Apprenticeship privacy notice
This privacy notice explains what types of information will be gathered about you as an apprentice, and how this information will be used.
Nottingham Trent University is committed to protecting the privacy and security of your personal information, this Privacy Notice provides important information about how Nottingham Trent University and its associated entities (“NTU,” “we,” or “us”) which includes Confetti Constellations Ltd, Nottingham Conference Centre Ltd, Nottingham Consultants Ltd, Nottingham Law School Legal Advice Centre Ltd, Nova Centric Ltd and NTU Temporary Staff Ltd) (“we”, “our” or “us”) identifies and manages its Data Protection responsibilities in accordance with its legal and regulatory obligations.
NTU encourages you to review the privacy statements of any websites you choose to navigate to from our website (or navigate from to our website) or digital services that we provide links to so that you can understand how those websites collect, use and share your information as well. Any third party sites that you can access through the website are not covered by this Privacy Notice and we accept no responsibility or liability for these sites.
Who we are
NTU is a “data controller” which means we are responsible for deciding how we hold and use personal information about you.
This Privacy Notice applies to all apprenticeship students studying at NTU (“you” or “your”) or using services that link to it (collectively, our “Services”). Occasionally, a Service will link to a different Privacy Statement that will outline the particular privacy practices of that Service – which are available on our Information Governance site.
Please read this Privacy Notice carefully and contact our Data Protection Officer if you have any questions about our privacy practices or your personal information choices:
- Nottingham Trent University Address: 50 Shakespeare Street, Nottingham, NG1 4FQ
- Email: DPO@ntu.ac.uk
We may need to update this Privacy Notice from time to time. If changes made to this Privacy Notice are considered to be material, we will take reasonable steps to publish the changes.
NTU is committed to the responsible handling and protection of personal information.
Personal Data, or personal information, means any information about an individual from which that person (a “Data Subject”) can be identified. It does not include data where the identity has been removed (anonymous data).The information will be Personal Data if a person can be identified either directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. For example personal data may include names, addresses, email addresses and telephone numbers; it may also include images in photographs or films and recorded telephone conversations.
Why we process your data
We collect, use, disclose, transfer, and store personal information to provide services to you and for our operational and business purposes as described in this Privacy Notice. We want to be clear about our privacy practices so that you are fully informed and can make choices about the use of your information, and we encourage you to contact us at any time with questions or concerns by emailing DPO@ntu.ac.uk.
The types of personal information we collect
By participating in an apprenticeship at the University (as a student/apprentice / employer / prospective business) we collect personal information from you. This will include details for you to register as a student with the University (please see the Student Privacy Notice), information required by the ESFA (Education & Skills Funding Agency), information required for apprenticeship work based learning. The categories of personal information that we may collect, store and use about you include (but are not limited to):
- Student information (full name, address, telephone number, email, gender, date of birth – for full details see the Student Privacy Notice
- Apprenticeship information (Unique Learner Number, NI Number, employment information including details of your employer and communications received from them)
- Your contact details
- Equality and diversity information (special category data)
- Financial and Bank details and/or payment card details
- Visual images / photographs (including CCTV)
- Computing and email information including login details, network access and library usage.
Special category of more sensitive personal information may include (but are not limited to) racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions we have asked you to declare.
We may process special category personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations or comply with relevant legislation.
- Where it is needed in the public interest, such as for equal opportunities monitoring and reporting or to carry out Criminal Record background checks.
- Where it is needed to assess your capacity to study on health grounds, to enable us to offer you the support, for example through Student Support Services such as access requirements or accommodation requirements if you have a disability or other medical condition, subject to appropriate confidentiality safeguards.
- Where it is needed to investigate student behaviour (under our Student Code of Behaviour).
- Where the processing is necessary for archiving purposes in the public interest, or for scientific or historical research purposes, or statistical purposes, subject to further safeguards for your fundamental rights and interests specified in law.
How we collect your data
The information you provide to make an enquiry relating to an apprenticeship with the University is required to enable us to enter into a contract with you for you and your employer and is a requirement to enable you to participate in the apprenticeship.
Not all of the personal information NTU holds about you will always come directly from you, we may obtain information about you from third parties. This information may include:
- Your Unique Learner Number and/or Employer Reference Number which is a requirement for the apprenticeship
- Data that we and our staff generate about you in connection with your involvement in the apprenticeship
- Information your employer has provided
- Through interactions you have with individual services at NTU.
How and when will data about you be used
The University, your employer and organisations/third parties connected to apprenticeships (including partners that we use) may use your information for the following purposes:
- To provide the apprenticeship/course of study to you
- To track your progress and your performance on the apprenticeship
- To maintain your Individual learner Record (ILR) and provide returns to the Government
- To work with Functional Skills and End Point Assessment Organisations
- For statistical analysis on apprenticeships or cohorts of apprentices at the University
- To market our services/apprenticeships within the University.
We will use your information for the following purposes:
- Where it is necessary for us to perform the contract with you
- Where it is necessary in the performance of our public task as a University
- Where it is necessary for the purposes of complying with a legal obligation
- Where we have your consent.
- Progressive profiling – we may use your personal information to better personalise communications to you
- Analysing web behaviour – we may use your personal information to recognise web visitors on and off our Digital Services to improve experiences, analyse marketing activities, understand audiences, and personalise content for our Digital Services, applications and advertising
- Targeting advertising – using data collected automatically on and off our Digital Services to target and tailor advertising and analyse marketing activities (e.g. retargeting users from an NTU website, or using anonymous data segments created by trusted partners who may collect your data)
- Internal data matching – to enable us to merge certain types of data collected by NTU to identify known and unknown users and map interactions with NTU’s Digital Services to CRM (Customer Relationship Management) platforms and applications, for purposes of personalising content, understanding audiences, analysing marketing performance and targeting advertising
- External data matching – to match customer lists with online platforms (e.g. through applications such as Facebook Custom Audiences and Google Customer Match) to target and tailor advertising, understand audiences and analyse marketing activities.
Who we share your data with
NTU shares or discloses personal information when necessary to provide Services or conduct our business operations. When we share personal information, we do so in accordance with data privacy and security requirements. Information about you is accessible to the University and its schools and professional departments (other apprentices do not have access to your data). Certain of your information is also accessible to your employer.
We may share your data with third party companies/organisations associated with the apprenticeship, including:
- Your employer
- Organisations providing Functional Skills Training
- End point assessment organisations
- Ofsted (https://www.gov.uk/government/publications/ofsted-privacy-notices)
- ESFA https://www.gov.uk/government/publications/esfa-privacy-notice).
We may also share your data with other organisations who we work or partner with from time to time; our professional advisors and any law enforcement agency (including court, regulator) where we believe it is necessary to comply with a legal/regulatory obligation.
How long we keep your data for
We will keep your information for as long as is necessary for us to fulfil the purposes set out in this Privacy Notice. We will retain information about your participation on the apprenticeship in accordance with ESFA regulations. Please see the Student Privacy Notice for student data retention periods.
How we secure your data
We have 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, agents, contractors and other third parties who have a business requirement to know.
NTU takes data security seriously, and we use appropriate technologies and procedures to protect personal information.
- Policies and procedures – measures are in place to protect against accidental loss and unauthorised access, use, destruction, or disclosure of data.
- Business Continuity and Disaster Recovery strategies that are designed to safeguard the continuity of our service to our clients and to protect our people and assets.
- Appropriate restrictions on access to personal information.
- Monitoring and physical measures, to store and transfer data securely.
- Data Privacy Impact Assessments (DPIA) in accordance with legal requirements and our business policies.
- Periodic training on privacy, information security, and other related subjects for employees and contractors.
- Vendor risk management.
- Contracts and security reviews on third-party vendors and providers of services.
How we keep your data secure in other countries
Your personal information may be transferred by us or our trusted partners outside of the European Economic Area (the “EEA”). The trusted partners that may do this are organisations who process data for analysis or marketing purposes, including a marketing automation hub where the email address of recipients will be logged and a record of email delivery, opening, click-through and bounce-backs will be kept. Our partner uses Microsoft’s Windows Azure data centres located in East US (Virginia), West Europe (Netherlands), and Australia East (New South Wales).
NTU has networks, databases, servers, systems, and support located throughout the world. NTU collaborates with third parties such as cloud hosting services, suppliers, and technology support located around the world to serve the needs of the NTU, workforce, and students. Your personal information may be shared with record matching and customer targeting partners, including Google, Facebook, Snapchat and LinkedIn. Some of these partners process personal data in Canada and the United States of America.
We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within NTU or to third parties in areas outside of your home country.
NTU shall ensure that your personal information transferred to countries outside of the EEA is adequately protection by transferring the personal information on terms of the standard data protection clauses adopted by the European Commission.
This means, your rights and protection remain with your data, ie: we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your personal information protect it.
We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.
Under certain circumstances, by law you have the right to:
- Request access to your personal information
- Ask us to correct or update personal information that we hold about you
- Ask us to erase personal information in limited circumstances
- Object to our processing or companies participating in the apprenticeship from processing your information in certain circumstances
- Object to direct marketing from us or companies participating in the apprenticeship
- Request that we provide you with your information in an electronic format and to have this transmitted to another organisation
- Another party.
How to contact us
If you are concerned about an aspect of your learning experience, you can use the complaints procedure for students to bring your concerns to the attention of relevant staff. The procedure enables investigation of the concerns with the aim of satisfactory resolution, and is available to students who are enrolled on NTU courses. Students who are studying at franchised centres should follow the centre's procedures in the first place. Our complaints procedures can be accessed through the following links: Employer Complaint Procedure; Complaints Procedure for Students.
Please contact us with any requests related to your personal information, or with any questions or queries you may have about this statement. Our DPO contact is:
If you are not satisfied with how NTU manages your personal data, you have the right to make a complaint to a data protection regulator. The ICO contact details are: