Race Equality Charter (REC) Survey Privacy Notice
What is the REC?
The following privacy policy covers the staff and students of the BPP Education Group referred to as (“BPP”). This notice also includes staff and students at the wholly separate subsidiaries owned by BPP – specifically Firebrand Training Ltd, Estio Training, Buttercups Training and Digital Marketing Institute. So, when we say ‘BPP’ in this privacy notice, we are also including participants who choose to complete the REC survey at BPP’s subsidiary companies.
BPP (the “University”, “We”, “Us”, “Our”) is the data controller for the purposes of this project. We aim to conduct this REC research with the highest standards of integrity. Our teaching and research is underpinned by policies and procedures that ensure we comply with regulations and legislation that govern our conduct. This Privacy Notice sets out your rights under the Data Protection Act 2018 (DPA 2018) and the UK General Data Protection Regulation (UK GDPR).
Advance HE’s Race Equality Charter helps institutions in their work to identify and address the barriers facing Black, Asian and minority ethnic staff and students, while also providing a framework for action and improvement. Institutions can apply for a bronze or silver award, depending on their progress. The data that is collected will be analysed to inform targeted action under REC, BPP Strategy, and as an evidence base for equality impact assessments (EIAs).
The survey aims to improve experiences for staff and students and to improve upon our statutory duties under the Equality Act 2010. BPP aims to develop evidence-based, comprehensive action plans to underpin the agreed priorities and advance race equality over the subsequent three years (after which time the institution plans to repeat the self-assessment process).
This Notice applies to any personal data processed for the purpose of the REC. For the purpose of any applicable data protection laws enacted in England and Wales, BPP is the data controller of your personal data. The main privacy notices for staff and students are also relevant and should be read in conjunction with this notice. The reason for this supplementary privacy notice is the need to let staff and students know exactly how their data is being managed for BPP’s application to obtain a REC award.
Contact Details: We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions, including any requests to exercise your legal rights, please contact the DPO using the following details:
FAO of the Data Protection Officer
BPP Professional Education Group (or select the relevant BPP entity from the list in the opening paragraph).
Legal Team
1 Portsoken Street
London
E1 8BT
Email: dataprotection@bpp.com
1. What is Personal Data?
The GDPR defines "personal data" as any information about an identified or identifiable natural person (referred to as a "data subject"). An identifiable natural person is someone who can be directly or indirectly identified, particularly by using an identifier like a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This encompasses information that may not directly identify you (for instance, if your name has been omitted), but which can reveal your identity when combined with other accessible information. For example, if available information includes race, gender, and role/team at BPP, it might be feasible to identify you by combining the data.
2. Your Personal Data - Our Responsibilities
For our REC application, as the data controller, we determine the methods by which your personal information is gathered, used, shared as necessary, stored, and ultimately disposed of (processed, retained, and anonymised).
We must keep your personal information secure and respect the sensitivity and confidentiality of the personal information processed for the purpose of the application to the REC. It will not be reused for another purpose.
When you complete the survey, we will process some information about you that is considered to be sensitive or which is “special category” personal data. The data that you disclose is entirely voluntary and you are under no obligation to complete the survey. Should you provide personal data in response to any of the questions, please consider whether your responses reveal circumstances which may identify you and whether you wish to include them. You can choose to skip any question that you do not feel comfortable answering and any disclosure of personal data is at your own discretion. Any personal data that permits identification will only be accessed in a confidential and secure manner by HR staff working on this Equality and Diversity project. You should restrict your answers to the matter at hand and avoid disclosing the personal data of others.
The special category data you may choose to voluntarily disclose that will be processed by BPP may include:
Information about protected characteristics including age, disability, gender, reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or religious beliefs and sexual orientation.
The REC requires the collection and analysis of data to guide focus areas. This data will be used to assess differential impacts on white staff/students versus staff/students of colour, as well as between white and BAME subgroups. Additionally, the survey gathers anonymous feedback to highlight areas where BPP excels, areas for improvement, or areas where performance is lacking.
The survey results are anonymised (as far as possible) and will be analysed and collated into meaningful analysis to show patterns/issues/concerns to then make action plans. This will be shared with a very limited BPP project team of four individuals and also included in a summarised or brief format with Advance HE when making the application. Data collected does not include names or Banner IDs so this survey is designed to make sure that you are not identifiable. However, we appreciate that it is not always possible to totally anonymise the data because certain specific combinations may make identification possible.
BPP uses an online platform to process the surveys and it will be stored securely in the SmartSurvey platform until the campaign has closed. It will also be shared via SharePoint and PowerBI dashboards (once anonymised as far as possible).
3. The Lawfulness of using Your Personal Data
To comply with UK GDPR and the DPA 2018, we are required to be transparent with you about the legal basis upon which we process your personal information. In the context of this research, we will process your personal information in accordance with:
UK GDPR - Art.6 1 (f) “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party”.
This is because BPP has a legitimate interest in using programmes like the REC to ensure we are offering equal access and opportunities to staff and students.
UK GDPR - Art.9 2(g) “processing is necessary for reasons of substantial public interest”. Processing for reasons of substantial public interest meets the condition at Schedule 1 Part 2 paragraph 8 of the Data Protection Act 2018 - i.e. it is necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people specified in relation to that category with a view to enabling such equality to be promoted or maintained and the appropriate policy documents are in place.
This means that any special category data that is processed as part of the REC initiative is to help BPP to progress its equality, diversity and inclusion aims to ensure equality of opportunity or treatment for its students and staff.
4. How will my data be shared?
If shared (published and/or placed in a database accessible by others), your data will be in an anonymised and aggregated form, meaning that no-one could use any reasonably available means to re-identify you. To further protect your identity, where a question returns 5 or fewer responses from one group, numbers will be redacted and presented as ‘-‘.
Summary (aggregated) analyses of this anonymised data will feature in BPP’s REC application, internal reporting and statutory equality reporting to ensure delivery on these priorities, and to feedback conclusions to participants.
5. For how long will my data be retained?
Downloaded survey data is required until a minimum of July 2025, which is the deadline for the application.
Your anonymised data will be securely stored indefinitely in aggregated form, to allow us to measure progress against the goals we set in the REC Action plan.
Data will be purged from the SmartSurvey platform within 365 days of submission.
6. Does the survey request excessive data?
The REC requires a thorough examination of the full breadth of our operations, and consequently asks extensive questions on participants’ experiences at BPP. The questions have been written to only request sufficient details to perform the current analysis and are not exhaustive.
Unless necessary, demographic questions that do not relate to race, ethnicity or nationality have been kept as broad as possible, for example asking whether you consider yourself to have a disability type, and “Are you a manager?” rather than “What do you manage?”
7. Your Legal Rights
Details about your rights and how to exercise them are set out on our main Data Protection webpage. Some of these rights are not absolute, for example you do not have the right to ask for your personal data to be erased beyond a certain point in the research.
8. You have the right to make a complaint at any time to:
The Information Commissioner’s Office (“ICO”), is the UK supervisory authority for data protection issues (www.ico.org.uk) If you are not satisfied with the response you receive from our DPO, you have the right to lodge a complaint with the ICO about our handling of your data.
We would appreciate the chance to deal with your concerns before you approach the ICO (or other relevant authority) so please contact us in the first instance.