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BPP Pro Bono Centre Privacy Policy

What is the purpose of this Privacy Policy?

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

  1. your use of BPP Pro Bono Centre websites, including any data you may provide through BPP websites when you make an enquiry or request any legal advice or support services from the BPP Pro Bono Centre (“Services”);
  2. your registration for, or use of, any Services (including but not limited to telephone advice lines, drop in centres, legal advice clinics, assistance with forms and legal translations);
  3. your use of any BPP Pro Bono Centre social media channel; and
  4. your sending of personal data to BPP Pro Bono Centre by any other means.

This Policy will also inform you of what we do with personal data, how we look after 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 notice we may provide on specific occasions when we are collecting 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 notices 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 IS YOUR PERSONAL DATA COLLECTED
  5. HOW WE USE YOUR PERSONAL DATA
  6. DISCLOSURES OF YOUR PERSONAL DATA
  7. COMPLIANCE WITH BRIBERY ACT AND RELEVANT LEGISLATION
  8. INTERNATIONAL TRANSFERS
  9. DATA SECURITY
  10. DATA RETENTION
  11. YOUR LEGAL RIGHTS
  12. GLOSSARY

Who we are

Data Controller

BPP Pro Bono Centre is part of BPP University Limited.  Therefore, BPP University Limited will be the Data Controller of any personal data you submit to the BPP Pro Bono Centre.

This Privacy Policy is issued on behalf of the BPP Pro Bono Centre so when we mention “BPP”, “we”, “us” or “our” in this Privacy Policy, we are referring to the BPP Pro Bono Centre, and by extension, BPP University Limited.

This Policy shall apply to probono.bppuniversity.ac.uk, including any subdomains that may be made available by us from time to time and all BPP Pro Bono Centre social media channels (“Website(s)”).

Contact details

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the following details:

FAO the Data Protection Officer
BPP University
Legal Team
4th Floor, 3 London Wall Buildings
London, EC2M 5PD
Email address: Legal@bpp.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Important information about this Policy

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

On 25 May 2018 the data protection law in the UK will change.  This Privacy Policy sets out your rights under the new laws.

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 relationship with us.

We may update this Privacy Policy from time to time. This version was last updated on 10th May 2018.

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 the Website or any other means.

Third-party links

The Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties 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.

Your personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity 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 in place for security purposes at our premises; any video recordings from any recorded interviews (such as client interviews in one of our legal advice clinics or drop in centres) and any audio or video recordings you may submit to us as in respect of the Services (such as video recordings of events that relate to your legal enquiry or legal issue).
  • Contact Data includes postal address, email address and telephone numbers.
  • Employment Data (this is relevant where your legal enquiry or issue relates to your employment) includes name of employer, job title, work contact details (email address, telephone number and postal address), National Insurance number and employment start and end dates.
  • Family Data (this is relevant where your legal enquiry or issue relates to family law or involves your family members) includes the names and details (age, relationship to you, employment status) of your family members.
  • Financial Data (this is relevant where your legal enquiry relates to your finances) includes annual income, description of payments in and out of your account, information about any benefits received and copies of bank statements.
  • Identity Data includes first name, maiden name, last name, any other identifier used by an organisation who has referred you to the BPP Pro Bono Centre (such as a charity you have previously sought advice from), marital status, title, date of birth and gender.
  • Communications Data includes your communication preferences.
  • Profile Data includes records of Services requested or received by you, preferences, feedback, survey responses and enquiries submitted to BPP Pro Bono Centre.
  • Services Data all the data provided by you in the course of your legal enquiry or legal issue and may include Employment Data, Family Data Financial Data, data relating to your business, data relating to consumer contracts you have entered into, data relating to debts you may have or debt claims made against you, data relating to judgments you have obtained or are seeking to enforce, data relating to your housing or a neighbour dispute, data relating to parking fines received by you, data relating to any other legal issue you wish to refer to the BPP Pro Bono Centre, and data relating to any complaints made by you regarding the BPP Pro Bono Centre.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
  • Usage Data includes information about your visit to a Website, including the Uniform Resource Locators (URL) clickstream to, through and from the Websites (including date and time), products and/or services you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) 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 statistical 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 identity. 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 identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

The law requires that “special categories” of particularly sensitive personal information require higher levels of protection than other personal data.

In some circumstances we may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your race or ethnicity – this information is only collected where it relates to the legal enquiry or issue you have referred to the BPP Pro Bono Centre. This information is voluntary.
  • Information about your nationality and immigration status – this information may be collected where it relates to the legal enquiry or issue you have referred to the BPP Pro Bono Centre. It may include copies of passports, visas and any relevant correspondence between you and the UK Visas and Immigration Department of the Home Office.  In addition, this information may be collected where you require legal translation or interpretation services from the BPP Pro Bono Centre.  This information is voluntary.
  • Information about your religion or political opinions – this information is only collected where it relates to the legal enquiry or issue you have referred to the BPP Pro Bono Centre. This information is voluntary.
  • Information about any disabilities– this information may be collected where it relates to the legal enquiry or issue you have referred to the BPP Pro Bono Centre. In addition, this information may be collected so that any reasonable adjustments can be made to accommodate clients with disabilities (for example requests for large print forms).  This information is voluntary.
  • Health information – this information is only collected where it relates to the legal enquiry or issue you have referred to the BPP Pro Bono Centre. This information is voluntary.
  • Information about your sex life or sexual orientation – this information is only collected where it relates to the legal enquiry or issue you have referred to the BPP Pro Bono Centre. This information is voluntary.
  • Information about trade union membership – this information is only collected where it relates to the legal enquiry or issue you have referred to the BPP Pro Bono Centre. This information is voluntary.
  • Information about criminal convictions and offences – this information is only collected where it relates to the legal enquiry or issue you have referred to the BPP Pro Bono Centre (for example where you are seeking advice on appealing a criminal conviction). This information is voluntary.

If you fail to provide personal data

Where we need to collect personal data in order to provide the Services to you and you fail to provide that data when requested, we may not be able to perform the Services you have requested or are trying to request from us. In this case, we may not be able to provide you with the Services (or a particular element of the Services), but we will notify you if this is the case at the time.

How is your personal data collected?

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

  • Direct interactions. You may give us your Audio/Visual, Contact, Employment, Family, Financial, Identity, Communications, Profile and Services Data by filling in forms; by corresponding with us by post, phone, email or otherwise; or attending (in person) one of our legal advice clinics or drop in centres. This includes personal data you provide when you:
  1. submit a request to receive Services from us;
  2. submit an online query or request a call back;
  3. receive Services from us;
  4. speak with one of our advice teams or student adviser;
  5. subscribe to a service or publication; or
  6. complete a survey or give us feedback.
  • Through the provision of the Services. You may give us your Services Data throughout the duration of your legal enquiry or legal issue with the BPP Pro Bono Centre. This includes personal data you provide when you:
  1. use our telephone advice lines;
  2. attend a drop in clinic or legal advice clinic; or
  3. contact one of our advice teams or student advisers for support.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
  • Third parties. We may receive personal data about you from various third parties as set out below:
    • Contact, Identity and Services Data from another legal advice centre or legal advice organisation who has referred your legal issue or enquiry to the BPP Pro Bono Centre ;
    • Contact, Identity and Services Data from a support charity who has referred your legal issue or enquiry to the BPP Pro Bono Centre;
    • Contact, Identity and Services Data from LawWorks (a charity which connects volunteer lawyers with people in need of legal advice) who has referred your legal issue or enquiry to the BPP Pro Bono Centre;
    • Contact, Identity and Services Data from a law firm’s pro bono team or centre who has referred your legal issue or enquiry to the BPP Pro Bono Centre;
    • Contact, Identity and Services Data from your MP who has referred your legal issue or enquiry to the BPP Pro Bono Centre;
    • Contact, Identity and Services Data from Doctors or other health care professionals who have referred your legal issue or enquiry to the BPP Pro Bono Centre;
    • Contact, Identity and Services Data from any other third parties who have referred your legal issue or enquiry to the BPP Pro Bono Centre;
    • Contact, Identity and Services Data from any Court, Tribunal or related organisation (such as ACAS) who are dealing with or have dealt with your legal issue or enquiry ;
    • Contact, Identity and Services Data from any interpreter or translator who is assisting you with your legal enquiry or legal issue;
    • Contact, Identity and Services Data from our student advisers who volunteer with the BPP Pro Bono Centre(all student volunteers are BPP students, studying law, and are subject to appropriate confidentiality obligations);
    • Identity and Profile Data from any third party survey organisation or portal provider, such as SurveyMonkey ;
    • Data relating to any legal complaint or dispute you may have or be involved with from a solicitor or barrister acting on your behalf or the Legal Ombudsman and/or Law Society and/or Bar Standards Board; and
    • Technical Data from analytics providers such as Google, Sessioncam and Optimizely; advertising networks; and search information providers.

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 Services we are about to agree to or have already agreed to provide to you.
  • 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 “special category” personal data (as set out in this Policy above) you may withdraw your consent to this processing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which legal basis we rely on to do so.

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.

Purpose/Activity Type of data Lawful basis for processing
Clients or prospective clients
To respond to enquiries or requests for information (a)  Identity
(b) Contact
(a)  Consent
(b) Carrying out a task in the public interest (providing pro bono legal services to the public)
To register you as a client of BPP Pro Bono Centre (a)  Contact
(b) Identity
(c)  Services
(a)  Consent
(b) Carrying out a task in the public interest (providing pro bono legal services to the public)
To deliver the Services to you (a)  Audio/Visual
(b) Contact
(c)  Communications
(d) Identity
(e)  Profile
(f)  Services
(a)  Consent
(b) Carrying out a task in the public interest (providing pro bono legal services to the public)
To use client cases to:
(a)  Train BPP Pro Bono Centre staff in client care and any relevant legal updates
(b) Train BPP Pro Bono Centre student advisers in client care and any relevant legal updates.
(a)  Services (a)  Necessary for our legitimate interests (to improve the services we offer to clients)
To:
(a) Keep records for audit/accounting purposes
(b) Defend any legal claims brought against BPP
(a) Identity
(b) Contact
(c) Financial
(d) Profile
(e) Services
(a)  Necessary for our legitimate interests (to defend legal claims)
(b) Necessary to comply with a legal obligation
To participate in audits, surveys or similar research and analysis exercises undertaken by BPP, governmental or other agencies (including but not limited to the Advice Quality Standard, LawWorks, Bail for Immigration Detainees and the Law Society) (or any successor body to them) or by third parties engaged by such bodies (a)  Identity
(b) Contact
(c)  Services
(a)  Necessary for our legitimate interests (to maintain certification with regulatory bodies, to study how clients use our services, to develop them and to inform our strategy, to include in marketing information and awards submissions)
(b) Consent
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to provide feedback or take a survey
(a)  Identity
(b) Contact
(c)  Profile
(d) Communications
(a)  Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how clients use our Services, and to develop them)
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a)  Identity
(b) Contact
(c)  Technical
(a)  Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant Website content (a)  Identity
(b) Contact
(c)  Profile
(d) Usage
(e)  Communications
(f)  Technical
Necessary for our legitimate interests (to study how clients use our Services, to develop them, to grow our business and to inform our strategy)
To use data analytics to improve our Website, client relationships and experiences (a)  Technical
(b) Usage
Necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. 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 special categories of personal information in the following circumstances:

Purpose/Activity Type of data Lawful basis for processing
Clients or prospective Clients
To provide you with the legal advice or support services you have requested Data relating to:
(a)  Race
(b) Ethnic origin
(c)  Politics
(d)  Religion
(e)  Trade union membership
(f)  Health
(g) Sex life
(h)  Sexual orientation
(a)  Your explicit consent
(b) processing is necessary for reasons of substantial public interest (providing pro bono legal services to members of the public)
To provide reasonable adjustments to clients with disabilities Data relating to disabilities (a)  Complying with our legal obligations (under the Equality Act 2010)
(b) Your explicit consent
(c)  processing is necessary for reasons of substantial public interest (providing pro bono legal services to members of the public)

Less commonly, we may also process this type of information where it is needed in relation 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 BPP believes your health or safety is at immediate risk).

Consent

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations.

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

You should be aware that it is not a condition of your right to seek our Services that you agree to any request for consent from us.  However, we may not be able to provide you with certain Services (such as legal advice) if you do not agree to provide such data to us.

Information about criminal convictions

We will only use information relating to criminal convictions where you have requested Services which relate to such information, for example, where you have asked for assistance with appealing a criminal conviction.  Therefore, this information will only be collected with your explicit consent and when it is for a task carried out in the public interest by a non for profit organisation (i.e. the provision of pro bono legal advice to individuals) and we will process such information in line with our data protection policy.

We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

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

  • Where we have notified you of the decision and given you 21 days to request a reconsideration.
  • 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 written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified 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 notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Marketing

We do not use your personal data to send any marketing to you. We will update this Policy if this changes and provide you with an opportunity to op-in to receiving marketing information.

Third-party marketing

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

Opting out

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

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 function properly. For more information 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 compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify 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 permitted by law.

Disclosures of your personal data

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

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Specific third parties marked with listed in paragraph 4 above (under the ‘Third parties’ heading).
  • Specific third parties listed in paragraphs 7 and 8 below.
  • LawWorks, a registered charity, which connects volunteer lawyers with people in need of legal advice. We may refer your legal issue or legal enquiry to LawWorks where we are unable to assist.
  • Intralinks Inc. Intralinks is a third party document storage provider. Intralinks provides free document storage to organisations registered with LawWorks so you may be asked to upload any documents relating to your legal issue or enquiry to Intralink’s document storage system.
  • Any other pro bono provider including, legal advice centres, advocacy services, pro bono centres, law firms or barristers’ chambers, who we believe may be in a better position to assist with your legal enquiry or issue. We will always seek your consent before providing your data to these third parties.
  • Your parent or guardian if you are under the age of 18 (or if you specifically request us to liaise with your parent or guardian on your behalf).
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, 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 parties 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 instructions.

Compliance with the Bribery Act and relevant legislation

In this Privacy Policy, we have explained that your personal data may be used for the purpose of ensuring compliance with legal obligations and that it may be disclosed to BPP’s group companies’ service providers or governmental departments. This includes for the purpose of enabling BPP’s group companies to comply with the US Foreign and Corrupt Practices Act 1977 (“FCPA”) and enabling BPP to comply with its obligations under the UK Bribery Act 2010 (the “Bribery Act”) and any other local laws or regulations relating to similar purposes which relate to fraudulent, illegal or unethical behaviour (the “Conduct Legislation”).

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 reporting mechanism (“Helpline”) to ensure compliance with Conduct Legislation.

It is possible that a BPP staff member, student or client may report matters 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 investigating any such report and taking remedial action thereafter. For example, if a BPP employee suspects that another employee is misusing company records for his own purposes or is committing 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 regulations. Wherever reasonably possible, your personal data will be anonymised prior to use for the purpose of investigations and remedial action so that it does not relate to you. However, in some specific circumstances this may not be possible as it may prohibit a full investigation and prevent compliance with a relevant regulation or Conduct Legislation.

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 justified as BPP considers is fair and necessary in the circumstances. These employees will be subject to appropriate confidentiality obligations.

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

Provided reports are made through the Helpline in good faith, we try to protect the confidentiality of your identity 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 allegation(s). Those subjects have the right to request their own personal data, as do you, as set out under Your Legal Rights.

International transfers

As set out in this Policy, we share your personal data with BPP group companies which includes BPP’s ultimate parent company based in the USA.  In addition, some of BPP’s IT support (including its Helpdesk function) is based in the USA and India.  Therefore, your data may be transferred outside the European Economic Area (EEA).

The Websites and/or any Services may be hosted on servers located outside of the UK and/or the EEA and maintenance and support services for the Websites and/or those Services may be provided from outside the UK and/or the US and/or EEA. This means that your personal data may be transferred to, stored and processed in other countries apart from the UK including outside of the EEA.

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

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

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 addition, we limit access to your personal data to those employees, student advisors, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

As set out in paragraph 8 above, your personal data may be held on the IT system of BPP, BPP’s group companies and/or on the IT system of another third party company (within or outside of BPP) within or outside the EEA which is providing IT hosting or other data processing services, in accordance with BPP’s arrangement in place with that company.

All information that you provide to us is stored on secure servers.

Data retention

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 satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential 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 retention periods for different aspects of your personal data are available in our Retention Policy which you can request by contacting us.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes and also for education and training purposes (with our staff and student volunteers) in which case we may use this information indefinitely without further notice to you.

Your legal rights

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

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, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity 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 information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting 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 potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting 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 obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

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

Therefore, your data may be transferred to other companies in the BPP group, acting as joint controllers or processors and who are based in the UK and the USA and provide IT and system administration services and undertake leadership reporting.

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

External Third Parties

  • Service providers acting as processors based in India who provide IT and system administration services.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, the UK Home Office, regulators and other authorities acting as joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Specific regulators in the field of legal pro bono activities, including the Advice Quality Standard, The Law Society, The Bar Standards Board and The Legal Ombudsman, acting as joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Legal advisers acting on behalf of a third party (such as a council or employer) which is related to your legal issue or enquiry.
  • Work experience students on a placement with BPP University.
  • The police, where the police make a request for personal information to BPP or as and when we consider necessary for the purpose of crime prevention.
  • The ambulance service or other health service if there is any immediate concern regarding your physical health or mental wellbeing.
  • Charities and other organisations that BPP works with in the delivery of pro bono services in the community (we will always obtain your consent before passing your data to these third parties).

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). 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 correction 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 continuing 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 information 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 notified to you, if applicable, at the time of your request.  Please be aware that this right does not apply to exam scripts or exam marks.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation 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 marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.  Please be aware that this right does not apply to exam scripts or exam marks.

Request restriction 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 legitimate grounds to use it.   Please be aware that this right does not apply to exam scripts 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 information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time 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 time you withdraw your consent.

BPP Pro Bono Centre Blog

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