofsted) or elsewhere.

Legal basis: Public task, Legitimate Interest

To enable the provision of our activities and events to those under 13 years old

Justification: We are required by our regulatory body, the Office for Students (OfS), to work with a wide cross-section of society with the aim of widening access and promoting equality of opportunity within higher education. In order to collect the data necessary to deliver our activies to those under 13 we must collect consent from parents/ legal guardians, those details will be retained within Bath Spa University for the purposes of evidencing consent to provide your child’s data.

Legal basis: Consent

To fulfil our contractual obligation to you as your employer

Justification: If you are a Bath Spa University student employed by us, we need to process some details about you in order to fulfil our obligation as your employer. This is so we can record your hours of work with us, pay you for work completed, and contact you about upcoming shifts.

Legal basis: Contract, Consent

To ensure your safety and the safety of others

Justification: If you are a Bath Spa University student employed by us, we need to process some details about you in order to ensure that your safety and the safety of others are made a priority, and to ensure that the necessary risk assessments take any medical conditions you have into account.

Legal basis: Contract, Consent

Data shared with third parties

Who we share your data with, what we share, and why

The Higher Education Access Tracker (HEAT)

What: Your name, date of birth, home postcode, school / colleges you attend or have attended, and outreach activities you have participated in with us.

Purpose and legal basis: Public task: We are required by the Office for Students (OfS) to report on the effectiveness and impact of our outreach activities. One aspect of this is the rates of participation in higher education of the young people we have worked with. HEAT matches your data with data from third party government bodies, such as the Higher Education Statistics Agency (HESA), the Department for Education (DfE), and the Skills Funding Agency to provide us with this information so we can report on it to the OfS.

Our partner institutions who subscribe to HEAT

Our partner institutions include universities and colleges we work with collaboratively, the Western Outreach Network (WON), and the Wessex Inspiration Network (WIN).

What: Your name, date of birth, home postcode and school / colleges you attend or have attended, and outreach activities you have participated in with us.

Purpose and legal basis: Public task: We are required by the Office for Students (OfS) to report on the effectiveness and impact of our outreach activities. Our outreach activities includes work the OfS requires us to perform collaboratively with partner institutions. If you participate in a collaborative activity, such as through the Western Outreach Network (WON), Wessex Inspiration Network (WIN), or the collaborative Bath Spa University and University of Bath Tutoring Scheme, we may share your data with our partner institutions, so we can report on it collaboratively to the OfS.

Government and funding bodies

Government and funding bodies include the Office for Students (OfS), Higher Education Statistics Agency (HESA), Department for Education (DfE), Skills Funding Agency, University and Colleges Admissions Service (UCAS), and Local Authorities.

What: Your name, date of birth, home postcode and school/colleges you attend or have attended, and outreach activities you have participated in with us. Aggregated and anonymised data on the people we have worked with.

Purpose and legal basis: Public task: We are required by the Office for Students (OfS) to report on the effectiveness and impact of our outreach activities. This includes reporting to them on the number of young people we have engaged with over a period of time, and the rates of participation in higher education of the young people we have worked with. To do this, data may be shared with appropriate government and funding bodies, so we can report to the OfS on the relationship between outreach participation and student success. Once processed, your data will always be aggregated and anonymised where it features in the figures in our reports. This means you will not be identifiable in any way.

Your school or college

What: Aggregated and anonymised data on the people we have worked with.

Purpose and legal basis: Public task: Schools are required to report on activities they are providing for students to their regulatory body, the Office for Standards in Education (Ofsted). When they work with us, we agree to provide them with overview reports on aspects such as the number of activities we have delivered for them, the number of their pupils we have worked with, and rates of progression to higher education of pupils from their school that we have worked with. Your data will be analysed and will feature in the figures we provide. All data will be aggregated and anonymised, so you will not be identifiable in any way.

Data we receive from third parties

Types of data, sources, legal basis and justification

Name, date of birth, home postcode and the school / college you attend

Source: Your school or college.

Legal basis and justification: Consent in the form of a signed consent form completed by your parent or legal guardian. We are required by our regulatory body, the Office for Students (OfS), to work with a wide cross-section of society with the aim of widening access and promoting equality of opportunity within higher education. We use your details to plan our activities, monitor participation in our activities, and evaluate and report on the effectiveness and impact of our activities.

Name, date of birth, home postcode, the school / colleges you attend or have attended, and outreach activities you have participated in

Source: Our partner institutions who subscribe to HEAT.

Legal basis and justification: Public task: We are required by our regulatory body, the Office for Students (OfS), to work with a wide cross-section of society with the aim of widening access and promoting equality of opportunity within higher education. This includes work the OfS requires us to perform collaboratively with partner institutions. If you participate in a collaborative activity, such as through the Western Outreach Network (WON), Wessex Inspiration Network (WIN), or the collaborative Bath Spa University and University of Bath Tutoring Scheme, our partner institutions may collect your data and share it with us, so we can report on it collaboratively to the OfS. Our partner institutions will collect your data in accordance with their own GDPR compliance procedures and will remain the Data Owner. Where your data is processed by Bath Spa University, this will be in accordance with the University’s GDPR compliance procedures, for the legal basis of public task.

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