DBS Privacy Notice
Subject Access Request
We take the management of your data seriously. If you have any questions regarding how we handle your data or if you
wish to access your Personal Data (as defined under GDPR) stored at Dublin Business School, you should submit a Subject Access Request form.
Dublin Business School (DBS) is committed to maintaining the privacy and security of your personal data. This
Privacy Notice explains how we collect, use, share and protect your personal data.
It is important that you read this Privacy Notice so that you are aware of how and why we are using your personal
data.
This Privacy Notice is provided in a layered format so you can click through to the specific areas set
out below:
1. Who we are
2. Data Protection Officer
3. What is personal data?
4. Data
protection principles
5. How we use your personal data
6. The personal data we collect from you
7.
When and how we share your personal data with others
8. Transfer of your personal data to other
countries
9. The security of your personal data
10. Our storage and retention of your personal data
11. Your rights as a data subject
12. Changes to this privacy notice
DBS is a “data controller”. This means that we are responsible for deciding how we hold and use personal
information about you. Where we act as a data controller, we are required under data protection legislation to
notify anyone who provides personal data to us, either directly or through a third party, of the information
contained in this Privacy Notice.
DBS is the trading name for Accountancy & Business College (Ireland)
Limited, 13/14 Aungier Street, Dublin 2 which is a company within the Kaplan group. When we mention “DBS”, "we",
"us" or "our" in this Privacy Notice, we are referring to this company which is responsible for processing your
data.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this
privacy notice. If you have any questions about this Privacy Notice, including any requests to exercise your
legal rights, please contact the DPO using the details set out below:
Contact
details
Email address: dpo@dbs.ie
Postal address: Palace House, 3 Cathedral Street, London
SE1 9DE
If you are a UK national or resident in the UK, and wish to contact our UK Representative, please
contact:
Kaplan UK Limited,
UK Data Protection Representative,
Palace House,
3 Cathedral St,
London
SE1 9DE,
England.
If you are a citizen or resident of China, and wish to contact our
China Representative:
Shanghai Kaibo Management & Consulting Co., Ltd,
29D, Building B, No.
1188,
Kai Xuan North Road,
Putuo District
Shanghai
People's Republic of China.
To find out
more about how we handle the data of Chinese citizens please see our privacy notice here
You have the right to make a
complaint at any time to the Data Protection Commissioner's Office (DPC), the Irish supervisory authority for data
protection issues at: dataprotection.ie. We would, however, appreciate
the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
Personal data is any information about an individual from which that individual can be identified. Your
name, address, phone number and bank account number are examples of personal data. It does not include
data where the identity has been removed (anonymous data).
We will comply with data protection law. This says that the personal information we hold about you must be:
•
Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly
explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the
purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
•
Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data
in the following circumstances:
• Where we need to perform a contract we have entered into with you.
•
Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests (or
those of a third party) and your interests and fundamental rights do not override those interests.
We
may also use your personal data in the following situations, which are likely to be less common:
• Where we
need to protect your vital interests (or someone else's interests).
• Where it is needed in the public
interest (for example, equal opportunities monitoring) or for official purposes.
Generally we do not
rely on consent as a legal basis for processing your personal data other than in relation to sending direct
marketing communications to you via email. You have the right to withdraw consent to marketing at any time by
contacting us.
Enquiries and leads
When you request information or make enquiries about any of our services or programmes, we may use the personal
data you provide in order to fulfil your request or respond to your enquiry. So that we can provide you
with the information, courses, programmes, services, materials or products you have requested, we collect and
store certain information about you, including your name, telephone number, e-mail address, postal address and
educational background when you ask for information about our courses or study materials. It is in our
legitimate interests to use your personal data in this way so that you receive the information you have
requested.
Applications and Enrolments
If you are applying or enrolling as a student, we may collect the following personal data about you:
•
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
•
Date of birth.
• Gender.
• Nationality and country of residence.
• Education history.
•
Employment history (if applicable).
• Professional certification number.
• Central Applications Office
(CAO) number (if applicable).
• Personal Public Service (PPS) number (if applicable).
• Credit card or
other payment information in order to process your payments.
• Information on how you will fund your studies with us.
• Information to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations.
This information will be used by us to
perform the contract we have entered into with you.
We may also collect information about your
academic experience and progression. This is in order to fulfil our contract with you but it is also in
our legitimate interests to use this personal data in order to monitor the provision of our service to you.
We may also collect personal data about your health in order to make appropriate arrangements and reasonable
adjustments for you regarding your welfare or attendance. We use this information in order to perform our
contract with you and in order to comply with our legal obligations.
We also may collect from you emergency
contact information, such as the telephone number or email address for a friend or family member. By submitting
such data to us, you represent to us that you have obtained consent from your emergency contacts to provide us
their information for this purpose.
Marketing
Where you have explicitly consented to do so, we may use your personal data to
i. Inform you of new
information that we believe may be of interest to you and the programme area(s) you have shown the interest in;
and/or
ii. Invite you to Open Events or Information Sessions relevant to your programme(s) of
interest.
If you would prefer that we do not send such communications to you, please follow the
opt-out links on any marketing message or contact us using the contact details in this Privacy Notice.
Internal business purposes
We also may use your personal data for our internal business purposes. This is in our legitimate interests
in order to operate as a business and monitor and improve the services we provide. Where possible we will
anonymise this information. Please contact us using the contact details in this Privacy Notice if you
would like more information.
Automated technologies or interactions.
As you interact with our website, we may automatically collect technical data about your equipment, browsing
actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see
our cookie policy on our website for further details.
Online courses
If the course you study with us is provided online, you may be required to sit
your examinations online.
To ensure the integrity of online exams, it is in our legitimate interest to use a third party supplier to
provide online invigilation, known as proctoring.
Further to the personal information listed above, for proctored exams we will also process the following
information, as it is in our legitimate interest to ensure the integrity of the exams:
• A photograph of identity document, such as a passport
• A photograph of you
• Facial information to detect potential academic misconduct
• Exam submissions
• Screen shots
• Audio and video recordings of you taking the exam
• Audio and video recordings of the room you are taking the exam in
• Information about your computer, including operating system and IP address. We may also require you to download a secure browser in order to take the exam.
Financial Crime and Sanctions Screening
We carry out necessary and targeted financial crime and sanctions screening on students, parents/legal guardians, sponsors, guarantors or payors located in or nationals of high-risk jurisdictions. This activity includes screening these individuals against publicly available information published by a number of governments and regulatory bodies globally, to ensure compliance with laws and regulation in both Ireland and other jurisdictions that Dublin Business School and Kaplan International are registered and operate in.
Our legal basis to process this information is to ensure that Dublin Business School complies with legal obligations.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We may share your personal data with third parties where required by law, where it is necessary to perform a
contract or where we have a legitimate interest in doing so. We will need to use your data to perform our
obligations and exercise our rights under agreements made with you and to inform you of feedback and exam
results.
Such third parties may include the following:
• Our service providers: We may share
your personal data with other companies that perform certain services on our behalf. These services may
include legal, financial and accounting advice, processing payments, providing customer service and marketing
assistance, performing business and sales analysis and supporting our website and IT functionality and online
exam proctoring. These service providers may be supplied with or have access to your personal data solely for
the purpose of providing these services to us or on our behalf. DBS is the data controller and will remain
accountable for your personal data.
• Your employer or sponsor: We may share your personal data
with your employer or sponsor with whom we have a contract relating to your programme of study. This may include
attendance and exam results
• Agents. If you use an agent to arrange your application or study with us,
we may share your personal data with them. If you apply to us directly without an agent and are residing in the
following countries we will share your personal data with our preferred student recruitment agent in your
country to assist and guide you through the application process as we do not accept direct applications from
these countries: Nigeria, Malaysia, Cameroon, Pakistan, Ghana, Bangladesh, India, Sri Lanka, Middle East,
Thailand, Singapore, Philippines, Indonesia, Vietnam and Cambodia. You can however use an agent of your choice
at any time.
The personal data we share with agents is, for administration purposes (such as
keeping track of your course records), accepting and recording your payments, providing you with certificates of
completion and complying with any regulatory reporting requirements or other reporting requirements agreed with
your sponsor.
• Government Authorities and Regulators. We may need to share the personal information of a student, their parents/ legal guardians, guarantor or sponsor, where necessary to ensure that we comply with all applicable laws and regulations. This includes, but may not be limited to responding to lawful requests from regulatory bodies, government authorities or law enforcement agencies, fulfilling statutory or regulatory reporting requirements, carrying out checks to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations, disclosing information regarding any criminal convictions*, where required.
• Awarding Bodies: We provide certain personal information collected by us, including PPS
numbers, to Quality and Qualifications Ireland (QQI) and other Awarding Bodies to allow them to process
students’ results through their system
• Department of Justice: We are obliged to provide certain
personal information, including attendance records, to the Department of Justice regarding non-EEA visa
requiring students.
• Public Health Officials: We are obliged to provide contact information to the Department of Health and/or the
Health Service Executive for the purpose of contact tracing in the event that a case of COVID-19 or another
infectious disease is reported amongst the DBS community.
• Parents and guardians: If you are
under 18, we may share your personal data with your parents or guardians in order to perform our contract, comply
with our legal obligations and if it is in your vital interests.
• Other entities in the Kaplan group:
We may share your personal data with other entities in our group as part of our regular reporting activities on
company performance, in the context of a business reorganisation or group restructuring exercise or for system
maintenance support and hosting of data.
• Professional bodies and regulators: We may need to share your
personal data if required by a professional body or institute related to your programme or if required by a
regulatory body or to otherwise comply with law.
• StudentSurvey.ie: During your studies, you may be
invited to participate in StudentSurvey.ie (Irish Survey of Student Engagement). Some of your information will be
sent to the survey company and will be matched to your survey responses in order to allow for anonymous analysis of
results, for example, by gender or full-time/ part-time. However, all identifier information, i.e. your student
number and date of birth, will be deleted before the results are returned by the survey company. This means that
your responses will be anonymous and no individual student will be identifiable in any reports or results generated
as a result of this survey. The StudentSurvey.ie privacy statement may be found here. The Higher Education
Authority (“HEA”) is the data controller for StudentSurvey.ie. Further information on why the Higher Education
Authority collects data may be found here.
• Graduate Outcomes Survey: After you graduate you may be invited to
participate in the annual Graduate Outcomes survey conducted by the Higher Education Authority ("HEA").
The survey will be conducted by DBS and your data, in aggregate with the data of other students, will be forwarded
to HEA for input to the production of a sector-wide report on graduate outcomes. All personal
identifying information will be deleted before any data is sent to the HEA. When you graduate your name may be
included in the booklet showing all graduate names distributed to people attending a graduation ceremony.
•
Others: We may share your personal information with other third parties such as in the context of the possible sale
of our business. We may also need to share your personal data in order to permit us to pursue available remedies or
limit damages we may sustain.
As we are an international business with employees, entities and service providers all over the world, we may
need to transfer the personal data you provide to us to other countries which may be outside the European
Economic Area (EEA).
The data protection laws in such countries may not be as comprehensive and
provide the same level of protection for your personal data as those within the EEA. In these circumstances, we
will take appropriate steps to ensure that your personal data is handled as described in this Privacy
Notice. These steps will include appropriate contractual mechanisms. Please contact us using the
contact details in this Privacy Notice if you would like more information.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost,
used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal
information to those employees, service providers, business partners, agents and other third parties who have a
legitimate need to know. They will only process your personal information on our instructions or as otherwise
agreed and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any
suspected data security breach and will notify you and any applicable regulator of a suspected breach where we
are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the
appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal
data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes through other means, and the
applicable legal requirements. Please contact us using the contact details in this Privacy Notice if you would
like more information.
It is important that the personal information we hold about you is accurate
and current. Please keep us informed if your personal information changes during your working relationship with
us. In some circumstances we may anonymise your personal data so that it can no longer be associated with you,
in which case we may use such information without further notice to you.
Under certain circumstances, by law you have the right to:
• 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
that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you
corrected.
• 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 exercised your right to object to processing (see
below).
• 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. You also have the right to object where we are processing your personal information
for direct marketing purposes.
• Request the restriction of processing of your personal data. This
enables you to ask us to suspend the processing of personal data about you, for example if you want us to
establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to
another party.
If you want to review, verify, correct or request erasure of your personal data, object
to the processing of your personal data, or request that we transfer a copy of your personal information to
another party, please contact us using the contact details in this Privacy Notice.
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 for access is clearly unfounded or excessive.
Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security
measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Your right to withdraw consent
In circumstances where you may have provided your consent to the
collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw
your consent for that specific processing at any time. To withdraw your consent, please contact us using the
contact details in this Privacy Notice. Once we have received notification that you have withdrawn your consent,
we will no longer process your information for the purpose or purposes you originally agreed to, unless we have
another legitimate basis for doing so in law.
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice
when we make any substantial updates. We may also notify you in other ways from time to time about the
processing of your personal information.