HEAT Privacy Notice

1. Purpose of this privacy notice

This privacy notice aims to give you information on how we process your personal data that has been collected by us or members of the HEAT Service. It is important that you read this privacy notice together with any other privacy policy or fair processing policy we or any member of the HEAT Service may provide on specific occasions when collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

2. Who are we?

The University of Kent is the controller and responsible for your personal data. Your personal data has been collected by a member of the HEAT Service, who is also a controller and responsible for your personal data.

Enquiries about data protection, including Freedom of Information requests, Subject Access Requests and Data Subject Rights, can be made to University of Kent can be made by emailing datapro@kent.ac.uk or writing to:

The Data Protection Officer, Assurance and Data Protection Team, The Registry, University of Kent, Canterbury, Kent, CT2 7NZ.

Alternatively, The University of Kent is registered with the Information Commissioner’s Office (ICO) Data Protection Register (Number Z6847902) and can be contacted pertaining to the business of data protection.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. Changes to this privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated in August 2024. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

4. What is the HEAT Service and what does it do?

The HEAT Service is a not-for-profit collaboration between higher education providers and third sector organisations enabling its members to monitor and longitudinally track the progression of individuals who have interacted with a HEAT organisation. It is hosted by the University of Kent. The HEAT Service is a research facilitating service that processes personal data and tracks participants for the purpose of monitoring and evaluating equality of opportunity for access and success in higher education. We rely on the following lawful bases as allowed by the UK General Data Protection Regulation (UK GDPR) for processing your personal data as this is necessary for:

• The performance of a task carried out in the public interest (equality of opportunity) or in the exercise of official authority – Article 6(1)(e)
• Our legitimate interests and such rights are not overridden by the interests or fundamental rights and freedoms of the data subjects – Article 6(1)(f)

As we also use your special category data, we must identify a further basis for processing that data. The processing is necessary for:

• Reasons of substantial public interest and is proportionate, respects the right to data protection and provides suitable and specific measures to safeguard the rights and interests of data subjects – Article 9(2)(g). Our substantial public interest reason is equality of opportunity or treatment.

• Archiving in the public interest, scientific or historical research purposes or statistical purposes with a basis in law – Article 9(2)(j).

If you are reading this information, you are very likely to have been contacted and/or offered the opportunity to participate in an activity delivered by a member of the HEAT Service. You may have been asked to provide information about yourself and your circumstances. The purpose of this data collection is to evaluate the impact of member-delivered engagement alongside, specifically but not exclusively, individual information regarding attainment, progression, social mobility, graduate outcomes, and eventual employment.

5. Why is your personal data collected and stored?

In accordance with UK data protection legislation, in providing the HEAT Service we are permitted to store and process individual data for research in the public interest. Personal information is used to underpin research that seeks to make improvements to future activities offered by HEAT member organisations as well as ascertaining the effectiveness of that activity by identifying and questioning purpose. For example:

• Are individuals more likely to progress their educational attainment if they have engaged with a HEAT member organisation?
• Are individuals participating in an activity more likely to progress than those who do not?
• Are organisations efficiently working together to deliver equality of opportunity for access and success in higher education to under-represented groups?
• What can schools, colleges, universities and other organisations do to improve equality of opportunity for access and success in higher education?

6. What personal data is collected and stored?

Personal data means any information about an individual from which that person can be identified. In providing the HEAT Service we store and process information relevant to individuals associated with the provision of activities, including but not limited to, students, student ambassadors, education staff, applicant referees, parents and carers and employees of organisations, and member users. The HEAT member requesting to collect your information may ask and keep one or more of the following information:

• Name
• Address, email address and telephone number
• Date of birth
• Asylum Seeker/Refugee status
• Children of Service Personnel
• Disability
• Ethnicity
• Gender identity
• Local Authority Care
• Religion
• Sex
• Identification number or similar identifier

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

7. How is your personal data stored?

The HEAT Service provides a secure, central online repository within which your information is stored. It does so to support and facilitate the evaluation of work around equality of opportunity, and evidence-based student success research. The service produces standardised or personalised data collection and reporting for members. It provides confidential recording tools to facilitate the reporting of information and individual engagement. It includes:

• Data sharing with researchers
• Importing and exporting tools to ease data capture and outputs
• Individual profiling, for example, using a profiler or the HEAT Advance Programming Interface (API) to help share information efficiently for the purpose of research
• Postcode profiling
• Sharing of information across partner institutions and organisations
• Storage of data that individual organisations use for their own purpose
• Tracking and reporting

8. How is your personal data processed?

The HEAT Service keeps your personal data for the purposes described in Section 5. Why is your data stored? The processing of your personal data is two-fold. Where tracking permission has not been sought/obtained, your personal information is processed to assist with the efficient delivery of engagement. Where consent to be longitudinally tracked has been sought/obtained, your personal information is processed to assist with the efficient delivery of engagement and evaluate the effectiveness of engagement.

This involves the linking of the information you have provided with ‘outcome’ data via administrative datasets. This is achieved by sharing your information with the following bodies:

• The Department for Education (DfE)
• The Education and Skills Funding Agency (ESFA)
• The Higher Education Statistics Agency (HESA)
•  The Joint Information Systems Committee (JISC)
•  The Office for Students (OfS)
• The Universities and Colleges Admissions Service (UCAS)
• Independent research by third parties

The purpose of sharing personal information is to explore the relationship between engagement and student success with the aim to improve future outcomes.

Your data will never be used for marketing purposes or sold to any third party. The HEAT Service processes data solely for the monitoring and evaluation purposes described herein. Data is not linked to or used for any decision-making process that directly affects individuals. Results presented outside of the HEAT Service are in aggregate form without disclosing specific detail on individuals.

9. For how long will your personal data be kept?

Where longitudinal tracking consent has been sought/obtained, and if you have:

• Attended an activity within the last 15 years
• Supplied your first name, last name, postcode and date of birth
• Not withdrawn your permission to be included in research into equality of opportunity for access and success in higher education

From the year ready to enter Higher Education, your data will be used for 15 years for the purpose of monitoring and evaluation. After this time, your information will be marked as ready for deletion to the HEAT member who collected it for this purpose.

Where tracking permission has not been sought/obtained and/or the personal information stored does not meet the track criteria, your data will be marked as ready for deletion to the collecting organisation within 7 years of being stored.

Once the retention period has expired, your information will be truly anonymised and you will no longer be identifiable.

10. Your rights: who to contact about your rights, to make an enquiry or complain if you are unhappy

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us via email to dataprotection@kent.ac.uk but you can also make verbal requests if preferred.

No fee usually required

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. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.