7. What information we collect and why
We collect different types of information for different reasons. For example, to answer your questions and help you find the right course information, to process a Student’s application and support them in their studies, to look after the Student’s health, safety and wellbeing, to keep our campuses safe and secure, to send useful updates, to meet our legal responsibilities, to improve how we support Students, including using technology like AI, and to make sure exams are fair and secure. We may collect various information during a Student’s studies but will always make sure this does not affect their rights and freedoms.
Special Category/Sensitive Personal Information
From time to time we may need to process special category data. The legal basis for using this information is explicit consent of the individual, where we are required to do so by law or where it is in the Student’s or another party’s vital interest.
If you are a Student
Applications
If you make an application to study on one of our Kaplan Pathways Programmes or for us to help you with your University Admission, we may collect the following categories of personal information about you and your Parent/Legal Guardian, UK Guardian or Sponsor (see what information we process about them in section If you are a Parent/Legal Guardian, UK Guardian, Sponsor or Guarantor of a Student):
- Name, title, addresses, telephone numbers, personal email addresses and social media handle
- Date of birth
- Gender
- Nationality and country of residence
- Passport number
- Visa information and immigration status
- Education history
- Level of English language
- Academic and any other qualifications you have
- Employment history
- Information on how you will fund your studies with us
- Information about the subjects you are interested in studying and the universities and countries you wish to study in
- Information about any criminal convictions*
- Information to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations
- Information about your health and any disabilities that you may need support with*.
Please note, depending on the course you apply for, we may need you to provide further information.
Other than the special category information, the legal basis for using this information is to enter into and fulfil the contract we have for your studies or to comply with our legal obligations.
We may also process the above personal information where we are assisting your direct University Admission to study in one of our partner universities.
If you use an Agent to arrange your application, we may collect the categories of personal information described above from your Agent.
Safety and Wellbeing
To look after your safety and wellbeing, we will ask for emergency contacts. This will usually be:
- Your Parents or Legal Guardian, if you are under 18
- A locally appointed UK Guardian, if you are under 18 and are studying in the UK
- A person whose details you have provided to us for this purpose, if you are aged 18 or over.
The personal information we will collect about them is:
- Name
- Telephone number
- Address
- Email address
- Relationship to you.
Our legal basis to process this information is our legal obligations to ensure the health and wellbeing you if are under 18, and your consent if you are 18 or over.
Equality and Diversity
To comply with our legal obligations under discrimination and inclusivity laws, and only if you are happy to provide this information, we will ask you about your background. If you are an International Year One (IYO) Student in the UK, we are required to this for regulatory purposes.
We may also ask all other students if they are happy to provide the information.
The information you will be asked to provide includes:
- Gender
- Gender identity*
- Ethnicity*
- Religion/belief*
- Sexual orientation*
- Whether you grew up in foster care*
- The level of your Parent’s/Legal Guardian’s education.
This information is treated with strict confidence. If you provide this information, it will be processed to comply with our reporting requirements from the Office for Students (OfS), the independent regulators of higher education in England and Higher Education Statistics Agency (HESA). The information will be shared with OFS/HESA to comply with our obligations under the Equality Act 2010.
The legal basis to process this information will be your explicit consent.
Studying at a Kaplan College in the UK
If you are studying on a Kaplan Pathways Programme (including Kaplan Digital Pathways online courses), during your studies, we will collect information:
- About your academic experience
- Attendance
- Progression
- Payments made to us
- To investigate any allegations of academic misconduct.
The legal basis for processing this information is to fulfil our contract with you, but it is also in our legitimate interest to use this personal information in order to monitor the provision of our services.
We may also collect personal information about your health and any disabilities you may have in order to make appropriate arrangements and reasonable adjustments to help you study. We will only process this information with your explicit consent.
Examinations
When you take an exam in-person at one of our centres, we collect some information to help run the test safely and fairly. This might include your:
- Name
- Student number
- The time you arrive
- Your ID
- Notes from the invigilator (exam supervisor) about anything important that happens during the exam.
- Sometimes, we may also use CCTV in the exam room to help keep everyone safe.
The legal basis for processing this information is to fulfil our contract with you, but it is also in our legitimate interests to use this personal information in order to monitor the provision of our services.
If you take an online exam, we may use a third party service provider to conduct the exam, which may involve the exam being proctored, which is where a person or an AI tool monitors the exam to ensure no academic misconduct takes place. Further to the personal information listed above for in-person exams, we will also process the following information:
- A photo of you with your ID to verify your identity
- A video and sound recording of you and your surroundings before and while you take the exam
- Information about your computer, internet browser and IP address. We may also require you to download and use a secure browser for the exam.
If you take an online exam, we will provide you with further details about the processing of your personal information before you sit the exam.
Accommodation
If you live in our accommodation or accommodation we have arranged for you, we will also process the following information about you:
- Name, title, addresses, telephone numbers and personal email addresses
- Bank account details
- Billing address
- Credit card or other payment information in order to process payments to us
- Any violations you commit of accommodation rules
- Financial information regarding the ability to pay the rent for the accommodation
- Information to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations.
This information, together with the personal information provided to us at application stage, will be used by us to perform the contract we have entered into with you, it is in our legitimate interest or to comply with our legal obligations.
If you are acting as a Guarantor for a Student, you can see how we process your personal information further below in section If you are a Parent/Legal Guardian, UK Guardian, Sponsor or Guarantor of a Student.
CCTV
CCTV is used within all our Colleges and Residences in internal and external communal areas. The footage captured is intended to ensure the safety of Students, employees and visitors and to safeguard property.
We may use CCTV in buildings where exams take place to monitor if any academic misconduct takes place.
The legal basis to process the information we collect is our legitimate interest.
Enquiries and Marketing
If you enquire about the services we offer, we may use your:
- Name
- Telephone number
- Where you live
- Nationality
- Age
- Whether you are under 18
- Your query
- What you are interested in studying and where
- How you have engaged with our website or our events and other interactions with us.
This helps us understand what courses we can offer you and to provide you information about similar services and to prioritise queries. It may be necessary to process additional personal information about you, depending on your enquiry.
The legal basis to process this information is your consent, where you have provided your consent in your enquiry, or where it is in our legitimate interest to do so.
If you have applied to study with Kaplan, are a current Student or one of our alumni, we may use your personal information to inform you of special offers and new or existing services that we believe may be of interest to you or to send you surveys or questionnaires so that we can learn more about your needs and interests and improve our services.
The legal basis to process your information is our legitimate interest.
You will always be provided with the option to opt out of such communications, if you no longer wish to receive them.
Internal business purposes
We may also use the personal information listed above 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.
Use of our website
As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies.
Please see our cookie policy on our website for further details.
Artificial Intelligence (AI)
To enhance the Student support we offer or to make our services more efficient, we may deploy AI tools which process some of your information.
For example, we may use AI tools to summarise questions we receive from you, to answer an FAQ, to capture information about you and your query before submitting it to a staff member, or to provide instant feedback on answers to simple quizzes or queries. These features will supplement the existing support we provide and will help us improve the services we offer you.
Where AI is utilised, Kaplan will ensure that your privacy rights and the security of your data are robustly protected as follows:
- We will always inform you where you are engaging with an AI tool such as a chatbot or virtual assistant
- In most cases the Al features we use will not be trained with your data
- In limited circumstances, and where there is no adverse effect on you, the AI models may be trained on your data. This will be done in order to enable specific features of the tool or to teach the model how to triage different types of queries. However, in most of these cases, your personal information will only be used by us and will not be shared with or used by the supplier of the AI tool. If this is not the case, we will inform you and give you the option to opt out of the sharing
- In some cases, aggregated data may be used to train a supplier’s AI model. In this case, all personal information will be anonymised in advance, which means that it will no longer be possible for anyone to identify you.
Where we use AI for other purposes, we will provide you a separate notice about how the AI tool is used and what personal information is processed.
If you are a Parent/Legal Guardian, UK Guardian, Sponsor or Guarantor of a Student
We may process the following personal information where it is necessary to support a Student’s application, study, wellbeing or accommodation.
Student Application
We may need to process the personal information of a Student’s Parents/Legal Guardians to facilitate the Student’s application. This includes:
- Name, title, addresses, telephone numbers and personal email addresses
- Date of birth
- Gender
- Nationality and country of residence
- Passport number
- Payment information
- Relationship with the Student
- Information to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations.
The legal basis for using this information is to enter into and fulfil the contract we with the Student or to comply with our legal obligations.
Emergency contacts
If you are named as an emergency contact for a Student, we will collect personal information about you to ensure we are able to contact you if necessary. This includes:
- Name
- Telephone number
- Address
- Email address
- Relationship to the Student.
Our legal basis to process this information is to satisfy our legal obligations to ensure the health and wellbeing of the Student is protected.
Student’s Accommodation
If you are acting as a Guarantor for the Student’s accommodation, we will collect the following personal information:
- Name, title, addresses, telephone numbers and personal email addresses
- Bank account details
- Billing address
- Credit card or other payment information in order to process payments to us
- Financial information regarding the ability to pay the rent for the accommodation
- Information to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations.
This information, together with the personal information provided to us at application stage, will be used by us to perform the contract we have entered into with the Student, to fulfil our legitimate interest or to comply with our legal obligations.
If you fail to provide personal information
Where we need to collect personal information for a Student’s application, studies or accommodation, and you fail to provide that information when requested, we may not be able to provide the services to the Student.
Where we need to collect personal information to fulfil our legal obligations, for example, to comply with visa and immigration obligations, we may be required to inform the government body responsible that the requested information has not been provided.