Highbury College takes its obligations under the Data Protection Act very seriously and will always ensure personal data is collected, handled, stored and shared in a secure manner. To provide you with information about the processing of personal data the College has created privacy notices for you to clearly understand how the College uses and keeps secure and confidential personal information. It applies to personal data provided to us, both by you or by third parties. For example, we have created privacy notices for applicants to the College (that can be found in the “Apply Now” part of the website) for students enrolled at the College and for visitors to the College.

These privacy notices have been prepared in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act 2018.


About Us

As a further education college, Highbury College determines how and why your personal data is processed. In accordance with Data Protection Legislation, we are a Controller, and this means that we are legally responsible for the personal data we collect and hold about you.

One of our responsibilities is to tell you about the different ways in which we use your personal information, what information we collect (and our lawful basis for doing so), why we collect it, where we collect it from and whether (and with who) we will share it. We also need to tell you about your rights in relation to the information. This information is provided in our privacy notices.

Our Data Protection Officer is Zoe Martin. If you have any questions about this policy or the ways in which we use your personal information, please contact our Data Protection Officer at dpo@highbury.ac.uk or by phone on 02392 328829 or by post at Tudor Crescent, Portsmouth PO6 2SA.

If you are concerned about the way Highbury College is managing your personal information you have a right to complain to the Information Commissioner’s Office at www.ico.gov.uk/concerns.


Data Collected via our Application Form

Highbury College is the Data Controller of personal information about you. Our address is Highbury College, Tudor Crescent, Portsmouth PO6 2SA. Our Data Protection Officer is Zoe Martin whose contact details are at the bottom of this notice.

As a public body the personal information Highbury College (the data controller) collects is of public interest and is required in order for us to process your application. Where the information we collect is ‘special category’ personal information (e.g. medical) we will process it because there is a substantial public interest for us to do so. The information will be stored in a secure database and may be shared with Government bodies and educational establishments. Please note that if you are under 18, your information will also be shared with your parents, carers and/or next of kin. Your information will be kept for six years and then securely deleted.

During this time, you retain the following rights:

  • the right to access your personal information, using the College’s Subject Access Request process
  • the right to have inaccurate personal information changed
  • the right to restrict the processing of your personal information
  • the right to object to the processing of your personal information
  • The right to lodge a complaint with the Information Commissioner’s Office in relation to how Highbury College has processed your data. You can do this by visiting – https://ico.org.uk/make-a-complaint/

To update your information or if you have any questions about the above, please contact our data protection officer by email: dpo@highbury.ac.uk


Privacy Notice for Online Lesson/Lecture/Activities Recording

In line with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA) Highbury College is your data controller and we process your personal data as a student in compliance with the law. This privacy notice is to inform you how your personal data is used and protected by Highbury College.

Why are some teaching sessions and activities recorded?

Occasionally recordings will be used to improve quality and monitor the learners experience of online delivery methods. They will also be used allow absent learners to access the lesson and learners in attendance to revisit the content. Highbury College may record some or all of your online teaching session. These recordings will be stored on Microsoft Stream within the College’s Microsoft account. Depending on how the teaching session is delivered this may include the recording of audio or video of the tutors and / or learners.

How do I know if the teaching session is being recorded?

If you are being taught on campus and the teaching session is being recorded, you will be advised by your Tutor. If the lesson/lecture is happening online via Teams you will know if it is being recorded as a red circle and the red text ‘Recording’ will show on your computer screen.

Is the whole recording personal data?

No. Parts of that recording could count as personal data according to data protection laws. Personal data in recordings would include your name, images of you and any opinions you contribute and anything you say about yourself.

What is the lawful basis of processing personal data in the recorded lecture?

The lawful basis for processing this personal data is legitimate interests. This applies when the data processing is not required by law but is of a clear benefit to the organisation or the individual, there is limited privacy impact on you as the individual and we think you would reasonably expect us to use the personal data in the way that we wish to. Tutors do not need to ask permission to record the lecture or online session, either on campus or if being delivered online.

Can I opt out of having my personal data recorded?

If the lesson/lecture is happening in person and you do not wish to be recorded, you should ensure you are not in view of the video camera and you could choose not to speak during that session.

If the teaching session is taking place online, you can mute your microphone or turn off your webcam. We hope you don’t feel the need to do this as your tutors and your fellow learners value your contribution to the sessions, but you are allowed to do so unless the session is being recorded for assessment purposes and your contribution is being assessed. Your full name will show within the Teams session.

How are recordings stored and shared?

Recordings are stored within Microsoft Stream, a repository within the College’s Microsoft environment. Recordings within Microsoft Stream can be shared directly with learners. Recordings will be stored in line with GDPR data retention timescales and then deleted. The recordings will be accessible to staff and learners. If the recordings are downloadable learners must not download them, share them, or edit them in anyway. They will remain accessible until the end of your studies so there is no need to download them.

The College may view the recordings for the purposes of ensuring good learner behaviour and share with the police and other law enforcement agencies, for the prevention or detection of crime.

Where can I get more information?

Highbury College’s Data Protection Policy is available on this page. For further information or to make a complaint please contact the Information Commissioner’s Office Website https://ico.org.uk/your-data-matters/ and in the main Privacy Notice for Learners.


Cookies and Your Privacy

Information on what cookies may be set when you visit a Highbury College Portsmouth website and how to reject or delete those cookies. 

How to control and delete cookies

Highbury College Portsmouth does not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by Highbury College Portsmouth website, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how.

Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual. 

Please be aware that restricting cookies may impact on the functionality of the Highbury College Portsmouth website.   Highbury College Portsmouth  make use of an Session Identity cookie which is used by the Highbury College Portsmouth web site to identify you as a user between page loads. This allows the Highbury College Portsmouth  website to remember certain settings, like which part of the website you were using before you were asked to sign in or register for certain services. This cookie is destroyed each time you close your browser. 

Third Party Cookies set for UK users and users outside the UK

Highbury College Portsmouth uses Google analytics which sets cookies on the Highbury College Portsmouth website in order to deliver the services that they provide. If you would like more information about the cookies used by these suppliers, as well as information on how to opt-out, please see their privacy policies listed below.  

Google Analytics

The Highbury College Portsmouth website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of the site and compile reports for us on activity on the site. Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.  By using the Highbury College Portsmouth website you consent to the processing of data about you by Google in the manner and for the purposes set out above. How to reject or delete this cookie http://www.google.com/intl/en/privacypolicy.html 

Cookies set by Third Party sites

Highbury College Portsmouth sometimes embeds photos and video content from websites such as YouTube and Flickr. As a result, when you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites. Highbury College Portsmouth does not control the dissemination of these cookies.  You should check the relevant third party website for more information about these.   

Highbury College Portsmouth Sharing Tools

We would like to draw your attention to the fact that the Highbury College Portsmouth website and phone apps may carry embedded ‘like” buttons to enable users of the site to easily highlight articles with their friends through a number of popular social networks. These sites may set a cookie when you are also logged in to their service. Highbury College Portsmouth does not control the dissemination of these cookies and you should check the relevant third party website for more information about these.  


Information on courses

Highbury College reserves the right to cancel or modify any course without prior notification. Highbury College reserves the right to withdraw a course if it does not have enough participants. Errors and omissions excepted.


Online information request

The information will be held on computer. The Data Protection Act gives you the right to see your record and check it for accuracy.


How We Use Your Personal Information

This privacy notice is issued by the Education and Skills Funding Agency (ESFA), on behalf of the Secretary of State for the Department of Education (DfE). It is to inform learners how their personal information will be used by the DfE, the ESFA (an executive agency of the DfE) and any successor bodies to these organisations. For the purposes of relevant data protection legislation, the DfE is the data controller for personal data processed by the ESFA.

Your personal information is used by the DfE to exercise its functions and to meet its statutory responsibilities, including under the Apprenticeships, Skills, Children and Learning Act 2009 and to create and maintain a unique learner number (ULN) and a personal learning record (PLR). Your information will be securely destroyed after it is no longer required for these purposes.

Your information may be shared with third parties for education, training, employment and well-being related purposes, including for research. This will only take place where the law allows it and the sharing is in compliance with data protection legislation.

The English European Social Fund (ESF) Managing Authority (or agents acting on its behalf) may contact you in order for them to carry out research and evaluation to inform the effectiveness of training.

Further information about use of and access to your personal data, details of organisations with whom we regularly share data, information about how long we retain your data, and how to change your consent to being contacted, please visit: https://www.gov.uk/government/publications/esfa-privacy-notice


Freedom of Information Act

Highbury College is compliant with the requirement of the Further Education model provided by the Information Commission.

Highbury College is committed to making as much Information about College activities as possible generally available to the public either through published documents (including those published on the College website), or on request. Guide to the documents available under the Publication Scheme

The contact for requests for documents, questions, comments or complaints about this policy or the publication scheme is

Freedom of Information Manager/Head of IT Services
Highbury College
Tudor Crescent
Portsmouth PO6 2SA

02392 882 813
foi@highbury.ac.uk

The College will do everything in its power to meet enquirers' information needs. However, if the College is unable to resolve a complaint, enquirers have the right to complain to the Office of the Information Commissioner, the independent body which oversees the implementation of the Freedom of Information Act. The address is:

Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

We ask that requests are made in writing and a response will normally be made within 20 working days.