Student Data Collection Notice
Alexander College, a company incorporated in Cyprus (company number HE149687) and Alexander Professional Studies Ltd, a company incorporated in Cyprus (company number HE391038), (hereinafter BOTH referred to as “Alexander College”) are committed to protecting your personal information.
Alexander College will collect, process and use your personal data exclusively in compliance with the principles of Regulation (EU) 2016/679 of The European Parliament And of The Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”), the applicable local legislation as amended from time to time and any other legal and/or regulatory obligations.
Why we hold personal data about you
Alexander College collects, holds and processes personal data about you while you are a current student and after you leave and become an alumnus/alumna. It is essential for us to do so in order to manage our operations effectively and provide you with teaching, research and administrative support.
This Data Collection Notice explains in a general way what personal data the college collects about you, how that data will be used and to whom it will be disclosed. It is not possible to describe all of the ways in which the College uses personal data on students, so this Notice should not be seen as exhaustive. By enrolling at the College, you consent to the College handling and use of your personal data in accordance with this Notice and for other legitimate purposes connected to your education at Alexander College; this includes improving teaching and learning, developing services and enhancing the student experience. The College may amend and update this Notice from time to time to reflect changes in how we use personal data.
While this Notice is intended for current and former students of Alexander College’s, applicants for admission to the College’s programmes should note that the College retains information on unsuccessful applications for statistical and audit purposes and in the event of a complaint or appeal. Applicants who require further information on what the College holds about them should contact email@example.com
Where your personal data is collected from
Your personal data is collected from the following sources:
- You – you provide data when you express an interest in studying at Alexander College, upon application to study, when registering as a student at the College, through using various College services while you undertake your studies, when registering for events or volunteering opportunities, when making a donation, when registering an interest in or joining the alumni community.
- Third parties – the College obtains data from various organisations such as other academic institutions.
Securing your personal data
The College is committed to carrying out its activities in accordance with the General Data Protection Regulation (GDPR) and any legislation enacted in the Republic of Cyprus in respect of the protection of personal data.
Your personal data is held securely within the College. Access to the data is controlled. Staff processing the data receive relevant training on data protection and information security.
From time to time, the College may commission agents of a third party to enhance the systems storing your personal data. Where this occurs they will act strictly in accordance with the instructions given by the College, scheduled within a data sharing agreement, so that your personal data remains secure.
What information we hold about you
The information held by Alexander College includes the details provided by you on application and enrolment, to which the College adds data collected during and after your studies at the College. This can include sensitive personal data.
The data collected and processed may include:
- Your name, title, gender, date of birth, passport number, country of domicile and nationality
- Contact details (address, email addresses, phone numbers)
- Information relating to your previous education, such as subjects studied and examination outcomes
- Any employment history, including employers and employment period
- Records of attendance at Alexander College
- Records of assessment outcomes, including details of summative assessments submitted, examinations taken, marks and grades awarded, academic appeals, student complaints and disciplinary procedures
- A digital photograph of you, which is used to produce your student ID and for security and identification purposes
- Records generated through your use of College services, such as Student Accommodation and Wellbeing
- Sensitive personal data or special category data, including your racial or ethnic origin, physical or mental health conditions and particular criminal convictions.
Sharing your personal data
The General Data Protection Regulation (GDPR) exists to protect the privacy of individuals. The College is committed to protecting the privacy of its students, and it should be noted that spouses, parents and friends have no automatic right of access to personal data on students. The general principle is that your personal data will normally only be disclosed outside the College with your consent. This is also true if you are under 18 when you enroll at the College– for Data Protection purposes, the College will treat your data in the same way as if you were over 18.
However, there are also occasions while you are here and after you leave when the College is obliged by law, or under other obligations, to disclose the personal data that we hold about you to external people or agencies. These are sometimes called third-party disclosures. The College has internal procedures to check that the disclosure is appropriate and that the third party is legitimate before any release takes place.
Who we release your information to
- Alexander College Students’ Union
- Ministry of Education
- Visas and Immigration Office
- Local authorities
- The police and other organisations with prosecuting powers
- Graduations, examination results and degree awards
- Professional Bodies
- Research Institutions
- Insurance companies
- Hospitals & Private Clinics
- Funding Agencies / Partner Institutions submitting to Funding Agencies
- Partner Universities for Erasmus purposes
- Career Promotion Organisations
- Other private organisations offering assistance to students
The legal basis for processing your data
Alexander College relies on several different legal bases. Depending on the processing being performed these may include one or more of the following:
- Consent – processing will sometimes be carried out in accordance with your consent
- Performance of the student contract – processing is required to fulfill the College’s contractual obligations to deliver you educational services
- Vital interest – to protect the vital interests of yourself or another, particularly in the case of medical emergencies
- Legal obligation – providing data to statutory and regulatory agencies
- Public interest – to enable teaching and research, which delivers a public and societal benefit
- Legitimate interests – a vibrant and engaged alumni community supports and enhances the teaching and research of the College, having taken account of the privacy rights and freedoms of alumni.
How long will we retain your personal data for?
We will keep your personal information for as long as you are a student and/or otherwise a person enjoying our services.
After you stop being a student and/or a person enjoying our services, we need to keep your personal information for a period of 7 years based on Cyprus government law. For academic purposes and in order for the College to be able to print and certify transcripts validity and issue certificates we may keep your data for up to 50 years. We also may keep your data for more than 50 years if we cannot delete it for legal and / or regulatory and/or technical reasons. If we do so, we will ensure that your privacy is protected and the data are used only for the above-mentioned purposes.
If for any reason we keep sensitive information, we will delete it as soon as the student or employee leaves from the College and there is no other relationship
You may ask at any time for us to delete your personal data by contacting firstname.lastname@example.org
Data transferred to a country outside the European Union
GDPR and the applicable local legislation as amended from time to time prohibits the transfer of personal information outside the European Economic Area (“EEA”) unless specific requirements are met for the protection of that personal information.
Data will only be transferred to countries outside the EU or the EEA (i) if it is required by law; or (ii) if you have granted us your consent and/or instructed us to do so.
Please note that if service providers in a third country are used, all reasonable and practicable measures will be taken to ensure that they will comply with the data protection level in Europe in accordance with the GDPR.
Any transfers to parties located outside the European Union will be in line with the legal and regulatory provisions of the GDPR and applicable local legislation as amended from time to time.
Photography and filming
Prior permission should be obtained for filming by external parties on the College’s premises and that the filming of individuals by external parties should only take place with their permission. Where photography or filming is carried out by or on behalf of the College, the College will take reasonable steps to ensure that students are aware that filming/photography is taking place so that students have the opportunity not to participate (unless filming / photography is part of their assessment).
Employment references/confirmation of qualifications
The College receives numerous requests for references. Where you have provided the College or an individual within the College as a referee, we will assume your consent to respond to the request and will do so unless we have reason to believe that the request is not genuine.
The College treats the details of your award from Alexander College as public information and will normally confirm your qualifications when requested to do so.
Students are required by the College’s Regulations to keep the College informed of their current term time and home addresses, including any changes to your personal email address if you have provided it to the College. If your personal details change, you must update them.
The College regards the Alexander College email address provided to you on enrolment as the primary method of contact with students. You must ensure that you check your College email account regularly.
As part of your record, we request that you provide us with your mobile telephone number, where you have one. In addition to being a normal contact method, this number may be used to send you a text in an emergency. Therefore you will be asked to check this periodically and will also receive a limited number of texts to confirm that this service is working.
Access to your data
Students have the right to access any information that the College holds on them. Article 15 of the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) grants you the right to access your personal data held by Alexander College, including the right to obtain confirmation that we process your personal data, receive certain information about the processing of your personal data, and obtain a copy of the personal data we process. We require that you submit this request electronically via email email@example.com. We will then seek to authenticate your identity.
We expect to respond to your request within 28 days of receipt of a fully completed form and proof of identity.
Privacy legislation gives you have a number of rights to decide how your personal data is collected and processed. Details of these are contained within the general information on our website (see forms).
Changes to this notice
This Notice may be amended or updated. Where this occurs, Alexander College will announce the change on its website. Once this has been done, you will be deemed to have accepted the change.
Should you have any concern about your personal data at Alexander College please contact the Data Protection Officer by email via firstname.lastname@example.org.