BPP Privacy Policy (Interna1onal)

What is the purpose of this Privacy Policy?

BPP respects your privacy and is commi8ed to protec9ng your personal data. The aim of this Privacy Policy is to give you informa9on on how BPP collects and processes your personal data through:

a. your use of BPP websites, including any data you may provide through BPP websites when you make an enquiry or purchase a product or any course/programme (whether online, face to face or distance learning) and whether on behalf of yourself or as an employer client (“Services”);

b. your registra9on for, purchase of or use of any BPP products and/or Services (including but not limited to courses, programmes or study materials (in any medium));

c. your use of any BPP social media channel; and

d. your sending of personal data to BPP by any other means.

This Policy will also inform you of what we do with personal data, how we look aJer personal data and tell you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing no9ce we may provide on specific occasions when we are collec9ng or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other no9ces and is not intended to override them.

This Privacy Policy is provided in a layered format so, if you wish, you can select the specific areas of the Policy you are interested in, as set out below. We have also included a Glossary to help you understand the meaning of some of the terms used in this Privacy Policy.

1. WHO WE ARE

2. IMPORTANT INFORMATION ABOUT THIS POLICY

3. YOUR PERSONAL DATA

4. HOW YOUR PERSONAL DATA IS COLLECTED

5. HOW WE USE YOUR PERSONAL DATA

6. DISCLOSURES OF YOUR PERSONAL DATA

7. COMPLIANCE WITH BRIBERY ACT AND RELEVANT LEGISLATION

8. VIRTUAL LEARNING ENVIRONMENT

9. INTERNATIONAL TRANSFERS

10. DATA SECURITY

11. DATA RETENTION

12. YOUR LEGAL RIGHTS

13. GLOSSARY

1. Who we are

Data User

BPP Holdings Limited is the parent company of several different BPP companies within the UK and the Channel Islands. Details of the companies which make up the BPP Holdings group in the UK and Channel Islands can be found here.

For ease of reference this Policy shall refer to the relevant UK and Channel Island companies under BPP Holdings Limited as the “BPP Professional Educa1on Group (UK)”.

In addi9on to BPP Professional Educa9on Group (UK), BPP Holdings Limited is also the parent company of:

• BPP China Limited with its branch office in Hong Kong (“BPP China”);

• BPP Malaysia SDN. BHD incorporated in Malaysia (“BPP Malaysia”); and

• BPP Singapore Pte Limited incorporated in Singapore (“BPP Singapore”).

For ease of reference this Policy shall refer to the above three companies under BPP Holdings Limited as the “BPP Professional Educa1on Group (Interna1onal)”.

This Privacy Policy is issued on behalf of the BPP Professional Educa9on Group (Interna9onal) so when we men9on “BPP”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the BPP Professional Educa9on Group (Interna9onal) responsible for processing your data.

However, as set out further in this Policy, there will be occasions when your personal data is processed by a company within the BPP Professional Educa9on Group (UK). Informa9on on how the BPP Professional Educa9on Group (UK) processes personal data is available in its Privacy Policy which can be found here.

The table below sets out which BPP en9ty will be the data user of your personal data.

Contact details

BPP Singapore

Where the relevant data user is BPP Singapore we have appointed a data protec9on officer (“DPO”) who is responsible for overseeing ques9ons in rela9on to this Privacy Policy. If you have any ques9ons about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the following details:

FAO of Vicky Knight BPP Singapore Pte Limited 80 Robinson Road, #02-00, Singapore 068898 Telephone number: +65 905 87764 E m a i l a d d r e s s :

Dataprotec9on@bpp.com

Country in which you (or your business) is based Relevant Data User

Hong Kong BPP China Limited

Malaysia BPP Malaysia SDN. BHD

Singapore BPP Singapore Pte Limited

Other country within Asia BPP Singapore Pte Limited

UK or Europe Please see the Privacy Policy of BPP Professional Educa9on Group (UK)

BPP China and BPP Malaysia

Where the relevant data user is BPP China or BPP Malaysia you can contact BPP Professional Educa9on Group (UK)’s Data Protec9on Team who have been appointed to oversee ques9ons in rela9on to this Privacy Policy. If you have any ques9ons about this Privacy Policy, including any requests to exercise your legal rights, please contact the Team using the following details:

FAO of the Data Protec9on Team BPP Professional Educa9on Group, BPP Execu9ve Offices, 4th Floor, 3 London Wall Buildings, London, EC2M 5PD E m a i l a d d r e s s :

Dataprotec9on@bpp.com

You have the right to make a complaint at any 9me to:

• the Office of the Privacy Commissioner for Personal Data, the supervisory authority for data protec9on issues in Hong Kong (www.pcpd.org.hk/);

• the Personal Data Protec9on Commissioner, the supervisory authority for data protec9on issues in Malaysia (www.malaysia.gov.my/portal/content/30873); or

• the Personal Data Protec9on Commission, the supervisory authority for data protec9on issues in Singapore (www.pdpc.gov.sg/).

We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.

2. Important informa9on about this Policy

Local Language

You can access a copy of this Policy in the relevant local language by using the links below:

Changes to the Privacy Policy and your duty to inform us of changes

This Privacy Policy sets out your rights under the relevant local laws:

• The Personal Data (Privacy) Ordinance (Cap. 486) (Ordinance) (Hong Kong)

• Personal Data Protec9on Act 2010 (Malaysia)

• Personal Data Protec9on Act of 2012 (Singapore)

As this Policy covers BPP China, BPP Malaysia and BPP Singapore in order to ensure compliance with the minimum standards of each country’s legisla9on, there will be occasions where you are afforded addi9onal protec9ons not contained in the relevant local legisla9on.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your rela9onship with us.

We may update this Privacy Policy from 9me to 9me. This version was last updated on 11 June 2020.

Local Language Link to Policy

Cantonese

Malay

If you reject the terms of this Privacy Policy

If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through our website or any other means.

Third-party links

Our website may include links to third-party websites, plug-ins and applica9ons. Clicking on those links or enabling those connec9ons may allow third par9es to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. Your personal data

Personal data, or personal informa9on, means any informa9on about an individual from which that person can be iden9fied. It does not include data where the iden9ty has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Audio / Visual Data includes recordings from closed circuit televisions systems which we may in place at our premises for security purposes, telephone recordings (for monitoring and training purposes), recordings (including video, audio and text) where any course or other interac9ve teaching session is recorded.

• Contact Data includes billing address, delivery address, postal address, email address and telephone numbers.

• Employment Data (this is relevant where your place on a course is arranged or paid for by your employer/future employer) includes name of employer, job 9tle, work contact details (email address, telephone number and postal address), any employee number (or other employment iden9fier) and employment start and end dates.

• Financial Data includes bank account, billing informa9on and payment card details.

• Iden1ty Data includes first name, maiden name, last name, BPP reference number, usernames for BPP sites (including for BPP e-commerce sites, BPP’s Virtual Learning Environment, or other online learning environments (including Adobe Connect or MicrosoJ Teams)) or similar iden9fiers (including any student registra9on number assigned to you by an external body who shares informa9on with us), marital status, 9tle, date of birth and gender.

• Marke1ng and Communica1ons Data includes your preferences in receiving marke9ng from us and your communica9on preferences.

• Profile Data includes your usernames and passwords (for BPP plarorms), purchases or orders made by you, your interests, preferences, feedback, survey responses and enquiries submi8ed to BPP.

• Recruitment Data includes any informa9on you have provided to us (or through a third party such as Job Train or LinkedIn) in your curriculum vitae, any covering le8er, any applica9on form (including name, 9tle, address, telephone number, personal email address, date of birth, gender, employment history, qualifica9ons and reasons for wan9ng to apply for the relevant posi9on) and any informa9on you provide to us during an interview.

• Student Data includes the course you are studying with BPP, your dates of study, records of achievements on the course, a8endance and progress informa9on, coursework or other assessment materials, feedback from BPP staff (including references), emails sent by you to BPP, messages posted on BPP’s VLE or any other online learning environment (including Adobe Connect or MicrosoJ Teams), informa9on rela9ng to your involvement in BPP’s alumni network, informa9on rela9ng to your registra9on for or a8endance at any BPP hosted/adver9sed events, and any complaints made by you or about you to BPP.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, 9me zone setng and loca9on, browser plug-in types and versions, opera9ng system and plarorm and other technology on the devices you use to access this website.

• Transac1on Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Usage Data includes informa9on about your visit to a BPP website, including the Uniform Resource Locators (URL) clickstream to, through and from the websites (including date and 9me), products and/or services you viewed or searched for, page response 9mes, download errors, lengths of visits to certain pages, page interac9on informa9on (such as scrolling, clicks and mouseovers) and methods used to browse away from the page and any phone number used to call our customer services numbers.

We also collect, use and share Aggregated Data such as sta9s9cal or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your iden9ty. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly iden9fy you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Sensi1ve Personal Data

The law requires that “sensi9ve” personal informa9on requires a higher levels of protec9on than other personal data.

In some circumstances we may also collect, store and use the following “sensi9ve” personal data:

• Informa1on about any disabili1es or learning needs – this informa9on is collected so that any reasonable adjustments can be made to accommodate individuals with disabili9es (for example large print learning materials or to allow for accessibility in BPP premises) and also to ensure that any learning needs are supported. This informa9on is voluntary.

• Informa1on about your race, ethnicity or religion – this informa9on is collected for equality and diversity monitoring purposes. This informa9on is voluntary.

• Medical informa1on – this informa9on may be collected where a medical issue is having an impact on your ability to a8end a BPP course. It may also include dietary requirements where you are a8ending a catered BPP event (this informa9on may be provided to BPP via third par9es such as Eventbrite). This informa9on is voluntary.

4. How your personal data is collected

We use different methods to collect data from and about you including through:

• Direct interac1ons. You may give us your Iden9ty, Contact, Employment, Financial and Marke9ng and Communica9ons Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

a. apply for a course;

b. submit an online query or request a call back;

c. purchase goods or Services from us;

d. speak with one of our client or supplier services teams;

e. speak with BPP teaching staff;

f. create an account on our website;

g. subscribe to a service or publica9on;

h. subscribe, register, take part in or view any BPP webinar;

i. request marke9ng to be sent to you;

j. enter a compe99on, promo9on or complete a survey; or

k. give us feedback.

• Through your course. You may give us your Student Data throughout your 9me on a course. This includes personal data you provide when you:

a. a8end learning sessions (whether online or face to face);

b. take any forms of assessment; or

c. raise any issues or ques9ons with BPP teaching staff.

• Automated technologies or interac1ons. As you interact with our website, we may automa9cally collect Technical Data about your equipment, browsing ac9ons and pa8erns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

• Third par1es. We may receive personal data about you from various third par9es as set out below:

• Contact, Employment and Iden9fy Data from your employer where your employer/future employer is sponsoring your place on a BPP course ∆;

• Contact, Iden9ty and Marke9ng Data from third party recruiters or event/seminar/symposium hosts (including LinkedIn and Eventbrite) ∆;

• Iden9ty, Contact, Transac9onal and Student Data from any external awarding bodies or professional membership bodies which you may be registered with in order to enrol onto or complete the course with BPP (including ACCA, CIMA etc.) ∆;

• Iden9ty and Student Data from any third party assessment centre or external marker or invigilator ∆;

• Student Data from any freelance tutor or external presenter engaged by BPP who has delivered teaching to you as part of your course. This includes any third party soJware (including Gmetrix and Pluralsight) for online learning ∆;

• Contact and Iden9ty Data from overseas agents, engaged by BPP who assist interna9onal students in submitng applica9ons for courses or programmes to BPP ∆;

• Iden9ty and Student Data from any third party assessment portal provider ∆;

• Iden9ty, Contact and Student Data from any third party survey organisa9on or portal provider, such as SurveyMonkey, Evasys, Qualtrics, Administrate and Eventbrite ∆;

• Technical Data from analy9cs providers such as Google, Sessioncam, Hotjar and Op9mizely; adver9sing networks; and search informa9on providers; and

• Contact, Financial and Transac9on Data from providers of technical and payment services such as SmartDebit, Worldpay, Sage Pay and CourseMerchant,∆.

5. 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 the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legi9mate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obliga9on.

• Where we have your consent.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Where we are relying on your consent as a legal basis for processing your personal data, for example where we collect voluntary “sensi9ve” personal data (as set out in this Policy above) you may withdraw your consent to this processing at any 9me by contac9ng us.

Purposes for which we will use your personal data

We have set out below, in a table format, a descrip9on of all the ways we plan to use your personal data, and which legal basis we rely on to do so. We have also iden9fied what our legi9mate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Please be aware that, if you are studying with BPP, in some cases we will have a contract in place with you in respect of the course you are undertaking. Therefore, our lawful basis for processing your personal data will be to perform our contract with you.

However, in some instances we will have a contract in place with your employer or prospec9ve employer. For example, some businesses will ask BPP to deliver a bespoke course or programme to a group of its employees. In these cases, BPP has a contract in place with your employer and not you as an individual. In these scenarios, BPP will process your personal data as necessary for our legi9mate interests, i.e. the delivering of services to your employer under a contract in place between BPP and your employer.

Purpose/Ac1vity Type of dataLawful basis for processing including basis of legi1mate interest

Students or prospec1ve students

To respond to enquiries or requests for informa9on

a. Iden9ty b.Contact

• Performance of a contract with you; or • Consent

To register you onto your chosen course

a. Contact b.Employment* (if sponsored by

an employer) c. Iden9ty

• Performance of a contract with you; or • *Necessary for our legi9mate interests (to

deliver services to your employer under a contract in place between BPP and your employer)

• Consent

To deliver the course to you (including the delivery of events)

a. Audio/Visual b.Contact c. Iden9ty d.Profile e.Student

• Performance of a contract with you; or • *Necessary for our legi9mate interests (to

deliver services to your employer under a contract in place between BPP and your employer)

• Consent

To: • Manage payments, fees and charges • Collect and recover money owed to us • Keep records for audit/accoun9ng purposes • Defend any legal claims brought against BPP

a. Iden9ty b.Contact c. Financial d.Transac9on e.Student

• Performance of a contract with you • Necessary for our legi9mate interests (to

recover debts due to us or defend legal claims)

• Necessary to comply with a legal obliga9on

• Consent

To par9cipate in surveys or similar research and analysis exercises

a. Iden9ty b.Student

• Necessary for our legi9mate interests (to study how students use our services, to develop them, to grow our business and to inform our strategy)

• Consent

Customers (or prospec1ve customers) of learning materials

To register you as a new customer when purchasing learning materials from BPP

a. Iden9ty b.Contact

• Performance of a contract with you • Consent

To process and deliver your order including: • Manage payments, fees and charges • Collect and recover money owed to us • Keep records for audit/accoun9ng purposes • Defend any legal claims brought against BPP

a. Iden9ty b.Contact c. Financial d.Transac9on e.Marke9ng & Communica9ons

• Performance of a contract with you • Necessary for our legi9mate interests (to

recover debts due to us or defend legal claims)

• Necessary to comply with a legal obliga9on

Clients of BPP (including employer clients)

To register you as a client of BPPa. Iden9ty b.Contact

• Performance of a contract with you Consent

To process and deliver the service: • Manage payments, fees and charges • Collect and recover money owed to us • Keep records for audit/accoun9ng purposes • Defend any legal claims brought against BPP

a. Iden9ty b.Contact c. Financial d.Transac9on e.Marke9ng & Communica9ons

• Performance of a contract with you • Necessary for our legi9mate interests (to

recover debts due to us or defend legal claims)

• Necessary to comply with a legal obliga9on

Suppliers to BPP

To register you as a supplier of BPPa. Iden9ty b.Contact

• Performance of a contract with you • Consent

To process and receive goods/services: • Manage payments, fees and charges • Keep records for audit/accoun9ng purposes • Defend any legal claims brought against BPP

a. Iden9ty b.Contact c. Financial d.Transac9on e.Marke9ng & Communica9ons

• Performance of a contract with you • Necessary for our legi9mate interests (to

recover debts due to us or defend legal claims)

• Necessary to comply with a legal obliga9on

For All

To manage our rela9onship with you which will include: • No9fying you about changes to our terms

or privacy policy • Asking you to provide feedback or take a

survey

a. Iden9ty b.Contact c. Profile d.Marke9ng & Communica9ons

• Performance of a contract with you • Necessary to comply with a legal obliga9on • Necessary for our legi9mate interests (to

keep our records updated and to study how customers use our products/services)

Purpose/Ac1vity Type of dataLawful basis for processing including basis of legi1mate interest

For All

To enable you to partake in a prize draw, compe99on or complete a survey

a. Iden9ty b.Contact c. Profile d.Usage e.Marke9ng & Communica9ons

• Consent • Necessary for our legi9mate interests (to

study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshoo9ng, data analysis, tes9ng, system maintenance, support, repor9ng and hos9ng of data)

a. Iden9ty b.Contact c. Technical

• Necessary for our legi9mate interests (for running our business, provision of administra9on and IT services, network security, to prevent fraud and in the context of a business reorganisa9on or group restructuring exercise)

• Necessary to comply with a legal obliga9on

How we use sensi1ve personal informa1on

“Sensi9ve” personal informa9on requires higher levels of protec9on. We need to have further jus9fica9on for collec9ng, storing and using this type of personal informa9on. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process sensi9ve personal informa9on in the following circumstances:

Less commonly, we may also process this type of informa9on where it is needed in rela9on 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 (for example if you suffer a medical problem whilst on BPP’s premises).

Consent

In some circumstances (as set out above), we ask you for your wri8en consent to allow us to process certain par9cularly sensi9ve data. When we do, we will provide you with full details of the informa9on that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

To deliver relevant website content and adver9sements to you and measure or understand the effec9veness of the adver9sing we serve to you

a. Iden9ty b.Contact c. Profile d.Usage e.Marke9ng & Communica9ons f. Technical

Necessary for our legi9mate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marke9ng strategy)

To use data analy9cs to improve our Website, products/services, marke9ng, student/ customer/client rela9onships and experiences

a. Technical b.Usage

Necessary for our legi9mate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marke9ng strategy)

To make sugges9ons and recommenda9ons to you about goods, services or events that may be of interest to you

a. Iden9ty b.Contact c. Technical d.Usage e.Profile

Necessary for our legi9mate interests (to develop our products/services and grow our business)

Purpose/Ac1vity Type of data Lawful basis for processing

Students or prospec9ve students

To provide reasonable adjustments to students with disabili9es and to provide learning support to students who have learning needs

Data rela9ng to disabili9es and/or learning needs

• Your explicit consent (this informa9on is voluntary)

Confirm any dietary requirements for BPP catered events

Medical data • Your explicit consent (this informa9on is voluntary)

To carry out equal opportuni9es monitoring and repor9ng

Data rela9ng to race, ethnic origin and religion

• Your explicit consent (this informa9on is voluntary)

You should be aware that it is not a condi9on of your contract/right to study with us that you agree to any request for consent from us. However, we may not be able to provide you with certain services (such as learning support) if you do not agree to provide such data to us.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal informa9on to make a decision without human interven9on. We are allowed to use automated decision-making in the following circumstances:

• Where we have no9fied you of the decision and given you 21 days to request a reconsidera9on.

• 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 wri8en consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any par9cularly sensi9ve personal informa9on, we must have either your explicit wri8en consent or it must be jus9fied in the public interest, and we must also put in place appropriate measures to safeguard your rights. 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 no9fied you.

We do use automated technologies and decision making when deciding what marke9ng messages you receive. However, we do not envisage that any other decisions will be taken about you using automated means, however we will no9fy you in wri9ng if this posi9on changes.

Marke1ng

We strive to provide you with choices regarding certain personal data uses, par9cularly around marke9ng and adver9sing. We have established a preference centre where you can view and make certain decisions about your personal data use. If you agree to receive marke9ng from us, you will receive a link to the preference centre by email.

The preference centre is not available for some courses and in respect of some client bookings and customer purchases. Where the preference centre is not available you will not receive a link to the preference centre. Instead your marke9ng opt-in preferences will be collected when you register, book a course or make a purchase. You can opt out of receiving marke9ng at any 9me by replying to the sender of the marke9ng communica9on with the word “UNSUBSCRIBE”.

If you do not agree to receive marke9ng from us, but change your mind at a later date, you can contact us and update your marke9ng preferences.

Please note that some marke9ng ac9vity is carried out centrally by BPP (predominantly in the UK) so your personal data may be passed to companies within the BPP Professional Educa9on Group (UK) and within the BPP Professional Educa9on Group (Interna9onal) in order for you to receive marke9ng from us.

Promo1onal offers from us

We may use your Iden9ty, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marke9ng). You will receive marke9ng communica9ons from us if you have requested informa9on from us or purchased goods or Services from us or if you provided us with your details when you entered a compe99on or registered for a promo9on and, in each case, you have not opted out of receiving that marke9ng.

Third-party marke1ng

We will get your express opt-in consent before we share your personal data with any company outside the BPP group of companies for marke9ng purposes.

As set out above, your personal data may be may be passed to companies within the BPP Professional Educa9on Group (UK) and within the BPP Professional Educa9on Group (Interna9onal) in order for BPP to provide marke9ng to you.

Op1ng out

You can ask us to stop sending you marke9ng messages at any 9me by logging into the preference centre and checking or unchecking relevant boxes to adjust your marke9ng preferences or by following the opt-out links on any marke9ng message sent to

you. Where you opt out of receiving these marke9ng messages, this will not apply to personal data provided to us as a result of you entering into a contract with us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not func9on properly. For more informa9on about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data 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 compa9ble with the original purpose. If you wish to get an explana9on as to how the processing for the new purpose is compa9ble with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will no9fy you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permi8ed by law.

6. Disclosures of your personal data

We may have to share your personal data with the par9es set out below for the purposes set out in the table in paragraph 5 above.

• Internal Third Par9es as set out in the Glossary.

• External Third Par9es as set out in the Glossary.

• Specific third par9es marked with ∆ listed in paragraph 4 above (under the ‘Third par9es’ heading).

• Specific third par9es listed in paragraphs 7, 8 and 9 below.

• External venues where some element of a course (or event) is delivered (BPP may share Iden9ty Data with the venue for registra9on and health and safety purposes).

• Future employers or educa9on providers where you specifically request that we provide confirma9on of Iden9ty or Student Data to those par9es for reference purposes.

• Third par9es to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alterna9vely, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third par9es to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instruc9ons.

7. Compliance with the Bribery Act and relevant legisla9on

In this Privacy Policy, we have explained that your personal data may be used for the purpose of ensuring compliance with legal obliga9ons and that it may be disclosed to BPP’s group companies’ service providers. This includes for the purpose of enabling BPP’s group companies to comply with the US Foreign and Corrupt Prac9ces Act 1977 (“FCPA”) and enabling BPP to comply with any other local laws or regula9ons rela9ng to similar purposes which relate to fraudulent, illegal or unethical behaviour (the “Conduct Legisla1on”).

BPP’s group companies may appoint one or more service providers to assist them in managing a whistleblowing helpline and a webpage which acts as a repor9ng mechanism (“Helpline”) to ensure compliance with Conduct Legisla9on.

It is possible that a BPP staff member or student may report ma8ers of concern through the Helpline and that your personal data may be used by BPP’s group companies, its service provider(s) which manage the Helpline and by BPP for the purpose of inves9ga9ng any such report and taking remedial ac9on thereaJer. For example, if a BPP employee suspects that another employee is misusing company records for his own purposes or is commitng fraud involving your personal data, they may report this through the Helpline.

Should this happen, your personal data will only be used for the purpose of ensuring compliance by BPP’s group companies with the relevant laws and regula9ons. Wherever reasonably possible, your personal data will be anonymised prior to use for the purpose of inves9ga9ons and remedial ac9on so that it does not relate to you. However, in some specific circumstances this may not be possible as it may prohibit a full inves9ga9on and prevent compliance with a relevant regula9on or Conduct Legisla9on. Any transfers to BPP’s group companies and their service provider(s) which manage the Helpline and which may also be in the US or elsewhere in the world will be carried out in accordance with the law.

A limited number of specially trained employees from BPP’s group companies will only have access to your personal data which is disclosed through the Helpline where and to the extent that this is necessary for the purposes of carrying out their roles and for the purpose of compliance. In any event, their access will be limited, secure, controlled and jus9fied as BPP considers is fair and necessary in the circumstances. These employees will be subject to appropriate confiden9ality obliga9ons.

We encourage our employees to use the Helpline in good faith and only for serious or substan9al issues which cannot properly be reported via other means.

Provided reports are made through the Helpline in good faith, we try to protect the confiden9ality of your iden9ty as far as is reasonably possible. However, we cannot guarantee this (especially in subsequent court or tribunal proceedings) and we are required to inform the subject of the reports about the allega9on(s). Those subjects have the right to request their own personal data, as do you, as set out under Your Legal Rights.

8. VLE

BPP offers a Virtual Learning Environment (“VLE”) to students and to selected sponsoring employers. The VLE is also accessed by BPP staff in order to deliver courses and programmes to students. Within the VLE the following data sharing is in opera9on: • Your name, last log-in date, campus loca9on and course or programme may be shared with other users of the VLE;

• The above details will be searchable to other VLE users, and you can be messaged through the VLE by other users based on your VLE user name;

• You may also elect to share your photo, a short biography and personal email address with other VLE users (this is voluntary);

• Your par9cipa9on in online sessions (such as webinars or chatrooms), including your text, audio or video content may be recorded and shared with other VLE users;

• Third Par9es chosen by BPP may review your interac9on with the VLE to help BPP con9nuously improve the service.

• Exam or assessment results (including mocks) in the VLE may also be combined to derive benchmarks of performance to allow students to assess their performance in their chosen programme. These will only be presented in aggregate and individual results will not be disclosed.

• Any assignment or assessment uploaded or completed through the VLE will be shared with the appropriate BPP staff for the purposes of assessment. Assignments/assessments may be sent to third par9es for the purpose of ensuring the work is original, a8ributes sources correctly and does not infringe on any exis9ng copyright (see references to Turni9n in paragraph 6 above).

• VLE data relevant to assessing your progress within the course or programme may also be shared with your sponsoring employer.

9. Interna9onal transfers

Some ac9vi9es (including marke9ng, HR/people management, IT services, teaching) are carried out centrally by BPP by staff located outside of your local country (most usually based in the UK or Singapore). Therefore, as set out in this Policy, we may share your personal data within the BPP Professional Educa9on Group (Interna9onal) and BPP Professional Educa9on Group (UK) which includes companies based in the UK and Channel Islands and BPP’s ul9mate parent company based in the USA. The websites and/or any products and/or Services may be hosted on servers located outside of your local country and maintenance and support services for the websites and/or those products and/or Services may be provided from outside of your local country. This means that your personal data may be transferred to, stored and processed in other countries apart from your local country.

Whenever we transfer your personal data out of your local country, we ensure a similar degree of protec9on is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where we use certain service providers, we may use specific contracts which give personal data the same protec9on it has in your local country.

• Where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protec9on to personal data.

Please contact us if you want further informa9on on the specific mechanism used by us when transferring your personal data out of your local country.

10. Data Security

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 addi9on, we limit access to your personal data to those employees, agents, contractors and other third par9es who have a business need to know. They will only process your personal data on our instruc9ons and they are subject to a duty of confiden9ality.

We have put in place procedures to deal with any suspected personal data breach and will no9fy you and any applicable regulator of a breach where we are legally required to do so.

As set out in paragraph 9 above, your personal data may be held on the IT systems of BPP, BPP’s group companies (e.g. for the purpose of providing training or educa9onal services to you) and/or on the IT system of another third party company (within or outside of BPP) within or outside your local country which is providing IT hos9ng or other data processing services, in accordance with BPP’s arrangement in place with that company.

All informa9on that you provide to us is stored on secure servers. Any payment transac9ons will be encrypted using SSL technology.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the websites, you are responsible for keeping this password confiden9al. We ask you not to share a password with anyone.

11. Data reten9on

How long will you use my personal data for?

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 sa9sfying any legal, accoun9ng, or repor9ng requirements.

To determine the appropriate reten9on period for personal data, we consider the amount, nature, and sensi9vity of the personal data, the poten9al 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.

Details of reten9on periods for different aspects of your personal data are available in our Reten9on Policy which you can request by contac9ng us.

As an educa9on provider BPP will hold details of your transcript (i.e. your name, years of study, course name, sponsoring employer, assessment) indefinitely.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or sta9s9cal purposes in which case we may use this informa9on indefinitely without further no9ce to you.

12. Your legal rights

Under certain circumstances, you have rights under data protec9on laws in rela9on to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.

• Request correc9on of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restric9on of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

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 is clearly unfounded, repe99ve or excessive. Alterna9vely, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific informa9on from you to help us confirm your iden9ty and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further informa9on in rela9on to your request to speed up our response.

Time limit to respond

We try to respond to all legi9mate requests within one month (or 21 days where you are based in Malaysia). Occasionally it may take us longer than this if your request is par9cularly complex or you have made a number of requests. In this case, we will no9fy you and keep you updated.

13. Glossary

Lawful basis

Legi1mate Interest means the interest of our business in conduc9ng and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any poten9al impact on you (both posi9ve and nega9ve) and your rights before we process your personal data for our legi9mate interests. We do not use your personal data for ac9vi9es where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permi8ed to by law). You can obtain further informa9on about how we assess our legi9mate interests against any poten9al impact on you in respect of specific ac9vi9es by contac9ng us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obliga1on means processing your personal data where it is necessary for compliance with a legal or regulatory obliga9on that we are subject to.

Third par1es

Internal Third Par1es

Other companies in the BPP Professional Educa9on Group (Interna9onal) and BPP Professional Educa9on Group (UK) ac9ng as joint users or processors and who are based in the UK and the USA and provide IT and system administra9on services and undertake leadership repor9ng.

For details on how BPP’s parent company (based in the USA) use personal data, please see their privacy policy here.

For details on how BPP Professional Educa9on Group (UK) use personal data, please see their privacy policy here.

External Third Par1es

• Your employer, ac9ng as an independent user, where your employer/prospec9ve employer is sponsoring your place on a course (or where your employer/prospec9ve employer has arranged for a course to be delivered to a group of its employees/prospec9ve employees). We will share informa9on rela9ng to your a8endance, performance (including assessment) and general behaviour on the course.

• Service providers ac9ng as processors based outside your local country who provide IT and system administra9on services (including Endava).

• Service providers which act as processors in respect of our telephone call recording opera9ons (NewVoiceMedia).

• Service providers which act as processors who provide learning resources or other elements of the courses.

• Professional advisers ac9ng as processors including lawyers, bankers, auditors and insurers (including outside of your local country) who provide consultancy, banking, legal, insurance and accoun9ng services.

• Any tax authori9es, other regulators and other authori9es ac9ng as independent users based in and outside of your local country who require repor9ng of processing ac9vi9es in certain circumstances.

• Specific regulators in the field of educa9on, ac9ng as independent users based in and outside of your local country who require repor9ng of processing ac9vi9es in certain circumstances.

• Any professional body where this is relevant to the course you have studied.

• The police or governmental body, where the police/ governmental body make a request for personal informa9on to BPP or as and when we consider necessary for the purpose of crime / fraud preven9on.

• Any health service if there is any immediate concern regarding your physical health whilst a8ending BPP premises.

Your legal rights You have the right to:

Request access to your personal data. 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 correc1on of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please be aware that this right does not apply to exam scripts or exam marks.

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 con9nuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your informa9on unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be no9fied to you, if applicable, at the 9me of your request. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks.

Object to processing of your personal data where we are relying on a legi9mate interest (or those of a third party) and there is something about your par9cular situa9on which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marke9ng purposes. In some cases, we may demonstrate that we have compelling legi9mate grounds to process your informa9on which override your rights and freedoms. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks.

Request restric1on of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legi9mate grounds to use it. Please be aware that this right does not apply to exam scripts, recorded assessments or exam marks.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated informa9on which you ini9ally provided consent for us to use or where we used the informa9on to perform a contract with you.

Withdraw consent at any 9me where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the 9me you withdraw your consent.