Privacy notice: apprentices 2024/25

This privacy notice tells you what to expect us to do with your personal information when you enrol at the University of Central Lancashire and become an apprentice. Personal information (or personal data) is any information which relates to and identifies you. Data protection legislation (the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018) set out how we should handle your personal information.

The University of Central Lancashire Higher Education Corporation is the controller for the personal information we process, unless otherwise stated. We are registered with the Information Commissioner’s Office and our registration number is Z5512420.

There are many ways you can contact us, including by phone, email, social media and post. You can view our main contact details on our website.

If you are enrolled on the Police Constable Degree Apprenticeship programme, the University and your employer are jointly responsible for the delivery of your apprenticeship programme. For data protection purposes, the University and your employer are joint controllers of the personal data used to deliver your apprenticeship programme. This means that the University and your employer are equally responsible for complying with data protection legislation and for ensuring your information is handled correctly. The University and your employer collect and use your information for a common purpose to achieve the same outcomes. You can contact the University or your employer if you have any questions about the way your information is used; however the University, as the awarding body, is the main contact for any queries about how your information is handled.

The University's Information Governance Manager and Data Protection Officer can be contacted on DPFOIA@uclan.ac.uk. Further information and contact details can be found on the data protection pages of our website.

If you are enrolled on the Police Constable Degree Apprenticeship programme, you can find the details of your employer’s Data Protection Officer on your employer’s website by searching for ‘data protection’.

The University uses information you and your employer provided on your application form, as well as any supporting documents, references or records from interviews obtained as part of the admissions process. We also collect and use information you provide during enrolment, including information about any disabilities or long-term health conditions you inform us about. As you progress through your course, we will collect and use a variety of other information to assist you with your studies, maintain records about your studies and academic achievements, finance arrangements and about your use of the academic and non-academic facilities and services that we offer, and manage the operation of our regulations, policies and procedures. Most of this information is usually collected from you directly during your time at the University.

If you are enrolled on the Police Constable Degree Apprenticeship programme, the University and your employer are jointly responsible for the delivery of your apprenticeship programme. Your employer may use the information we collect in the same way as outlined above, for the purposes of jointly delivering your course.

Once you enrol, we use information about you for a variety of purposes. The main purposes are set out below. Depending on the nature of your course or use of University facilities, there may be additional reasons why we use your information which are specific to your course, school or service we offer. You will be informed about these locally as appropriate.

If you are enrolled on the Police Constable Degree Apprenticeship programme, your employer will also use your personal data for the purposes set out below when they are jointly delivering your programme with the University.

For the administration of your studies

We use your information to deliver and administer all aspects of your education (including any placements with external providers), including for identity verification and visa/immigration checks; teaching, assessment and quality assurance purposes; considering and approving academic progression and managing academic appeals; managing resits; considering any applications for mitigating circumstances; and determining and confirming awards. Where relevant, we monitor, evaluate and support your research activity. We also maintain records of your studies and academic achievements. We cannot deliver your apprenticeship contract without using your information in these ways.

To provide an enhanced student experience, we use software to analyse the information we hold about you within a number of different systems to create a profile of your engagement and academic achievements throughout your course. This profile helps us to identify if you may benefit from additional support. In any such instances, staff supporting your studies will contact you to discuss any additional support we can offer.

Financial administration

We will use your information, as provided by you or your employer, to administer all financial aspects of your relationship with us. This includes managing and collecting payments for course fees from your employer and the ESFA (Education and Skills Funding Agency), and payments for car parking, fines, bursaries and other support allowances. We will also use your information for debt recovery purposes in the event money is owed to the University and may use external debt collection agencies for this purpose.

Operation of the University’s regulations, procedures and codes of practice

We will use information about you to investigate complaints or allegations involving you or another apprentice or student, member of staff or external party under any of the University’s rules, regulations, procedures or codes of practice. This includes personal data held within emails, Teams chat messages, meeting or lecture recordings, CCTV and body worn video camera footage and any other format. We may also use information about you that is publicly available, such as information posted to social media and other public forums, where this is relevant in a particular case e.g. complaints about inappropriate posts on social media. Information will be used to investigate complaints or allegations, manage the outcomes and put in place any remedies, including additional support or disciplinary measures. This includes investigating cases where academic misconduct is suspected (which includes suspected plagiarism, cheating or collusion), support to study and fitness to practise cases (where this is relevant to your course). The investigations mentioned here may also involve using information about any criminal convictions you receive during the time you are enrolled, in order to determine whether or not you are able to continue on your course (for example, where a particular type of conviction may prevent you from undertaking mandatory placements) or to determine any steps that should be taken in the context of helping to provide a safe community in which staff and students can teach and learn, and in which we can safeguard children (those under 18 years old) and adults at risk. We will exchange information with the police and probation service as part of these investigations, where relevant and appropriate. We will also share information with regulators and professional bodies to comply with regulatory requirements which require us or another party to establish if you have been involved in dishonesty, malpractice or other seriously improper conduct; or to carry out protective functions to protect members of the public against dishonesty, malpractice or other seriously improper conduct, or unfitness or incompetence.

We will use your information for academic integrity purposes and to manage our academic misconduct procedures. You will be required to submit some of your assessed work via Turnitin, which is a similarity detection tool. Turnitin will generate a score to suggest what percentage of your work is similar to existing content stored in its databases. It compares your work against publicly-available sources and work submitted by other students. Turnitin reports are always assessed by a member of staff before a decision about academic misconduct is made and you have the right to submit an appeal in relation to any decision relating to a particular piece of work.

We will also use information about you to monitor your attendance and engagement at physical and online teaching sessions for the purposes of complying with the University’s Academic Regulations, ESFA rules and, where relevant, the requirements of your visa. Information is generated from systems you use to scan in at face-to-face teaching sessions, and systems such as Microsoft Teams which are used to deliver online teaching sessions. We may also use Microsoft apps such as Insights, which allows your lecturer to see your learning activity within a specific Teams space.

Security and crime prevention

The University operates a CCTV system for security and crime prevention purposes, among other things, which includes the use of body worn video devices. The CCTV system covers University buildings (inside and outside) and public areas across our campuses. Your images are likely to be captured by the CCTV system while you are on, in, or near University premises. CCTV footage will be used to maintain the security of the University community, enhance public safety, prevent and detect crime and apprehend and prosecute offenders. CCTV footage will be used, where there is a lawful basis, in the investigation of complaints and allegations made under the University’s rules, regulations, procedures and codes of practice. Further information is available in our CCTV Privacy Notice.

The University will also use your information to carry out welfare checks, maintain a safe environment around the University campus and University accommodation and investigate complaints or concerns regarding safety or security. We will produce internal reports about safety and security incidents and share them within the University on a need-to-know basis to help manage and ensure the safety, security and wellbeing of the University community.

We make available the SafeZone app to all apprentices and, if you choose to use the app, will use information (including location data) collected via your use of the app to help ensure the safety of you and others on and around campus (or anywhere else in the world, if you use the app elsewhere), and manage and monitor check-ins and alerts. We will also use SafeZone to send emergency text alerts (and push notifications, if you have downloaded the app) in the event of a serious incident, campus closure, significant IT issue, etc. that we need to notify lots of students about at the same time. The University is also part of the SafeZone Alliance, which you can opt in to via the app. If you travel to another university that is also part of the Alliance, you can choose, via the app, to raise emergency/first aid alerts while you are in that university’s Alliance region. The host university will be able to access information about you only if you raise an alert while you are on its campus, and only if you have opted in to the Alliance. The SafeZone app is provided on our behalf by CriticalArc, a third party under contract to the University.

All University buildings have security access controls and require you to scan your student card to enter and exit. The door entry system collects information each time your card is used to show the date and time you enter and leave a particular building. This information is used to ensure that only authorised individuals can access our buildings; it is also used to check building occupancy for safety and security purposes, and for research purposes to establish patterns of use of buildings and services across our estate.

Delivery of facilities and services

We will use your information to provide you with services and facilities such as the library, accommodation, parking permits, sports centre, clubs and societies (via the Students’ Union) and a careers service. All apprentices and graduates are automatically eligible to receive ongoing support from the Careers Service. The Careers Service uses your information to provide specialist careers advice, mentoring, help with CV preparation and advertising and informing you of job vacancies. Further information is available in the Careers Service Privacy Notice.

We will also use your information to provide you with an IT service. This involves using your information to help keep our IT network and systems secure, robust and fit for purpose, including system testing and the requirement to use multi-factor authentication to access our IT services.

Provision of a student wellbeing service

The University offers a variety of support to apprentices via its Student Services team. Student Services uses your information to provide wellbeing support, including counselling and mental health support. It also provides an inclusive support service. If you declare a disability during the enrolment process or at any other time, the information will be passed to the Inclusive Support Team which will contact you to discuss your support needs and any reasonable adjustments which may need to be put in place. The team will discuss with you how we might need to share your information to put reasonable adjustments in place and you will be given the option to say that you want information about your disability to remain confidential. If you are referred for Functional Skills assessments and training and require reasonable adjustments to be put in place, we will need to disclose information about your disability to Training 2000 Limited (T2000), which delivers Functional Skills on our behalf under contract. T2000 is a company wholly owned by the University. Your course team will discuss this with you if it applies to you.

You can find out more about how Student Services uses your information by reading the Student Support, Wellbeing and Inclusive Support privacy notice, available on the Student Hub.

Communicating with you

We will use your information to communicate effectively with you via email, OneFile, post, telephone, text (SMS), social media or other methods, as appropriate. We will send you messages about a variety of things such as the administration of your course, timetable changes and events and activities happening at the University. We will also keep you informed of important updates using newsletters, circulars or other methods. We may also send you messages about University services and facilities. You can opt out of receiving communications which are considered to be marketing by contacting the Academic Registry: RDMT@uclan.ac.uk. Only some of the communications we send are marketing so you cannot opt out of everything we send to you.

Research, reporting and statistics

We will use and analyse your information to obtain and act upon your feedback during your time as an apprentice (such as via our Unitu platform, for which all apprentices are given an account upon enrolment), to compile statistics and to undertake surveys and market research to help with corporate planning, reporting and University administration. We will use external agencies to carry out market research on our behalf. We will also use your information to participate in surveys run by external agencies, such as the National Student Survey (NSS) and Graduate Outcomes. Participation in these surveys will involve us sharing your information with those running the surveys.

We will also use your information for statutory reporting purposes to external agencies, where required, such as the information we disclose about all students to the Higher Education Statistics Agency (HESA), which is part of JISC, as well as for purposes associated with our ongoing registration with the Office for Students. We also collect information about you to populate the Individualised Learner Record (ILR) on behalf of the ESFA and Department for Education (DfE). Information within the ILR is given to the ESFA, which gives it to the DfE so it can be used to help to ensure that public money distributed through the ESFA is being spent in line with government targets. It is also used for education, training, employment and wellbeing purposes, including research. Further information about how the ESFA and DfE will process your personal data can be found in the ESFA privacy notice.

Your information will also be used for research purposes, including research by University staff for planning and development purposes, and University researchers for the purposes of academic research. We may also use your information to participate in research carried out by third parties including those unrelated to the University, such as research that would benefit current and future students of the University or the student population generally, or research that would help formulate government policy. Your information will only be used in this way where the law allows us to and we consider it appropriate under the circumstances.

Monitoring and compliance

We will use your information to ensure and monitor our compliance with legislation including laws relating to equality, health and safety and immigration. We will also use your information to monitor our compliance with regulatory and contractual requirements set by external agencies such as the ESFA. This includes using information stored in OneFile (such as your learning journals and timesheets) to monitor compliance with the ESFA’s ‘off-the-job training’ requirements.

Providing an alumni service

When you complete and pass your course, you automatically become a member of the University of Central Lancashire Alumni Network and will be provided with information about its services. We will use information about you from your student record to populate our alumni system and offer you an alumni service, which includes keeping you informed of University news, publications and events, career opportunities, academic and professional development opportunities and much more. Further information is available in the Alumni Privacy Notice. You can opt out of receiving communications from the alumni service at any time by contacting the Alumni team.

 The University relies on the lawful bases from the UK GDPR set out below to process information about you for the purposes set out in this notice. If you are enrolled on the Police Constable Degree Apprenticeship programme, your employer also relies on these lawful bases when using your personal data to jointly deliver your course; in this case, references to the University will also apply to your employer.

Article 6(1)(b), which allows us to process personal data when it is necessary for the performance of a contract. You enter into a contract with us when you accept an offer of a place (the student contract). Under your student contract, we deliver and administer your studies, administer finances, operate the University’s regulations, rules, procedures and codes of conduct, communicate with you and deliver facilities and services, among other things. We require you to provide any information we reasonably request for these purposes otherwise we cannot deliver your student contract.

Article 6(1)(c), which allows us to process personal data when it is necessary to comply with a legal obligation. We are legally required to provide some reports and statistics to external agencies, as well as monitoring compliance with laws relating to immigration (e.g. visas) and equality, among other things.

Article 6(1)(e), which allows us to process personal data where it is necessary to perform a task in the public interest. Research and teaching; some monitoring and internal reporting, including obtaining and acting on student feedback; auditing; and the provision of student support is carried out as part of our public tasks. We may also rely on this lawful basis to process personal data where it is necessary for the public tasks of other organisations, such as when we disclose information to HESA (see ‘Who will my personal information be shared with?’ for further information) or when we disclose information to third parties for surveys and research purposes which are not directly related to the University.

Article 6(1)(f), which allows us to process personal data where it is in our, or someone else’s, legitimate interests to do so and it does not unduly prejudice your rights and freedoms. We rely on this condition to, among other things:

• communicate marketing messages to you (unless you opt out). It is in the University’s legitimate interests to promote its services, courses and events to those who may be interested.
• deliver some services and facilities to you such as IT services, the Careers Service and the Alumni Network. It is in the interests of you, our apprentice, to have access to careers advice to help you plan for your future and secure employment, and to be provided with other beneficial services as part of your University experience, to help you get the most out of your time at the University and beyond and achieve the best academic result you can.
• provide a security service and CCTV monitoring. It is in the interests of the University community and the general public to make the University a safe and secure place to live and study.
• produce some internal reports, research and statistics. It is in our legitimate interests to use these to evaluate, plan and assess how the University is operating and make any changes we think are appropriate and will benefit current and future students and apprentices.
• share information with third parties for your benefit, or where it is in their interests, for example to facilitate membership of Students’ Union clubs and societies, or where your employer is paying for your course and enquires about your attendance or attainment.

We also process some information only if you provide your consent. In this case, Article 6(1)(a) applies, and Article 9(2)(a) applies where the information is special category data (special category data is information about your race, ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data used for ID purposes, health, sex life or sexual orientation). It will be clear where we are relying on your consent to collect and use your information because consent will be requested at the time you provide the information. When you are asked for consent, we will explain why we are asking for the information and how we will use it if you choose to provide it. Consent can be withdrawn at any time and we will explain how you can do this in each individual case.

Where we process special category data and data about criminal convictions for the purposes set out in this notice, we rely on the following additional lawful bases from the UK GDPR and DPA:

Article 9(2)(g) UK GDPR, which allows us to process special category data if the processing is necessary in the substantial public interest and there is a basis to do so in law. The law which allows us to rely on Article 9(2)(g) is section 10 DPA by virtue of Schedule 1 DPA, which also provides the lawful basis for processing data about criminal convictions. The specific conditions from Schedule 1 DPA on which we rely for this type of processing are as follows:

• Schedule 1(6), which allows us to process special category data and/or data about criminal convictions to comply with a statutory or legal function. Such functions include the duties set out in the Equality Act 2010 and the requirement to comply with the registration conditions imposed on us by the Office for Students under the Higher Education and Research Act 2017.
• Schedule 1(8), which allows us to process special category data to monitor equality of opportunity or treatment.
• Schedule 1(10), which allows us to process special category data and/or data about criminal convictions to prevent or detect unlawful acts.
• Schedule 1(11), which allows us to process special category data and/or data about criminal convictions to carry out protective functions to protect members of the public against dishonesty, malpractice or other seriously improper conduct, or unfitness or incompetence.
• Schedule 1(12), which allows us to process special category data and/or data about criminal convictions to comply with regulatory requirements which require us or another party to establish if you have been involved in dishonesty, malpractice or other seriously improper conduct. We rely on this to undertake activities for regulated courses to enable us to meet the regulatory requirements and good practice principles associated with your course.
• Schedule 1(18), which allows us to process special category data and/or data about criminal convictions to safeguard individuals at risk and children.

When processing special category data or data about criminal convictions in reliance on the above conditions from Schedule 1 DPA the University must have an appropriate policy document, which can be read here: Data Protection: Processing special category data and criminal convictions data.

Article 9(2)(j) UK GDPR, which allows us to process special category data for archiving, scientific or historical research purposes or statistical purposes, where there is a basis to do so in law. The law which allows us to rely on this basis is section 10 DPA by virtue of Schedule 1(4) DPA. We may also rely on Schedule 1(4) DPA if we process personal data relating to criminal convictions for archiving, research or statistical purposes.

We share your information with a range of external organisations and bodies, some of which are processing personal data on our behalf. We only share your personal data with another person or organisation where the law allows us to and we consider it to be appropriate under the circumstances. The external parties we may share information with include the following:

• HESA (the Higher Education and Statistics Agency), which is now part of JISC. We share some apprentice data with HESA to help HESA carry out its statutory functions in the public interest. Every apprentice has a HESA record which contains various details about you including your ethnic group and any disabilities you have declared. For more information please see the HESA website.
• ESFA (the Education and Skills Funding Agency) and DfE (Department for Education). We are required to share some apprentice data with the ESFA to enable the DfE to perform its statutory functions. We also act as a processor for the ESFA and collect some information on its behalf to populate your Individualised Learner Record (ILR), which we then make available to the ESFA. Further information about how the ESFA and DfE will process your personal data can be found in the ESFA privacy notice.
• Office for Students (OfS) and Ofsted to enable these organisations to carry out their functions associated with checking the quality of apprenticeships. Ofsted is responsible for the inspection of apprenticeship provision at all levels; it inspects our apprenticeship provision and reports its judgements to the ESFA and the OfS. The OfS is responsible for the external quality assurance of our higher and degree apprenticeships where we deliver the end-point assessment ourselves, rather than using an independent end-point assessment organisation. The OfS or Ofsted may require us to share your personal data during their audits and checks on the quality of our apprenticeships so they can see how we are delivering our apprenticeships and assessments.
• Higher Education bodies such as Research England, UK Research and Innovation, Office of the Independent Adjudicator, and the organisation(s) running the National Student Survey and other student and leaver surveys.
• Public authorities, including the police, DWP and probation service for the prevention and detection of crime, apprehension and prosecution of offenders, safeguarding purposes, regulatory purposes, the collection of tax or duty and safeguarding national security, among other things.
• Government departments and public bodies such as UK Visas and Immigration, HM Revenue and Customs, and the Health and Safety Executive.
• Local authorities: we are legally required to share information about you so the Electoral Registration Officer can contact you about your right to register to vote. We also share information about your student status so that you can obtain a discount on your Council Tax. We do this because it is in your legitimate interests to be able to obtain the discount.
• UCLan Students’ Union (SU): you automatically become a member of the SU once you enrol at UCLan. We share some information with the SU for membership purposes to enable it to verify your eligibility to join clubs and societies and vote in elections, and to contact you with essential updates. You can opt out of this process by emailing the Academic Registrar: RDMT@uclan.ac.uk.
• Professional and regulatory bodies if this is relevant to your course. Information is shared for ‘fitness to practise’ purposes, to confirm your qualifications and for the accreditation of courses, as well as to comply with regulatory requirements which require us or another party to establish if you have been involved in dishonesty, malpractice or other seriously improper conduct; or to carry out protective functions to protect members of the public against dishonesty, malpractice or other seriously improper conduct, or unfitness or incompetence, among other things.
• Your employer: We will disclose information to your employer such as details of your attendance and academic progress. Your employer will have a OneFile account which will enable them to sign some of your assessments; sign reviews and your ILP; and report on and track your progress. We may also disclose outcomes of academic misconduct investigations and other information required for reporting against key performance indicators. This will be carried out in line with contractual arrangements and the commitment statement. If you are enrolled on the Police Constable Degree Apprenticeship programme, any sharing of personal data with your employer detailed in this section refers to information which is shared for purposes which are not related to the joint delivery of your apprenticeship programme.
• External End Point Assessing Organisations so that they can administer and undertake the end point assessment and report outcomes to the ESFA to claim your apprenticeship completion certificate.
• HEDD (Higher Education Degree Datacheck): We share information about your dates of study and the qualifications you gain here with HEDD. HEDD is a processor acting on our behalf. It holds information about apprentices and graduates so that employers and recruitment agencies can check the qualification details and dates of study you provide when applying for jobs. HEDD only discloses this information to employers if you provide consent in each case. You can find further information about HEDD on its website.
• Academic misconduct services: to identify potential instances of plagiarism and other types of academic misconduct, we share information with a service called Turnitin, which is based in the USA. We have a contract in place with Turnitin to ensure your information is protected.
• External debt collection agencies to recover unpaid debts owed to us.
• University insurers: information, including accident forms, is shared with our insurers to enable us to make insurance claims and to provide insurance cover for trips abroad.
• External examiners and assessors for assessment and examination purposes.
• Internal and external auditors to provide assurance that the University is following its risk management, governance and internal control processes and to independently inspect our financial statements and records.
• Third parties carrying out research or surveys where there is a lawful basis to share information and they are carrying out their statutory tasks in the public interest.

Companies or organisations acting on our behalf: We use processors who are third parties who provide elements of services for us. We have contracts in place with our processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will hold it securely and retain it for the

Occasionally we may need to send your personal information outside the UK and/or the European Economic Area (EEA) e.g. to obtain a service from a processor. These transfers are only carried out when there is a lawful basis for the processing. All transfers are carried out with appropriate safeguards in place to protect your information and ensure it remains secure, for example, on the basis of the UK International Data Transfer Agreement or UK International Data Transfer Addendum. A copy of these Agreements can be obtained from the University on request by contacting the Data Protection Officer in the first instance.

We will maintain your full apprentice record for six years following the date you complete and pass your course or the date you are withdrawn from your course. If you are studying on certain courses, we are legally required to keep your information for longer than this. You will be informed if you are on such a course.

Six years after you complete and pass your course, the majority of your information will be deleted but we will keep indefinitely information which is necessary to confirm that you studied here and the qualification and grade you obtained. If you are an active member of our Alumni Network, we will retain additional information.

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information. Further information about each of these rights can be found on the

Information Commissioner’s Office website. To make a request to exercise any of these rights, please contact the Information Governance Manager & Data Protection Officer on DPFOIA@uclan.ac.uk.

If you are enrolled on the Police Constable Degree Apprenticeship programme, the University and your employer are joint controllers in relation to personal data processed for the delivery of your course. You may exercise your rights by contacting the University or your employer; however you are encouraged to send any requests to the University using the contact details above.

Your right of access

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. For further information or to make a request, please see the data protection pages of our website.

Your right to rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing

You have the right to object to any processing we carry out, if we carry it out on the basis that it forms part of our public task or is in our legitimate interests. You also have the right to object to your personal information being used for direct marketing purposes.

Your right to data portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information because we have your consent or because it is necessary for your student contract, and the processing is automated.

We work to high standards when it comes to processing your personal information. If you have queries or concerns, please contact the relevant part of the University, or the Information Governance Manager & Data Protection Officer, and we will respond.

If you remain dissatisfied, you can make a complaint about the way we process your personal information to the Information Commissioner’s Office, which is the UK supervisory authority for data protection. Further information can be found on the data protection pages of our website.