Terms and Conditions
Important
In these Terms and conditions, 'we' or 'us' means Study Group Limited ('Study Group'). Study Group is the owner and provider of University of Strathclyde International Study Centre (the 'Centre'). It is incorporated in England and Wales (Company number 02325576) with its registered office at 21 Station Street, Brighton, BN1 4DE. References to the ‘University’ are to University of Strathclyde.
Please ensure you read these Terms and Conditions carefully and understand them before signing your final acceptance of a place at the Centre. These Terms and Conditions, along with any offer letter received from us and the policies referred to below form part of a wider agreement between you and us which will become legally binding once you confirm your acceptance of our offer.
Please note that these Terms and Conditions assume that you are an international (non-UK) student. If you hold dual nationality, you will NOT be permitted to enrol at the College as an international student and progress to the University with the status of a UK student in order to take advantage of lower university tuition fees.
Your attention is also drawn to our Student Protection Plan at the following link that contains important information about how we will mitigate risks affecting your ability to study:
View the Student Protection Plan: https://assets-us-01.kc-usercontent.com/95d47d95-36b6-00af-a24c-b886ecdfc4a2/07804e0a-cf98-4114-baf7-658b545be5f0/Student_ProtectionPlan_V2.pdf
This website's Terms and Conditions were updated on 29 November 2023.
Application and confirmation payment
If your application is accepted, a written offer of a place will be made. To accept this offer a confirmation payment is required comprising a non-refundable administration fee of £260 and £1,000 security deposit. Prior to enrolment (and before you apply for your Confirmation of Acceptance of Studies (‘CAS’)) you will also need to pay a minimum of £6,000 in advance tuition fees. Please note that certain territories are deemed high risk by UKVI for the issuance of a visa. If your territory is considered high risk, you may be required to pay a higher amount in respect of advance fees. Details will be set out in the individual payment plan attached to your offer letter. Non-payment by the fee deadline may put your place at risk and we reserve the right to not enrol you and withdraw your visa sponsorship if you have failed to make the appropriate payments in accordance with your payment plan. If you do not require a student visa you must pay this sum no later than 3 months before the start date of your programme. You will be required to pay the balance of the first semester's fees along with the accommodation fees (if applicable) no later than 28 days prior to your programme start date, unless otherwise stated in the individualised payment plan in your offer letter.
In the event of an official visa rejection, only one further CAS will be issued in support of a second and final visa application. Full fees for the year must be paid in advance for a second CAS to be issued, but will be refunded in the event of a second visa refusal (unless the visa is refused on account of fraud). We reserve the right not to issue a second CAS if we deem the risk of rejection too great. The issuance of a CAS is subject to meeting certain criteria including, but not limited to, your financial status and, in some cases, a satisfactory interview.
The security deposit is primarily held against any damages incurred to Centre property and related expenses. If, at the end of a programme, there are any monies left these may also be offset against debts incurred by you in relation to expenses such as programme-related travel or extra-curricular activities, otherwise an invoice will be issued for any damages/outstanding fees in excess of the deposit. Any monies left will be refunded within 90 days of completion of the final term less any deductions made for any amount outstanding at that time.
Blended learning and technology requirements
Please note that you will learn through a mixture of as many live teacher-led classes as possible, as well as interactive activities and resources delivered in a virtual learning environment (‘blended learning’).
To access course materials on a Learning Management System/Virtual Learning Environment or platform and undertake assessments, it is important that you come prepared with the appropriate technology. While it is possible to access and interact with most course content using tablets and smartphones such as iPads, iPhones and Android devices, these devices will NOT work for assessments. Therefore you must have a PC or Mac based computer available for use. Please note that Linux, Chromebooks and Windows 10S/11S Mode are not supported.
Minimum recommended specifications:
PC:
- A Microsoft windows-based PC with at least 4GB RAM and 200 MB available free disk space (laptop or desktop, preferably running Windows 10 or 11)
- Web browser: Google Chrome or Microsoft Edge (Chromium version)
Mac:
- Mac OS/X 10.13 or a more recent version-based laptop or desktop with at least 4GB RAM and 200 MB available free disk space
- Web browser: Google Chrome or Microsoft Edge (Chromium version)
Online teaching sessions will be recorded and you will be reminded of this at the beginning of your course and before each session until the last date of admission to a programme. You may at any time tell us that you do not wish to be recorded by notifying the relevant member of staff. Please note that if you do not consent to the recording of an assessment, this may adversely affect your right to appeal and/or the outcome of any later appeal.
Deferral, Cancellation and Refund Policy
You may defer your programme prior to commencing your study by using the following link:
https://www.studygroup.com/request-deferral
You have a right to cancel your place and receive a full refund of any amounts paid by informing us in writing within 14 days of the date you accept the offer. Please note, if you defer your initial offer of a place after the 14-day period has expired you will NOT be able to cancel your deferred place at a later date to take advantage of a full refund. You may wish to cancel using the following link:
https://www.studygroup.com/request-withdrawal
Our cancellation and refund policies can be accessed at the links below. Your attention is drawn in particular to the circumstances in which £6,000 (or such higher amount as you may have been required to pay) of your advance tuition fees will NOT be refunded:
- If you cancel after a CAS has been issued;
- If you cancel within 8 weeks of the programme start date; and
- If your visa is rejected due to student error or fraud.
Refunds will only be made to the same card/bank account of the individual from whom Study Group received the original payment. Refunds will be made within 90 days of the end of the relevant term.
If you have been issued a CAS and this has been used as part of a visa application, any applicable refund will only be made if you if you can provide sufficient evidence that may include, but not be limited to:
- Proof that you have not used your student visa to travel to the UK, such as a complete copy of your passport’s pages; or
- Proof that you have left the UK to return to your home country, such as copies of relevant boarding passes and passport copies showing the appropriate entry/exit stamps.
Refunds will be made after calculating any damages, disbursements due or any other incidental fees or charges. Should you decide not to pursue your place on a programme after a CAS has been issued, no monies will be refunded unless there are exceptional circumstances as set out in the refund policy below.
If you have not been issued a CAS or received a student visa, please refer to the full Pre-Visa Refund Policy below:
UK Pre-visa Refund Policy
For students who have not yet been issued a CAS or who have been issued a CAS but not yet received a student visa.
Payments Key: X Not Refunded | Pre-arrival Confirmation fees | |||
Non-refundable administration fee | Security deposit | Pre-arrival Tuition fee deposit | Due before start of programme | |
£260 | £1,000 | £6,000 or £8,000 as applies to your payment plan | Balance of 1st and 2nd terms fees (or 1st semester) | |
In all cases within 14 (fourteen) days of accepting an offer | ||||
Student cancellation within 14 day cooling off period, no reason required | / | / | / | / |
For students who have not been issued a CAS or do not require CAS Cancellation due to student failing to meet entry requirements or pass compliance checks (including pre-CAS interview) | ||||
It has not been possible to offer an acceptable alternative study plan | X | / | / | / |
Rejection by Study Group | ||||
Fraud or submission of falsified paperwork | X | X | X | X |
Cancellation where student meets entry requirements, but chooses not to study | ||||
More than 8 weeks prior to start date | X | / | / | / |
Within 8 weeks of programme start date (for exceptional circumstances see below) | X | X | X | / |
For students who have been issued a CAS or confirmation of acceptance / enrolment | ||||
Student cancellation with no exceptional circumstances | X | X | X | / |
Exceptional circumstances e.g. illness, bereavement (documentation will need to be sent to Admissions for final decision) | X | / | / | / |
Fraud or submission of falsified paperwork at any stage of the application process | X | X | X | X |
Visa Rejection due to… | ||||
Student Error | X | X | X | / |
Standard visa refusal (student did not meet visa entry requirements) | X | / | / | / |
Fraud or submission of falsified paperwork | X | X | X | X |
Agent error | X | / | / | / |
Visa / immigration service error (administrative appeal documentation must be sent to Admissions for final decision) | X | / | / | / |
Study Group error | / | / | / | / |
Notes:
- If you defer your initial offer of a place to a later programme start date after the 14-day cooling off period has expired (i.e. more than 14 days after accepting the offer) you will NOT be able to cancel your deferred place at a later date to take advantage of a full refund
- The unused portion of any Study Care Insurance Plus payments will be fully refunded upon student cancellation
- Students in receipt of a scholarship shall be refunded any eligible amounts less the relevant pro-rated discount applied to such fees
Where a CAS or visa has been issued, please refer to the UK EU In-flight and Post Commencement Refund Policy below:
UK – EU In-flight and Post-Commencement Refund Policy
In-flight Refund Policy (applicable to students intending to study in the UK only)
- Students will be considered to be in-flight either:
- when they have been issued a student visa and are about to travel to the UK; or
- have travelled to the UK, but not yet commenced their Programme or arrived in Centre and attended any induction, registration, or teaching activities.
- Students who have travelled to their country of study by means of a student visa sponsored by Study Group but do not arrive in Centre or commence their Programme will be considered to be Absent Without Leave (AWOL).
- Any student who has been issued a visa or a CAS that has been used as part of a visa application will not be provided any applicable refund until sufficient evidence has been provided. This may include, but is not limited to: -
- Proof of leaving the UK and returning in their home country (such as copies of boarding pass or passport pages showing the appropriate entry/exit stamps); or
- Proof of not having left their home country to travel to their chosen country of study, such as copies of all pages in their passport
Payments Key: X Not Refunded | Pre-arrival Confirmation fees | |||
Non-refundable administration fee | Security deposit | Pre-arrival Tuition fee deposit | Due before start of programme | |
£260 | £1,000 | £6,000 or £8,000 as applies to your payment plan | Balance of 1st and 2nd terms fees (or 1st semester) | |
For students who have been issued a CAS or student visa | ||||
Student cancellation with no exceptional circumstances | X | X | X | / |
Exceptional circumstances e.g. illness, bereavement (documentation will need to be sent to Admissions for final decision) | X | X | / | / |
Discovery by Study Group of fraud or submission of falsified documents by student or agent | X | X | X | X |
IMPORTANT
Students who arrive in the UK on a student visa and claim asylum or apply to switch their immigration / visa status will NOT be issued a refund of any amounts paid unless there are exceptional circumstances, assessed on case by case basis by Study Group.
Post-Commencement Refund Policy (Applicable to all UK/EU students)
- Students are considered to have commenced their Programme once they have arrived in Centre and attended any induction, registration or teaching activities.
Withdrawal Reason Key: X Not Refunded | Security Deposit (£1,000/€1,000) | Fees for Current Term or Semester (includes Tuition Fee Deposit if 1st term) | Fees for Next Term or Semester | Fees for Future Terms or Semesters |
Student withdrawal from studies | ||||
Student withdrawal with no exceptional circumstances | / (less any unpaid incidental charges) | X | X | / |
Student withdrawal due to exceptional circumstances e.g. illness, bereavement (documentation will need to be provided) | / (less any unpaid incidental charges) | Payable up to the last date of study, balance of fees refunded | / | / |
Study Group termination of studies due to: | ||||
Academic performance | / (less any unpaid incidental charges) | Payable up to the last date of study, balance of fees refunded | / | / |
Other reason (e.g. withdrawal of programme of study) | / (less any unpaid incidental charges) | Payable up to the last date of study, balance of fees refunded | / | / |
Serious misconduct or attendance issues or non-payment of tuition fees | / (less any unpaid incidental charges) | X | X | / |
Student is AWOL or there is evidence of Fraud (e.g submission of falsified or exam results, deliberate misuse of CAS or related visa for non-study purposes) | X | X | X | X |
- In the event that Study Group is unable to complete the teaching of a paid for programme of study, Study Group will pay any reasonable and demonstrable incremental costs incurred by the student completing the same or a comparable programme of study within Study Group or its affiliates.
- In the event that Study Group is unable to complete the teaching of a paid for programme of study and no alternative arrangements are available to complete the same or a comparable programme of study within Study Group or its affiliates, Study Group will refund all tuition/accommodation/living fees/expenses paid for incomplete programmes of study.
IMPORTANT
Students who arrive in the UK on a student visa and claim asylum or apply to switch their immigration / visa status will NOT be issued a refund of any amounts paid unless there are exceptional circumstances, assessed on case by case basis by Study Group.
Notes:
(1) £260/€260 Administration Fee is never refunded
(2) For accommodation, refer to your tenancy agreement or accommodation refund policy
(3) StudyCare Insurance Plus will be charged by week up to the date of withdrawal, the unused balance will be refunded in all cases
(4) Students in receipt of a scholarship shall be refunded any eligible amounts less the relevant discount applied to such fees
Please read the refund policies carefully and note in particular the circumstances in which advance tuition fees will NOT be refunded.
Accommodation
Should you decide to book accommodation through Study Group, additional charges may also be made for such items as accommodation security deposits, bedding packs and accommodation-specific insurance. You will be advised of these charges under a separate accommodation agreement at the time of booking. Residential accommodation is subject to availability and early confirmation is advised. For more information on accommodation during your period of study, please contact: Strathclyde.CSS@studygroup.com
For accommodation cancellations and refunds, please refer to your individual tenancy agreement.
Centre tuition fees
Admission to programmes and your continued enrolment with the Centre is dependent on all fees having been paid by the required date.
After starting your programme, fees for the second term (and any subsequent terms) must be paid in full no later than two months before the start of the second term.
Reasonable efforts are always made to keep fees to the minimum that is consistent with the provision of a modern and efficient teaching programme. However, fee increases may become necessary from time to time in order to maintain standards or following a change in law or regulation. You will be notified in advance of any increase, but we will not increase fees during the course of an academic year.
If payments become overdue, we reserve the right to suspend or cancel tuition and to charge interest on the balance at the rate of 2% above the base rate of NatWest bank per month or part thereof. We also reserve the right to terminate your studies and withdraw sponsorship of your student visa. Please refer to the Post-Commencement Refund Policy for further details.
Provision of tuition
Pre-commencement
The Centre will use all reasonable endeavours to deliver all programmes described in our prospectus and other marketing materials. However circumstances may change due to factors beyond our reasonable control and it may be necessary to vary the content of a programme. We will use reasonable endeavours to ensure that any changes are kept to a minimum, but if we are required to make material changes to a programme before your arrival at the Centre, we shall inform you as soon as possible. If you reasonably believe that the changes will affect you adversely, you may transfer to an alternative programme at the Centre for which you are qualified or withdraw your application without any liability for fees (including the enrolment fee).
If there are not sufficient applicants either to make a programme viable or to deliver a quality student experience, we may cancel or withdraw a programme. If you receive an offer for a programme and we discontinue or withdraw that programme prior to your registration at the Centre, we will notify you as soon as possible and you will be given the opportunity to either change your programme of study or withdraw from the Centre. In such circumstances you will be eligible for a full refund of any fees paid to us. Please also be aware that certain programmes are extremely popular and have limited spaces available, therefore it is important that you confirm your place as soon as possible after receiving an offer. Failure to do so may result in your being unable to register on your chosen programme and you may be offered an alternative programme of study.
Programme commencement date
You must ensure that you arrive on campus and are ready to start by the programme start date. You will not be admitted to your programme if you arrive after the programme start date, unless there are exceptional circumstances that have been agreed with Study Group in advance. If you are unable to arrive by the programme start date or are unlikely to obtain a visa in time to travel to the Centre by the programme start date, you must contact our Admissions Team who will advise on the options available to you.
University undergraduate/postgraduate Programme Preparation Fee
Should you be successful in progressing to a University programme, an amount equivalent to 15% of that programme’s first year’s tuition fees will be payable by you to us as a programme preparation fee. At the same time, you will be entitled to receive a 15% discount from the University in respect of its first year’s fees. The relevant University programme preparation fees will be payable through your first year’s University tuition fees.
Academic criteria
Acceptance on a programme is subject to students meeting the defined entry requirements and the Centre’s criteria for English Language proficiency.
Students are accepted into the Centre on the strict understanding that progression through the programme is conditional upon satisfactory and required attendance and successful attainment of prescribed performance targets as outlined to you at the beginning of your programme. Students are formally assessed at least twice a year. The assessment will take into consideration:
- Programme work assignments
- Internal examination results
- Attendance
- Commitment to study
Students who do not meet the attainment criteria will not be allowed to proceed with their original programme, but may be offered an alternative programme or invited to withdraw from the Centre.
Termination of studies
Your attention is drawn to the following non—exhaustive list of circumstances in which we may terminate your studies:
- Insufficient attendance in line with our Attendance Policy (in accordance with UKVI requirements)
- Failure to provide evidence of your eligibility to study in the UK (in line with UKVI requirements)
- Serious breach of required standards of conduct as further set out in our Code of Conduct and Disciplinary Policy
- Multiple chargebacks in respect of any attempted payment of fees or any attempt to pay fees by fraudulent means by fraudulent means (including, but not limited to, the use of a stolen credit or debit card)
Study plan changes
All students’ English and numeracy skills will be tested on arrival. If your results differ materially from those in your home country, for example as a result of not having been tested for a long time the Centre may discuss an alternative study plan more appropriate to your English and numeracy level. We would rather you succeed on an appropriate study programme than struggle on a programme beyond your levels of English and numeracy.
Personal insurance
Accident and Medical insurance
We strongly recommend that all students have appropriate accident and medical insurance for the duration of their study in the UK. Depending on the policy, insurance may cover otherwise non-refundable programme fees in the event of cancellation. You may either take out our StudyCare Insurance Plus policy or cover with an alternative provider. Further information about StudyCare Insurance Plus Policy can be found at the following link: https://www.studygroup.com/studycare. Cover under the StudyCare Insurance Plus policy will not commence until the insurance fees have been paid in full. Should you cancel your programme, you will also need to notify us that you wish to cancel your insurance policy.
Personal belongings and contents insurance
While the Centre takes all reasonable precautions to ensure the safety and security of students on campus we cannot accept responsibility for loss or damage to students’ personal property. All students are, therefore, strongly advised to take out a contents insurance policy.
Withdrawal from the Programme
Once you have commenced your programme, a minimum of one semester’s notice in writing is required to withdraw from your programme, whether or not you continue to attend lessons. Please refer to our UK EU In-Flight and Post-Arrival Refund Policy above.
Notice of withdrawal must be given in writing or by email to the Centre Head and is effective from the date it is received. You may use the following link:
https://www.studygroup.com/request-withdrawal
Accounts procedures
Payments
Payment can be made to the Centre using a number of payment options via our payment platform. Access to this platform can be found at: https://isc.strath.ac.uk/how-to-apply/fees/how-to-pay using your unique student access code.
Please note that we are NOT able to accept cash payments for fees. Cash payments may only be made to cover sundry charges that may arise during your programme.
If you choose to pay in your local currency a foreign exchange rate will apply. The applicable exchange rate can be viewed online as at the time and date of the payment. Bank charges and commission for both the sending and receiving banks should be paid by the sender of funds or they will be applied to the student’s account.
Accounts communications will be sent both to you and the person responsible for paying the fees unless written instructions are received to the contrary.
Privacy Notice for Students
Study Group Notice
Version | 2.3 |
Short description | Notice to students reflecting Study Group’s commitment to ensure the privacy and security of personal information. |
Authority | The Global Executive Team |
Policy Owner | The Data Protection Officer |
Relevant to | All students, prospective students or enquirers of services provided by Study Group and subsidiaries. |
Date introduced | 30 April 2018 |
Last reviewed | March 2023 |
Next scheduled review date | July 2024 |
Related Study Group documents | This policy is an addition to the Study Group policy framework. Any other existing Study Group policies should be read in conjunction with this policy. |
NOTICE STATEMENT
Study Group is committed to protecting the privacy and security of your personal information. This privacy notice (“this Notice”) describes how we collect and use personal information about you during and after your relationship with us, in accordance with the Data Protection Act 2018, which implements the General Data Protection Regulation (UK GDPR) and other privacy legislation within the applicable jurisdiction. It applies to all students.
Study Group is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Notice.
This Notice applies to students and any reference to “students” in this Notice includes current, former or prospective students. This Notice does not form part of any offer made by Study Group to you. We may update this Notice at any time and shall inform you if we make any amendment that will significantly affect your rights.
It is important that you read this Notice, together with any other policies we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
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.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
- Date of birth;
- Gender;
- Next of kin and emergency contact information;
- Parent/Guardian contact Information;
- Visa, Nationality, Police Registration and Identification Documents;
- Bank account details;
- Course Information (duration, location and Study Plans);
- Educational information (including copies of right to study documentation, certificates and other information included as part of the application process);
- Grades and Progression Information;
- Behavioural and Attendance information;
- CCTV footage and other information obtained through electronic means such as swipecard records – see CCTV Policy;
- Information about your use of our information and communications systems;
- Photographs;
- Feepayer Information;
- Cookies and Data Analytics Information from our Web Pages;
- Recordings of online classes/presentations.
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your race, ethnicity and religious beliefs
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about students through the application process, either directly from students or on occasions from Agents or Sponsors. We may sometimes collect additional information from third parties including former educational institutions and Study Group’s University Partners that you have applied to.
We will collect additional personal information in the course of your period of study with us.
ON WHAT BASIS WILL WE USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to enter into the agreement with you to provide the study programme according to Study Group Terms and Conditions, and to perform such an agreement once we have entered into it with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for Study Group’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Such instances may include the prevention of fraud, error, harassment or child abuse.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
SITUATIONS IN WHICH WE WILL USE STUDENT PERSONAL INFORMATION
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. In limited situations such as for the purposes of photographs and videos, we may ask you for consent to process your data. Your refusal will not put you into a disadvantageous situation. The situations in which we may process your personal information are listed below.
- Making a decision about your application or appointment to an educational establishment;
- Determining the terms on which you study with us;
- Checking you are legally entitled to study within an educational establishment;
- Providing you with the necessary study material required;
- Administering the agreement we have entered into with you;
- Business management and planning, including accounting and auditing;
- Conducting performance reviews, managing performance and determining performance requirements;
- Making decisions about course content and curriculum;
- Assessing qualifications for a particular study centre;
- Making arrangements for the termination of Study Group’s relationship with you;
- Making arrangements for travel between your home and the educational establishment;
- Education, training and development requirements;
- Dealing with legal disputes involving you, or other students including accidents;
- Managing sickness absence;
- Complying with health and safety obligations;
- To prevent fraud;
- To monitor your use of our information and communication systems to ensure compliance with our IT policies;
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution;
- To conduct data analytics studies to review and better understand student progression rates;
- Equal opportunities monitoring;
- Our social media profiles
- Communications and marketing purposes
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain information when requested, we may not be able to perform the agreement we have entered into with you (such as providing a place at an educational establishment, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our students).
CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations and in line with our Data Protection policy.
- Where it is needed in the public interest, such as for equal opportunities monitoring and in line with our data protection policy.
- Where it is needed to assess your studying capacity on health grounds and to act with a duty of care, subject to appropriate confidentiality safeguards..
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about students or former students in the course of legitimate business activities with the appropriate safeguards.
OUR OBLIGATIONS AS AN EDUCATION PROVIDER
We will use your particularly sensitive personal information in the following ways:
- We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with policies, regulations and laws.
- We will use information about your physical or mental health, or disability status, to ensure your health and safety in the educational establishment and to assess your fitness to study, to provide appropriate adjustments and to monitor and manage sickness absence.
- We may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. We will not use this information for any other purpose without your consent.
DO WE NEED YOUR CONSENT?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your agreement with us that you agree to any request for consent from us.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may only use information relating to criminal convictions where the law allows us to do so. This data is generally processed for the purposes of safeguarding of children and of individuals at risk based on substantial public interest.
Data is only accessible to Study Group staff on a need to know basis and therefore cannot be accessed by all the staff who generally have access to student data. Absent specific circumstances in individual cases, the data shall be deleted when the student leaves the programme.
Less commonly, we may use information relating to criminal convictions in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about students or former students in the course of legitimate business activities with the appropriate safeguards.
We will only collect information about criminal convictions if it is appropriate given the nature of your place of study and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the Application process or we may be notified of such information directly by you in the course of you studying with us.
We will use information about criminal convictions and offences to provide the educational establishment you have applied to with the relevant information requested.
AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We can use automated decision-making in the following circumstances:
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights, provided we have notified you of the decision and given you 21 days to request a reconsideration.
If we make an automated decision on the basis of any special categories of data (sensitive personal data), this will have to be based on explicit consent.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
DATA SHARING
We may have to share your data with third parties, including third-party service providers and other entities in the group. Similarly, your university results in pseudonymised or anonymised form, including basic demographics, may be processed by Study Group in order to evaluate the impact of its courses. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the country in which you reside. If we do share your data, you can expect a similar degree of protection in respect of your personal information based on a lawful arrangement we have in place to transfer your data.
WHY MIGHT YOU SHARE MY PERSONAL INFORMATION WITH THIRD PARTIES?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
WHICH THIRD-PARTY SERVICE PROVIDERS PROCESS MY PERSONAL INFORMATION?
”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes:
United Kingdom Visa and Immigration (UKVI) – Legal requirement to share information on attendance, immigration status and police registration
National Health Service – Legal requirements to share information
Child Protection Services – Legal requirements to share information
College Guardians (UK) and Godsil Education Dublin – Under 18s Guardian services providers
Homestay Families – Accommodation providers
Landlords – Accommodation providers
The Universities and Colleges Admissions (UCAS) – for use in applications to UCAS on behalf of the student.
Third-party service providers perform functions in connection with the operation of Study Group’s business including IT service providers, system administrators, workflow automation providers, technical support providers and those who host/manage Study Group data.
HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS AND OTHER ENTITIES IN OUR GROUP?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
WHEN MIGHT YOU SHARE MY PERSONAL INFORMATION WITH OTHER ENTITIES IN THE GROUP?
We will share your personal information 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, for system maintenance support and hosting of data.
WHAT ABOUT OTHER THIRD PARTIES?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
In other circumstances we may share your personal information with Agents, Parents/Guardians, Sponsors and educational establishments you have applied for.
SHARING OF DATA WITH SPONSORS, AGENTS AND PARENTS/GUARDIANS
Data regarding your enrolment, attendance and marks may be shared with your parents or another holder of parental responsibility and/or your designated sponsors, in order to perform the contract with you and to comply with their legitimate interest to be informed about your progress. Information may also be shared via your designated agent. The data mentioned is not an exhaustive list and there may be other types of data that are shared for the purpose of performing the contract with you or for a legitimate interest.
TRANSFERRING INFORMATION OUTSIDE YOUR COUNTRY
As well as within the UK, we may transfer the personal information we collect about you to the following countries in order to enter into and perform our contract with you or for our legitimate interest of corporate group administrative purposes:
- Australia
- Brazil
- Canada
- China
- Dubai
- Hong Kong
- India
- Indonesia
- Malaysia
- Netherlands
- New Zealand
- Republic of Ireland
- Singapore
- South Korea
- Taiwan
- Thailand
- USA
- Vietnam
There is an adequacy decision in respect of the following countries; Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland and Uruguay as providing adequate protection. This means that these countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information.
To ensure that your personal information does receive an adequate level of protection wherever it is transferred within Study Group, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with data protection regulations in the applicable jurisdiction. If you require further information about these protective measures, you can request it from the DPO.
DATA SECURITY
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information 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, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the DPO or by reference to the Data Protection Policy.
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.
DATA RETENTION
How long will you use my information for?
We will only retain your personal information for as long as is necessary either to fulfil the purposes we collected it for or for the purposes of satisfying any legal, accounting, or reporting requirements. We will retain data after completion of your course where we have obtained your consent, where required by law e.g. for tax purposes, or where required to protect our legitimate interests. 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 any applicable legal requirements. After this period we will use our best endeavours to securely destroy your personal information.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
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 study with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information 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 information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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 information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.
No fee usually required
You will not have to pay a fee to access your personal information (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.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, a procedure that is comparably simple to the procedure for giving consent will be followed. You may in either case withdraw consent by contacting the DPO. 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.
DATA PROTECTION OFFICER (DPO)
We have appointed an external DPO to oversee compliance with this privacy notice. If you have any questions about this Notice or how we handle your personal information, please contact the DPO, Aphaia Limited, at dpo@aphaia.co.uk. You have the right to make a complaint at any time to your relevant Information Commissioner for data protection issues. For any general data protection related queries, you can contact privacy@studygroup.com.
CHANGES TO THIS PRIVACY NOTICE
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.
If you have any questions about this privacy notice, please contact the DPO at dpo@aphaia.co.uk.
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