Kaplan Resilience Programme Privacy Notice
Introduction
We care about your privacy and keeping your personal information safe. This notice explains what information we collect about Students in our Resilience Programme, how we use it and who we might share it with, and how Students can exercise their privacy rights. It is important that you read this Privacy Notice so that you understand how and why we are using your personal information. This notice should be read in conjunction with the Kaplan Pathways Student Privacy Notice.
You can click through to the specific areas set out below.
1. Key Terms
Throughout this Privacy Notice, we use some essential terms, which are defined below:
Kaplan Resilience Programme – a self-access online programme offered by Kaplan International Pathways to help Pathways Students develop certain skills and strategies to build resilience in the face of stress, change, uncertainty and challenges
Student (Participant) – a Kaplan Pathways Student who wishes to participate in the Kaplan Resilience Programme
Parent – a Student’s parent(s). A parent of a Student under the age of 18 can make decisions on behalf of the Student
Legal Guardian – an individual who has been legally appointed to make decisions on behalf of a Student under the age of 18 through a formal court process.
2. Who we are
We are Kaplan International Pathways. We deliver the Kaplan Resilience Programme. We decide what personal information we need for the programme and how it is used. We are responsible to look after this information.
Where you are a Participant in a Kaplan Resilience Programme, Kaplan International Pathways is a data controller. This means that we decide what to do with the personal information we collect about you, like your name, contact information and anything else that identifies you. The law says we must explain clearly how we use and protect this information. This is what this Privacy Notice is for – to let you know what happens to your personal information when you give it to us, either directly or through someone else.
Kaplan International Pathways group is made up of different legal entities. When we mention “Kaplan”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the Kaplan International Pathways group responsible for processing your information, including the International College you may be studying with.
3. Who to contact about your personal information
You can contact our Data Protection Officer (DPO) using the details set out below, if you have questions about how we use your information. Our DPO makes sure we look after your information properly.
Email address: dpo@kaplaninternational.com
Postal address: Palace House, 3 Cathedral St, London SE1 9DE, England, UK.
You have the right to make a complaint at any time. In the first instance, the complaint should be directed to us. We will respond within 30 days of receipt. If you are not satisfied with our response, you are free to raise any concern with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
4. What is personal information?
Personal information is anything that can identify you. We may process the following information about you.
- Name
- Age
- Email address
- IP Address
- Browsing history
- Cookie information
- Network interaction history
- Emoticons you use.
Anonymous Surveys
We will invite you to complete surveys about your experience of the Programme. These surveys may include optional questions about matters such as your mood or stress. You do not have to answer these questions in order to participate in the Programme.
The surveys are configured to be anonymous. Kaplan International Pathways does not ask you to provide your name or email address with your responses and does not use the responses to identify you. Anonymous survey information may be used to understand the Programme at an overall level and to improve it.
Special Category/Sensitive Personal Information
Some personal information is more sensitive – like details about health, ethnic background, religion, sexual orientation or criminal convictions. This is called special category or sensitive personal information. We do not collect special category data for the Kaplan Resilience Programme.
5. Our rules for using your personal information
We follow strict rules when using your personal information. We promise to use it fairly and legally, always inform you how we use it, only collect what we need, keep it up-to-date, not keep it longer than we need to, and keep it safe.
6. How we use the personal information we collect
We use personal information to help Students to enrol and participate on the Kaplan Resilience Programme and by maintaining contact with former Participants to offer ongoing support and updates about opportunities that may be of interest to them.
We use personal information when we need to follow the law.
We also may need some information that helps our business, as long as using it will not harm your rights or freedoms.
For these purposes we may also need to use the personal information of the Student Parents/Legal Guardians, like their name, email and relationship to the Student.
Generally, we do not rely on consent as a legal basis for processing your personal information, other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
7. What information we collect and why
We collect different types of information for different reasons. For example, to answer your questions and help you find the right Kaplan Resilience Programme information, to process a Student’s participation and support them on the Resilience Programme, to send useful updates about the Resilience Programme, to meet our legal responsibilities, to improve our products according to learner usage and to improve how we support Participants. We may collect various information during a Student’s registration on the Resilience Program but will always make sure this does not affect their rights and freedoms.
- Registration and Participation
If you register to participate in a Kaplan Resilience Programme, we may collect the following categories of personal information about you and your Parent/Legal Guardian if you are under 18:
- Name
- Programme access and engagement information
- Device and browser information
- Approximate location
- Work/school email address
- Age
- College
- Emojis
- .
The legal basis for processing this information is to fulfil our contract to provide the Kaplan Resilience Programme to you, but it is also in our legitimate interest to use this personal information in order to monitor the provision of our services.
- Enquiries and Marketing
If you enquire about the services we offer, we may use your:
- Name
- Date of birth
- Your query
- How you have engaged with our website or our events and other interactions with us.
This helps us understand what we can offer you and to provide you information about similar services and to prioritise queries. It may be necessary to process additional personal information about you, depending on your enquiry. The legal basis to process this information is your consent, where you have provided your consent in your enquiry, or where it is in our legitimate interest to do so.
If you have applied to participate in the Kaplan Resilience Programme, are a current Participant or one of our Programme alumni, we may use your personal information to inform you of special offers and new or existing services that we believe may be of interest to you or to send you surveys or questionnaires so that we can learn more about your needs and interests and improve our services. The legal basis to process your information is our legitimate interest.
You will always be provided with the option to opt out of such communications, if you no longer wish to receive them.
- Internal business purposes
We may also use the personal information listed above for our internal business purposes. This is in our legitimate interests in order to operate as a business and monitor and improve the services we provide. Where possible, we will anonymise this information.
- Use of our website
As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. Please see our cookie policy on our website for further details.
- Artificial Intelligence (AI)
We may use AI tools to assist with analysing aggregated and anonymised Kaplan Resilience Programme data and preparing Programme-level reports. This may include analysis of overall participation, engagement, completion rates and aggregated survey results and trends. AI tools are not provided with information that identifies individual Participants. Where we use AI for other purposes, we will provide you a separate notice about how the AI tool is used and what personal information is processed.
- Anonymous surveys
We may invite you to complete surveys about your experience of the Programme. These surveys may include optional multiple choice questions about matters such as your feelings of stress. You do not have to answer these questions in order to participate in the Programme.
Where surveys are configured to be anonymous, Kaplan International Pathways does not collect any information to identify you, including name, email, IP address or other information and cannot use the responses to identify you. Anonymous survey information may be used to understand the Programme at an overall level and to improve it.
If you fail to provide personal information
Where we need to collect personal information for a Participant’s participation in the Programme and you fail to provide that information when requested, we may not be able to provide the services to the Participant.
8. Who we share your personal information with
To provide the services we offer, it is sometimes necessary to share the personal information we process with third parties. We only do this where it is necessary and where we have ensured the organisation we are sharing your information with will keep it as safe and secure and will comply with any relevant data protection laws. This could include our third-party service providers, other Kaplan companies and other third parties.
- Our service providers
We may share your personal information with other companies that perform certain services. These services may include performing business and recruitment analysis and supporting our website and IT functionality. These service providers will be supplied with or have access to your personal information solely for the purpose of providing these services to us or on our behalf.
9. Sending your personal information to other countries
Sometimes we need to send the personal information we process to other countries, but we make sure it is still protected. Even if a country’s privacy rules are different, we take steps to keep your personal information safe.
10. How we keep your personal information safe
We take care to keep the personal information we process safe and protected from any loss, theft or misuse. We make sure only the right people can see or use your information. If something goes wrong, we will tell you if you need to take action.
11. Keeping your personal information up-to-date
If you are a Participant and there is a change to your personal information, please update it via your learning portal. If you are unable to update the information, please contact your College Services Team.
12. How long we keep your personal information
We will keep the personal information we process for as long as it is necessary for us to provide Participants our services, to meet our business needs or to meet our regulatory and legal duties. We will delete or anonymise the personal information when it is no longer necessary to keep it.
13. Your rights
You have rights over your personal information. These include the right to:
- Understand how we use your information
- See what information we hold about you
- Ask us to correct inaccurate information
- Ask us to delete your information (in some cases)
- Tell us not to use your information (in some cases)
- Ask for your information to be sent to someone else
- Make a complaint if you’re unhappy with the way we have handled your personal information.
We are always happy to help you exercise these rights. If you would like to do so, please use this link here. We may request information from you to help us confirm your identity to ensure we do not disclose your information to a third party.
Your right to withdraw consent
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw that consent. To withdraw your consent, please contact us using the contact details in this Privacy Notice. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
14. Changes to this Privacy Notice
We may update this notice and we will let you know if we have made any big changes.
15. Our companies
If a Participant is on a Kaplan Resilience Programme, the college they attend is part of Kaplan International Pathways. Please see below the full list of companies within Kaplan International Pathways covered under this Privacy Notice.
| Name of college or operation | Kaplan International Pathways group company Registration Number Registered Office |
| Headquarters and Digital Pathways | Kaplan International Colleges U.K. Limited (Company number 05268303) Palace House, 3 Cathedral St, London SE1 9DE, England |
| Bournemouth University International College | Kaplan Bournemouth Limited (Company number: 08291927) Palace House, 3 Cathedral St, London SE1 9DE, England |
| Glasgow International College | Kaplan Glasgow Limited (Company number: 05976922) Palace House, 3 Cathedral St, London SE1 9DE, England |
| Kaplan International College London | Kaplan International College London Limited (Company number: 06533974) Palace House, 3 Cathedral St, London SE1 9DE, England |
| Nottingham Trent International College | Kaplan NT Limited (Company number: 05268287) Palace House, 3 Cathedral St, London SE1 9DE, England |
| University of Brighton International College | Kaplan Brighton Limited (Company number: 07331979) Palace House, 3 Cathedral St, London SE1 9DE, England |
| University of Essex International College | Kaplan Essex Limited (Company number 10846169) Palace House, 3 Cathedral St, London SE1 9DE, England |
| University of Liverpool International College | Kaplan Liverpool Limited (Company number: 06217892) Palace House, 3 Cathedral St, London SE1 9DE, England |
| University of Nottingham International College | Kaplan Nottingham Limited (Company number: 10199220) Palace House, 3 Cathedral St, London SE1 9DE, England |
| University of the West of England, Bristol’s International College | Kaplan UWE Limited (Company number: 08102562) Palace House, 3 Cathedral St, London SE1 9DE, England |