Privacy Policy
InUni Marketing Limited Privacy Policy

InUni Marketing Ltd (“InUni”) takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.

When processing your Personal Data, on occasions, on behalf of our partner institutions’ we are obliged to fulfil individuals’ reasonable expectations of privacy by complying with the UK General Data Protection Regulation (the UK GDPR), the Data Protection Act 2018 (DPA), and other relevant legislation and regulations (collectively “Data Protection Law”).

Purpose of this Notice

This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this notice at any time and we may supplement or amend this notice by additional policies and guidelines from time to time. We will notify you if this notice is amended.

1. Who we are

InUni Marketing Ltd (also referred to in this notice as “we” or “us”) is a data controller (which means we are responsible for deciding how we hold and use your personal information) of your data and is part of The Global University Systems B.V. group of companies which is made up of different entities, details of which can be found at https://www.globaluniversitysystems.com/

InUni Marketing Ltd is a UK based global student recruitment company. We assist applicants in finding suitable education admissions offers from one of our partner university or suggesting alternative universities from our portfolio, based on your eligibility.

InUni Marketing Limited’s Companies House registration number: 07581287

2. Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details:

Our contact details

Email address: DPO@InUniglobal.com

Postal address: Belmont House, Station Way, Crawley, West Sussex, RH10 1JA

InUni Marketing Limited maintains a data protection registration with the Information Commissioner's Office, the independent authority which oversees compliance with the Data Protection Legislation. InUni Marketing Limited registration number is ZA843307 and sets out, in very general terms, the full range of purposes for which we use, students and all other personal information.

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

3. What is personal data?

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).

4. How we use your personal data

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).

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 following the opt-out links on any marketing message or contact us using the contact details in this Privacy Policy.

5. The personal data we collect from you

Enquiries

When you request information or make enquiries about any of the programmes or schools we recruit for, we may use the personal data you provide in order to fulfil your request or respond to your enquiry. It is in our legitimate interests to use your personal data in this way so that you receive the information you have requested.

You may give us information about you on our website completing a form, downloading a prospectus, by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.

Applications

If you make an application to study on one of the institutions we recruit for we may collect the following categories of 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.
Photo ID (e.g. your passport, driving licence or government ID)
Visa information and immigration status.
Education history.
Employment history.
Funding information.
It is in our legitimate interests to collect and use the above information in order to consider and process your application.

As part of our application process, we are obliged to ask for the following information on behalf of HESA (the Higher Education Statistics Agency), the official agency for the collection, analysis and dissemination of quantitative information about higher education in the UK. You can choose whether to provide this information to us or not.

Gender
Religion.
Sexual orientation.
Disabilities.
Ethnic origin.
Gender orientation.

Marketing

Where you have explicitly consented to do so, we may use your personal data to inform you of special offers and new or existing services offered by us, and or courses our partners’ offer that are similar to those that you have already purchased or enquired about. This may also include surveys or questionnaires so that we can learn more about your needs and interests.

From time to time we may use your personal data to offer you the opportunity to participate in contests, sweepstakes and other promotions. When you enter you should carefully review any rules, as they may contain additional information about our use of your personal data.

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 Policy. Please also see the section entitled “Your rights as a data subject” in this Privacy Policy.

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 for further details.

Our website

With regard to each of your visits to our website and we may automatically collect the following information:

  • technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages you viewed or searched for;
  • • page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We will use this information:

  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you and assist you in participating in interactive features of our service and track your progress on one of our courses;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

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 Policy if you would like more information.

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.

Parents and guardians

We collect personal data as described above. However if you are under 16 years of age and want to request information, download a prospectus, apply or enrol on one of our courses or contact us, you must ask your parent or guardian for permission. Our courses are not available to anyone under the age of 18.

6. When and how we share your personal data with others

We may share your personal data with third parties where required by law, where it is necessary to perform our contract with you or where we have a legitimate interest in doing so. 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 processing payments, providing customer service and marketing assistance, performing business and sales analysis, advertising, analytics, search information services, credit reference services and supporting our website and IT functionality. 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. InUni is the data controller and will remain accountable for your personal data.

Our business partners:

We may share your personal data with our university partners or with your sponsor with whom we have a contract relating to your programme of study.

Agents:

If you use an agent to arrange your application or study with us, we may share your personal data with them.

Other entities in the GUS 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.

Regulators:

We may need to share your personal data if required by a regulator or to otherwise comply with law.

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.

7. Transfer of your personal data to other countries
  • As we are part of 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 Policy. These steps include putting in place appropriate contractual mechanisms. Please contact us using the contact details in this Privacy Notice if you would like more information.
8. The security of your personal data
  • 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.
9. Our storage and retention of your personal data
  • 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 Policy 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.
10. Your rights as a data subject

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 in writing using the contact details in this Privacy Policy.

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 Policy. 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.

11. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy 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.

This Policy was last updated on 7th September 2020 Due for Review by: 7th September 2021

Website visitor – Privacy Notice

Types of personal information we collect

We collect, use and store different types of personal information about you, which we have grouped together as follows:

Types of personal information> Description>
Publicly Available Data Details about you that are publicly available, such as on Companies House or elsewhere on the internet
Marketing Data Details about your preferences in receiving marketing communications from us and our third parties
Consents Data Any permissions, consents or preferences that you give us
Usage Data Information about how you use our website, products and services

How we use your information

Cookies

For more information on our cookies use, please read our cookies policy

Generally

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.

What we use your information for Our reasons Our legitimate interests
To provide you with information you may ask for Consent Legitimate interests To fulfil enquires you might make of us
To allow you to register for updates or for notifications of blog posts on our website Consent Legitimate interests To provide you with information that you may request from us
To allow you to register for events that we may be hosting Consent Legitimate interests To hold events, such as seminars, webinars, open days or corporate hospitality to promote our business and its services
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Legitimate interests To provide efficient client care and services
To ensure that our technology operates efficiently and without error
To assess which of our services may be of interest to you and to tell you about them
To develop new products and services and improve existing ones
To manage our relationship with you which will include notifying you about changes to our privacy notice and our website terms and conditions Legitimate interests Contract performance To provide efficient client care and services To keep you updated about changes in the legal terms that apply to the use of our website For record keeping and firm management
To manage the systems that contain our marketing database
To manage marketing preferences and keep our records up to date
Legitimate interests For data management for marketing and business development purposes
To improve our systems and services
To seek feedback
To seek your consent when we need it to contact you
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Legitimate interests Consent To improve our marketing strategy and the services that we provide
Sharing information with third parties - to facilitate data-gathering to improve our educational services, our website, and our marketing efforts. Legitimate interests For the purposes of InUni’s legitimate business interests such as managing and developing its business

Where we collect your personal information from

We may collect personal information about you from the following sources:

  • Directly from you
  • Cookies – see our cookie statement which can be accessed from our website
  • Analytics providers, such as Google Analytics

Who we share your information with

We may share your personal information with the following third parties:

  • Our agents and service providers who we use to help us with marketing.
  • Event organisers (if we are organising an external event which you are attending)
  • The police and other law enforcement agencies
  • Relevant regulators, including the Information Commissioner's Office in the event of a personal data breach
  • Other companies owned or jointly owned by Global University Systems and/or our partner institutions
  • Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business.

How long we keep your personal information

Where we use your personal information for marketing purposes we will retain your personal information for so long as we have your consent to do so (where we use your personal information with your consent in order to send you marketing messages) or, in other cases, for so long as we have a legitimate business or commercial reason to do so (unless you ask us to stop).

Where you withdraw your consent to receiving marketing materials or otherwise ask us to stop marketing we will add your details to a suppression list which ensures that we remember not to contact you again.

For further information as to how to withdraw your consent or to ask us to stop other marketing activities see Withdrawing consent using your information and Objecting to how we may use your information.

If you withdraw your consent to receiving marketing materials or ask us to stop our marketing activities, we will still communicate with you for other purposes in the normal course of any other relationship we may have with you.

International transfers

As a global company, we hold some personal information concerning our suppliers and their affairs within the United Kingdom. We do work with agents and service providers who may process your personal information on our behalf outside the EEA. If your information is processed outside the EEA, we will ensure that it is protected to the same standards as if it were being processed within the EEA by putting in place a contract with our agents and service providers that provides adequate safeguards.

If you require more information or have any queries, please contact our Data Protection Officer at: DPO@InUniglobal.com

Applicants Privacy Notice

1 Purpose of this Notice

Inuni Marketing Ltd ("we", "our", "us") are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this notice at any time and we may supplement or amend this notice by additional policies and guidelines from time to time. We will notify you if this notice is amended.

We are a data 'controller', which means we are responsible for deciding how we hold and use your personal information.

“Personal data” refers to information relating to a living, identifiable individual. It can also include "special categories of data", which is information about your racial or ethnic origin, religious or other beliefs, and physical or mental health, the processing of which is subject to strict requirements. Similarly, information about criminal convictions and offences is also subject to strict requirements.

“Processing” means any operation which we carry out on your personal data e.g. obtaining, storing, transferring and deleting.

2 Your personal information

We hold a range of personal data about you, some of which you provide to us direct and some of which we receive from third parties, such as agents where relevant. See below for further details of personal data we receive from third parties. Examples of categories of personal data which we hold are: your contact details, prior educational experience/attainment, immigration information (e.g. passport details, language proficiency), where relevant, health information (including any disabilities) and other equality-monitoring data you provide to us.

The purposes for which we process your personal data and the legal basis

When you are an applicant, we process your personal data for the purposes of assessing your eligibility to be offered a place on one of our partners academic or professional programmes.

If you are unsuccessful or do not take up a place at one of our partner institutions we will retain your personal data in line with our retention schedules for statistical and audit purposes or in the event of a complaint or an appeal.

We only process data for specified puposes and if it is justified in accordance with dataprotection law. The table below lists the various purposes for which we process personal data and the corresponding justification for it. Some processing of your personal data is justified on the basis of contractual necessity. In general, this applies to personal data you provide to us to process your application. Without that information, we would be unable to provide you with your chosen academic programme and related support services. Some personal data is also required to fulfil our legal obligations regarding immigration. A failure to provide that information would prejudice your application for a Tier 4 visa.

Purpose Legal basis/ justification
Assessing eligibility to undertake our partners academic or professional programmes. Processing is necessary for the purposes of taking steps prior to entering into a contract with us
Supporting applicants through the application process and providing further information on the services we can offer Necessary for negotiating to enter into a contract and legitimate interests in providing support to applicants
Making reasonable adjustments for disabilities and providing relevant support to students with ill health and providing wellbeing support. This includes processing special category information. Explicit consent.
Obtaining payment of fees. Contractual necessity and our legitimate interest in obtaining payment for the services we provide.
To facilitate data-gathering to improve our educational recruitment services, our website, and our marketing efforts. InUni’s legitimate business interests such as managing and developing its business

Where the basis of processing your personal data is contractual necessity and you fail to provide the personal data in question, InUni Marketing Limited may not be able to process your application or provide you with the programme for which you have applied. A failure to provide immigration-related data may result in failure to obtain a Tier 4 visa for those who students who require it.

Personal data received from third parties

Data Source
Your immigration status. Home Office (UKVI) and other country immigration data as relevant
Transcripts - details of programmes undertaken or being undertaken at another institution; attainment. Another institution and/or secondary/high schools.
Details of any InUni Marketing Ltd Limited -associated complaint Office of the Independent Adjudicator, and/or Competition and Markets Authority
Information required to assess eligibility for courses i.e. from employers or sponsors. Employers or sponsors.

On occasion we may need to share your data with third parties. The following table lists what information we may share with whom

Recipients Data which we may share with them
Data processors i.e. third parties who process personal data on our behalf e.g. software providers or marketing service providers Application or contact details which are not retained by the third party
Government agencies i.e. HMRC* Contact details and potentially other information if requested where there is a legal basis.
Police*. Contact details and potentially other information if requested where there is a legal basis.
Other UK based and international educational institutions which InUni Marketing Limited partners or collaborates with Contact details, application details to assess eligibility for the programs you are interested in or make suggestions for other suitable study options based on your suitability for the program.

* This will only be shared on request and where there is a legal basis for doing so.

Overseas transfers of personal data (i.e. outside the European Economic Area (EEA)

Where possible, we aim to hold personal data relating to students within the EEA. Where any of your personal data is transferred outside the EEA it will be subject to a legally binding data sharing agreement and to an adequacy decision by the European Commission (country, territory or specified sectors), or other appropriate safeguards as set out in Article 46 of the UK GDPR.

Retention of data

The length of time that we keep your personal data for is set out in our Retention Schedule, please contact DPO@InUniglobal.com for more information.

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data processed by us:

  • To gain access to your personal data;
  • To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
  • To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
  • To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
  • To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
  • To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
  • To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month.

Exercising your rights, queries and complaints

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at: DPO@InUniglobal.com

Complaints to the Information Commissioner

You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/

Recruitment Privacy Notice

This notice applies to individuals applying to work with us, including prospective directors, employees, trainees, apprentices, work experience students, workers, consultants and contractors. It applies whether the work applied for is part time or full time; or permanent, temporary or for a fixed term.

We are a data 'controller', which means we are responsible for deciding how we hold and use your personal information. This notice explains how and why we will collect and use your personal information in the context of the recruitment process and your rights in relation to your personal information. We may amend this notice at any time.

2 Your personal information

In this privacy notice, 'your personal information' means your personal data i.e. information about you from which you can be identified. Sections 5 and 6 below set out your personal information that we may process.

Your 'personal information' does not include data where the identity has been removed (anonymous data).

It is important that your personal information is accurate and up to date. Please inform us if your personal information changes during the recruitment process.

3 Special categories of personal information

'Special categories of personal information' means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purpose of uniquely identifying you.

Data marked * in the table at section 5 below, and data described at section 6, falls within these 'special categories' or might disclose special categories of personal information. We must have additional legal grounds for processing special categories of personal information, and these grounds are set out at sections 5 and 6 below.

4 Where does your personal information come from?

Your personal information will come from you or us, and may also come from the following sources:

Recruitment agencies and apprenticeship providers may provide us with the following personal information: personal contact details, qualifications, schools attended, details of previous employment(s), skills and experience, hobbies and interests, and interview notes.

Credit reference agencies may provide us with the following personal information: personal contact details, date of birth, details of credit accounts and usage and an overall credit score.

Former employers or other referees, whom you have given us permission to contact, may provide us with the following personal information: role(s) held, dates of employment, details of skills and capabilities and any other information that helps to assess your suitability for the position applied for.

InUni Marketing Ltd staff may provide us with: personal information about you if they are referring you for recruitment.

Medical professionals may provide us with the following personal information: information relating to any disability that you may have, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability.

Professional bodies such as the, Association of Chartered Certified Accountants, Law Society of England and Wales, and / or the Solicitors Regulation Authority may provide us with the following personal information: qualifications, registrations, practising certificates, accreditation details and membership details.

Google and social networking accounts (such as LinkedIn): as part of the recruitment process we may source personal information relating to roles you have held, details of skills and capabilities and any other information that helps us to assess your suitability for the position applied for.

Disclosure Scotland: as described at section 6 below.

5 Processing your personal information

We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.

In general, we process your personal information for the reasons, and on the legal grounds set out in the following table, and also to:

  • Retain records relating to the recruitment process;
  • Establish, exercise or defend legal claims;
  • Comply with the law or requirements of any regulator; and
  • Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).
Reason for processing your personal information Legal ground(s) for processing, and legitimate interest (where applicable) Your personal information
Contact you regarding the recruitment process and any offer of work To enter a contract Personal contact details (including name, address, email, telephone number)
Make a decision about your recruitment or appointment, including assessing your skills, To enter a contract Information provided in your application form, CV, any covering letter or email, and interview notes Information sourced from google and social networking accounts (such as LinkedIn) relating to roles you have held, details of skills and capabilities and other information that helps us to assess your suitability for the work.
qualifications and suitability for the work For our legitimate interests: to select suitable employees, workers and contractors Information sourced from google and social networking accounts (such as LinkedIn) relating to roles you have held, details of skills and capabilities and other information that helps us to assess your suitability for the work.
If you have accepted an offer of work from us that is subject to such checks:
Take up references (from referees whom you have given us permission to contact);
Carry out credit checks; and / or
Confirm your professional memberships, registrations and / or qualifications.
To enter a contract
For our legitimate interests: to select suitable employees, workers and contractors
References and details of previous employers (including role(s) held, dates of previous employment, details of skills and capabilities and other information that helps to assess your suitability for the position applied for) Results of credit check: personal contact details, date of birth, details of credit accounts and usage and credit score Professional qualifications, registrations, practising certificates, accreditation details, and membership details
Determine the terms of any potential contract between you and us To enter a contract To comply with a legal obligation Offer letter, and proposed contract between you and us
If you have accepted an offer of work, check you are legally entitled to work in the UK To enter a contract To comply with a legal obligation Documentation confirming your right to work in the UK
Consider reasonable adjustments to the recruitment process for disabled applicants To enter a contract To comply with a legal obligation For our legitimate interests: To select suitable employees, workers and contractors *For special categories of information: To exercise or perform employment law rights or obligations Information about a disability, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability*
To exercise or perform employment law rights or obligations
Carry out equal opportunities monitoring. For our legitimate interests: To review equality of opportunity or treatment *For special categories of information: To review equality of opportunity or treatment To exercise or perform employment law rights or obligations The following information you have provided via our equal opportunities monitoring form: Health data, including disability information* Information regarding pregnancy and maternity* Age and date of birth Marriage or civil partnership status* Gender Information on gender reassignment* Data revealing race, religious beliefs or sexual orientation*

6 Information about criminal convictions

To enable us to make recruitment decisions and assess suitability for particular work, we will process information about criminal convictions and offences (including alleged offences) as described in this section 6. We will process this information to enter a contract with you, to comply with a legal obligation, for our legitimate interests (in selecting suitable employees, workers and contractors), and to exercise or perform employment law rights or obligations. If you have accepted an offer of work from us that is subject to a criminal record check, we will ask you to obtain a disclosure check (at the appropriate level) from Disclosure Scotland, and provide us with a copy of this.

7 Data necessary for the contract

Sections 5 and 6 above identify personal information that we may need to enter a contract with you. You are not obliged to provide this information, but if you don't provide it, we may not be able to proceed with the recruitment process or enter into the contract.

8 Statutory requirement to provide your personal information

In some circumstances, the provision of your personal information relates to a statutory requirement. This includes:

Documentation confirming your right to work in the UK – you are not obliged to provide this information, but if you don't provide it, we will not be able to enter into a contract with you.

9 Sharing your personal information with third parties

We may share your personal information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

Health professionals and occupational health providers involved in your care, in order to consider reasonable adjustments to the recruitment process for disabled applicants.

Relevant regulators such as The Association of Chartered Certified Accountants, the Law Society of England and Wales and the Solicitors Regulation Authority.

Our professional advisors.

Other third parties as necessary to comply with the law.

10 Automated decision-making

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

11 Transferring your personal information outside the EU

We share your personal data within the GUS Group. This will involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

12 Data retention

If you don't start work with us following the recruitment process, we will retain your personal information for six months thereafter:

to allow us to establish, exercise or defend legal claims; and

for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for becomes available again.

If you ask us to retain your personal information so that we can contact you to discuss future work opportunities, we will write to you separately, to obtain your explicit consent to retain your personal information for a fixed period of two years on that basis.

If you start work with us following the recruitment process, we will give you a copy of our Staff Privacy Notice and will retain your personal information as detailed in the Staff Privacy Notice.

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data processed by us:

  • To gain access to your personal data;
  • To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
  • To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
  • To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
  • To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
  • To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
  • To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month

If you require more information or have any queries, please contact our Data Protection Officer at: DPO@InUniglobal.com

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner's Office. Full details may be accessed on the complaints section of the ICO's website

Staff Privacy Notice

InUni Marketing Ltd ("we", "our", "us") are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this notice at any time, and we may supplement or amend this notice by additional policies and guidelines from time to time. We will notify you if this notice is amended.

What is Personal Data?

'Personal data' means any information which identifies you as an individual. It may include your name, but it may also be other information such as your date of birth, nationality and gender which when combined identify you.

This Statement and InUni Marketing Limited data protection obligations

In accordance with the UK General Data Protection Regulation (the “UK GDPR”) and the Data Protection Act 2018 (the “DPA”), together, the “Data Protection Laws”, we are a Data Controller as we determine the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This means that we are legally responsible for the personal data we collect and hold about you. It also means that we must comply with the data protection principles (see below). One of our responsibilities is to tell you about the different ways in which we use your personal data – what information we collect (and our legal basis for doing so), why we collect it, where we collect it from and whether (and with whom) we will share it. We also need to tell you about your rights in relation to the information. This notice provides further details about all of these issues.

In order to comply with our contractual, statutory, and management obligations and responsibilities, we need to process personal data relating to our employees, including ‘sensitive’ or special categories’ of personal data, as defined in the Data Protection Laws which includes information relating to health, racial or ethnic origin, and criminal convictions.

All personal data will be processed in accordance with the Data Protection Laws and InUni Marketing Limited Privacy Policy.

Using your information in accordance with Data Protection Laws

Data Protection Laws require that we meet certain conditions before we are allowed to use your data in the manner described in this notice, including having a 'legal basis' for the processing.

The legal bases on which your personal data are collected, the types of personal data, and the purposes for which they are processed is given below.

Application for employment (Subsection)

We need to process your personal data that you supplied to InUni Marketing Limited as part of your application for a position at InUni Marketing Limited. This is to ensure that your application can be considered by the relevant department. In your application we will collect the following information:

Personal data gathered

In your application we will collect the following information

  • First Name(s)
  • Last Name
  • Title
  • Other Name(s)
  • Preferred Forename
  • Your Address
  • Postcode
  • Telephone (Home)
  • Telephone (Work)
  • Telephone (Mobile)
  • Your personal Email
  • Details of your Secondary and/or Tertiary education
  • Professional qualifications
  • Statement in support of your application
  • Details within your submitted Curriculum Vitae (CV)
  • Details of your right to work in the UK
  • Information about your present and employment history for the previous five (5) years including:
  • Name of Employer(s)
  • Address Line 1
  • Address Line 2
  • Town
  • County
  • Postcode
  • Job Title
  • Date From
  • Date To
  • Salary
  • Notice Required

In addition, we may contact your referees as provided in your application to confirm the employment information that you provided.

Special categories personal data

As part of the application you will be asked to provide equality and diversity information, this may include data concerning:

  • Any disability
  • Your ethnicity
  • Your sexual orientation
  • Your religious beliefs

You have the right to not provide this information, in which case InUni Marketing Limited will note to statutory bodies that you elected not to provide this information

Criminal records information

In some circumstances we may process your information to undertake a Disclosure and Barring Service (DBS) check, as required by law.

During your employment (subsection)

The Data Protection Laws define ‘sensitive personal data’ or 'special categories of personal data' as information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, data concerning sex life or sexual orientation. We will process this data, as well as the data provided in your application in order to perform our obligations arising from your contract of employment with us. The additional personal data we process to meet these responsibilities includes:

Additional data-personal information

The additional personal data (including some special category personal data) we process to meet our responsibilities as an employer includes the following:

    Previous sickness information including the reasons for the absence

    Bank account details

    Passport details

    Visa details

    Sick pay

    Leave entitlement

    Parental pay

    Pensions data

    Remuneration and benefits

    Emergency contacts

    Trade Union Membership

Statutory responsibilities

We may process your personal data in order to meet responsibilities imposed on us by legislation. The personal data processed to meet statutory responsibilities includes, but is not limited to, data relating to:

  • tax;
  • national insurance;
  • statutory sick pay;
  • statutory maternity pay;
  • family leave;
  • work permits, and
  • equal opportunities monitoring.

Our lawful basis for processing

The lawful bases for processing personal data will be:

  • Article 6(1) (b) Contract
  • Article 6(1) (c) Legal obligation
  • Article 6(1) (f) Legitimate interest

Purpose of processing

We will use your personal data in connection with your employment relationship with us, including for the following purposes:

  • To facilitate staff training, such as e-learning.
  • Managing our accounts and records and providing commercial activities to our clients.
  • For the use of CCTV systems to monitor and collect visual images for the purposes of security and the prevention and detection of crime
  • To provide you access to relevant systems to undertake your role.
  • To fulfil our obligations for the contract of employment.
  • Processing recruitment applications.
  • Talent, performance and succession planning.
  • Paying and reviewing salary and other remuneration and benefits.
  • Providing and administering benefits (including pension, voluntary healthcare schemes, salary sacrifice schemes and others).
  • Undertaking performance appraisals and reviews.
  • Policy and Legal Governance requirements and compliance.
  • Internal audit and data collection.
  • Legal compliance, requirements and obligations.
  • Maintaining sickness and other absence records.
  • Providing references and information to future employers and, if necessary, governmental bodies.
  • Processing information regarding equality of opportunity and treatment of data subjects in line with the monitoring of equal opportunities and access.
  • The information we process may be held on InUni Marketing Ltd’s Corporate systems some of which may be owned and operated by third parties. Where we engage with such third parties, we insist upon strict contractual requirements to be adhered to by them to protect the personal data.

Special categories personal data

The Data Protection Laws define ‘sensitive personal data’ or 'special categories of personal data' as information about racial or ethnic origin; political opinions; religious beliefs or other similar beliefs; trade union membership; physical or mental health; sexual life. In certain limited circumstances, the Data Protection Laws permit us to process such data without requiring the explicit consent of the employee.

(a) We will process sensitive personal data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and consent.

(b) Other than in exceptional circumstances, InUni Marketing Limited will process sensitive personal data about an employee’s racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for the purpose of monitoring and upholding InUni Marketing Limited’s equal opportunities policies and related provisions.

(c) Information about an employee’s criminal convictions will be held as necessary and only in accordance with Data Protection Legislation.

The lawful basis for processing this special category personal data will be:

The UK GDPR Article 9(2)(b) ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.

Sharing personal data

We sometimes need to share the personal information we process with you and also with other organisations. Where this is necessary we are required to comply with all aspects of the Data Protection Laws.

We may use third party providers to deliver our services, such as externally hosted software or cloud providers, and those providers may involve transfers of personal data outside of the EU. Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

Where necessary or required we will share your information with:

  • family, associates and representatives of the person whose personal data we are processing;
  • current, past or prospective employers;
  • healthcare, social and welfare organisations;
  • suppliers and service providers;
  • financial organisations;
  • auditors;
  • police forces, security organisations;
  • courts and tribunals;
  • prison and probation services;
  • legal representatives;
  • local and central government;
  • consultants and professional advisers;
  • trade union and staff associations;
  • survey and research organisations, and
  • press and the media.

Furthermore, in order to fulfil its statutory responsibilities, InUni Marketing Limited is required to provide some of an employee’s personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.

Automated processing

InUni Marketing Limited does not use automated processing and decision making without manual intervention.

Principles

We will handle your personal data in accordance with the principles set out below:

Principle Personal Data shall be:
Lawfulness, fairness and transparency be processed lawfully, fairly and in a transparent manner in relation to the data subject.
Purpose limitation collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Data minimisation adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy accurate and, where necessary, kept up to date.
Storage limitation kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
Integrity and confidentiality processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
Accountability be able to demonstrate compliance with the above principles

Keeping personal data up-to date

The Data Protection Laws require us to take reasonable steps to ensure that any personal data we process is accurate and up-to-date. Employees are responsible for informing us of any changes to the personal data that they have supplied during the course of their employment. You can contact cezannehr@gus.global to update your personal data.

Retention of your data

InUni Marketing Limited retains personal information it collects from you where there is an ongoing business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When there is no ongoing business need to process your personal information, InUni Marketing Limited will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then InUni Marketing Limited will securely store your personal information and isolate it from any further processing until deletion is possible. Personnel files are retained for a period of at least 6 years from the date of termination of employment.

How does InUni Marketing Limited protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

Your rights

Under certain circumstances, you may have the following rights in relation to your personal data:

  • Right 1:
    A right to access personal data held by us about you.
  • Right 2:
    A right to require us to rectify any inaccurate personal data held by us about you.
  • Right 3:
    A right to require us to erase personal data held by us about you. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
  • Right 4:
    A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.
  • Right 5:
    A right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organisation.
  • Right 6:
    A right to object to our processing of personal data held by us about you.
  • Right 7:
    A right to withdraw your consent, where we are relying on it to use your personal data.
  • Right 8:
    For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at: DPO@InUniglobal.com

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at: DPO@InUniglobal.com

Changes to our privacy Policy

Any changes we make to this privacy notice in the future will be [posted on this page] and, where appropriate, notified to you by e-mail.

Who regulates the use of my personal information?

InUni Marketing Limited maintains a data protection registration with the Information Commissioner's Office, the independent authority which oversees compliance with the Data Protection Legislation. InUni Marketing Limited registration number is ZA843307 and sets out, in very general terms, the full range of purposes for which we use, staff and all other personal information. Please visit the Information Commissioners Office website for details.

Who do I contact with questions?

The data controller for the purposes of the General Data Protection Regulation is InUni Marketing Limited. If you have any questions or concerns about how your personal data is used, please consult https://www.inuniglobal.com/privacy-policy.html and if you have a complaint please email InUni Marketing Limited Data Protection Officer at: DPO@InUniglobal.com

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner’s Office. Full details may be accessed on the complaints section of the ICO’s website

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner’s Office. Full details may be accessed on the complaints section of the ICO’s website

Suppliers to InUni Marketing Limited

Types of personal information we collect

We collect, use and store different types of personal information about you, which we have grouped together as follows:

Types of personal information Description
Identity Data Identity Data ID information including your name, marital status, title, date of birth and gender
Contact Data Your financial position, status and history, including bank details and credit rating
Transactional Data Details about payments to and from you and other details about services you purchase from us and we purchase from you
Communications Data What we learn about you from letters, emails and conversations between us
Publicly Available Data Details about you that are publicly available, such as on Companies House or elsewhere on the internet
Consents Data Any permissions, consents or preferences that you give us

How we use your information

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.

What we use your information for Our reasons Our legitimate interests
To receive the products or services you provide to us Contractual performance Legal obligation For company management To maintain access and control records For incident/breach reporting, management and investigation
Legitimate interests
To fulfil our contractual obligations Contractual performance Legitimate interests To comply with our contractual obligations to you and your organisation To properly manage the risks and liabilities associated with the contracts we are party to To comply with laws and regulations that apply to us To protect our reputation
To enforce the terms of our contract with you Contractual performance Legitimate interests To ensure that we benefit from the terms of the contracts we have entered into and properly manage the risks and liabilities associated with them
For procurement purposes, including supplier due diligence, background checks and the assessing of tenders To carry out credit checks Legitimate interests To carry out supplier due diligence To ensure our contracts provide us with best value To assess the financial worthiness and reliability of those with whom we deal
For financial administration, including calculating and managing payments, benchmarking, calculating fees and interest and collecting and recovering money that is owed to us Contractual performance Legitimate interests Our legal duties To meet our contractual obligations to you or your organisation To ensure that we benefit from the terms of the contracts we have entered into and properly manage the risks and liabilities associated with them To comply with laws and regulations that apply to us
To establish, enforce and defend legal claims Legal claims Legitimate interests To comply with laws and regulations that apply to us To respond to questions or complaints To maintain records to evidence matters that may be in dispute
To manage our business properly Consent Contractual performance To manage our business efficiently and properly in accordance with normal business practices, legal requirements
For corporate activity, such as a sale, transfer, merger or re-organisation of our business Legitimate interests To manage our business efficiently and properly in accordance with normal business practices, legal requirements and to optimise its value for shareholders To ensure that we run our business in accordance with good business principles and meet corporate governance, accounting and audit standards
For the prevention of crime and public safety, including through the use of CCTV Legal obligation Legitimate interests To manage the risk of crime and safety for us, our employees and our clients To develop and improve how we deal with crime To report criminality or the suspicion of criminality for the wider benefit of society To be efficient about how we fulfil our responsibilities generally

Where we collect your personal information from

We may collect personal information about you from the following sources:

  • Directly from you or the organisation for whom you work
  • Companies or individual that tell you about us
  • Publicly available resources, such as Companies House
  • The internet and social networking sites such as LinkedIn
  • Third parties with whom we deal with during the course of carrying on our business
  • Market researchers
  • Intermediaries such as other companies who know you

Who we share your information with

We may share your personal information with the following third parties:

  • Agents and service providers that we use during the course of providing services,
  • Our professional advisors
  • Other suppliers to the GUS Group
  • The police and other law enforcement agencies
  • Relevant regulators, including the Information Commissioner's Office in the event of a personal data breach
  • Other companies owned or jointly owned by GUS or our partner institutions
  • Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business

If you choose not to give your personal information

If you choose not to give us your personal information, it may delay or prevent us from being able to comply with our own legal obligations. It may also result in us being unable to, or refusing to, engage you or your organisations as a supplier.

Automated decisions

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

How long we keep your personal information

We will only retain your personal information 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In general terms, we will hold information for so long as you continue to provide us with products and services and for an additional period of 6 years thereafter.

International transfers

As a global company, we hold some personal information concerning our suppliers and their affairs within the United Kingdom. We do work with agents and service providers who may process your personal information on our behalf outside the EEA. If your information is processed outside the EEA, we will ensure that it is protected to the same standards as if it were being processed within the EEA by putting in place a contract with our agents and service providers that provides adequate safeguards.

If you require more information or have any queries, please contact our Data Protection Officer at: DPO@InUniglobal.com