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LONDON SCHOOL OF BUSINESS & FINANCE (MALTA)
Student Privacy Notice

 

This Privacy Notice is dated 3rd April 2024

  1. INTORDUCTION

London School of Business & Finance (Malta) (“LSBF”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Notice (the “Notice”) is a statement of the practices adopted by LSBF in connection with its processing of student personal data and the steps taken to protect it.

This Notice applies to all students enrolled with LSBF, whether full-time or part-time and including alumni. It explains what personal data we collect and process about our students, how and why we collect and process that data and the ways in which we may disclose it and our reasons for doing so. It also provides information on how to exercise your rights as a data subject over your personal data.

We may revise this Notice from time to time, but we will never do so in a manner that undermines your rights.

Please also use the Glossary to understand the meaning of some of the terms used in this Notice.

  1. INFORMATION ABOUT LSBF

This Privacy Notice is a statement of the practices of LSBF in connection with the processing of personal data and the steps taken by LSBF to protect personal data and safeguard students’ right to privacy. LSBF is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at: www.globaluniversitysystems.com.

It is important that you read this Notice together with any other privacy notice 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 personal data.

This Notice supplements the other notices and is not intended to override them.

Controller

London School of Business & Finance (Malta) is the controller and responsible for your personal data as a student. We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Notice. If you have any questions about this Notice, including any requests to exercise your legal rights, please contact the data privacy officer using the details set out below.

Full name of legal entity:  London School of Business & Finance (Malta)

Email address: dpo@lsbf.edu.mt  

Postal address:  Mediterranean Conference Centre, Triq-I Ipstar, II- Belt Valletta VLT 1645

Please use the words ‘Data Protection Matter’ in the subject line.

  1. GLOSSARY

Below are definitions of certain key terms used in this Notice:

  • data subjects” means living, natural persons about whom we process personal data;
  • data controller” or “controller” means any entity or individual who determines the purposes for which, and the manner in which, any personal data is processed;
  • data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we, being the data controller);
  • legitimate interest” means our interest to conduct and manage our business appropriately and responsibly, to protect the reputation of our business, and to provide the best possible services. 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;
  • personal data” means data relating to a living individual (i.e., natural person) who can be identified from the data we possess about him or her. This includes your name and surname, address, date of birth, contact details. It does not include information relating to a legal person (such as a company);
  • processing” means any activity or set of operations that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organising, amending, retrieving, using, consulting, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties; and
  • sensitive personal data” includes information about a person's racial or ethnic origin, political opinions, religious, philosophical, or similar beliefs, trade union membership, physical or mental health or condition or sexual life or his or her biometric data.

 

  1. PERSONAL DATA WE MAY COLLECT (OR RECEIVE) ABOUT YOU

Personal data 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, store and use the following categories of personal data about you:

  • Category of Personal Data:Identity Data

Examples:  Your first name, last name, preferred name, title, date of birth, gender, photocopy of national identity document number and/or passport, languages spoken (and level of proficiency), photographic image

  • Category of Personal Data:Contact Data

Examples: Permanent home address, current address (if dissimilar), email address, telephone number, mobile number, place of work.

  • Category of Personal Data:Education Data

Examples: Details of the secondary school and undergraduate school you attended (including the location, start & end date), your average grade, transcript of results and degree certificate.

  • Category of Personal Data:Course Data

Examples: Details of your student record, including your courses, assessments, work produced, examinations taken, exam scripts, results and grades, repeated units, and other information that may be included in your record as well as your attendance

  • Category of Personal Data:Employment Data

Examples: Details of current and previous employment, including your position, start & end date and description of employment

  • Category of Personal Data:Financial Data

Examples: Bank account details, payment details, details about payments to and from you and other details of products/services you have purchased from us.

  • Category of Personal Data:Video Data

Examples: Video and audio recordings of you at our online lectures (including your online username and any questions raised by you during the online session) will be shared . As a student, participation in our online sessions by video is entirely at your choice. A notice will appear before the start of the online session informing you that it is being recorded.

  • Category of Personal Data:Marketing Data

Examples: Your marketing preferences.

The data we collect from you will be used by LSBF in accordance with the purposes outlined in this Notice. We collect personal data via website forms, written application forms and documents, email and phone enquiries, research studies and surveys. We also collect via third parties such as: the Authority responsible for regulating further and higher educational institutions and education providers; Jobsplus; the National Research Statistics Office; Identity Malta; the Ministry responsible for Education; the Ministry responsible for Justice; research partners and international affiliates.

 

We will also collect additional personal data throughout the period of your student enrolment with us.

Students

LSBF process data relating to students as detailed below. Personal data and sensitive personal data may be collected directly from students who avail of specific services offered by LSBF, for example access disability support or counselling services. If you provide LSBF with your data for these purposes, then specific information on data protection will be provided at the point of collection. 

LSBF will ensure that student personal data is processed fairly and lawfully in keeping with the principles of data protection and will process personal data under various legal bases depending on the purpose for which the data is collected. These may include:

  • Where the processing of personal data is a statutory function of LSBF under the Maltese Education Act, Chapter 327 of the Laws of Malta.
  • Where LSBF is required to process personal data by law including the sharing of data with governmental authorities such as the Ministry responsible for Education; the Ministry responsible for Justice; the Authority responsible for regulating further and higher educational institutions and education providers; the National Research Statistics Office; the National Audit Office; Banks.
  • Where the processing of personal data is necessary for the formation of a contract with you.
  • Where the processing of personal data is not related to the official functions of LSBF we may sometimes process personal data based on legitimate interests e.g., for the administration of events, purchasing of tickets, gift shop purchases and the use of our services.

Generally, when processing sensitive personal data, LSBF will seek explicit consent for the processing of data except where another condition applies e.g. disability legislation, legal claims or vital interests.

 

List of purposes for processing personal data:

Category: Identity Data, Contact Data, Education Data, Employment Data, Financial Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Performance of a contract.
  • Compliance with a legal obligation.

Category: Identity Data, Contact Data, Education Data, Employment Data, Financial Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Performance of a contract.
  • Compliance with a legal obligation.

 

  • Administration of your education and student records. This includes the provision of core teaching, learning and research services.

Category: Identity Data, Contact Data, Education Data, Course Data, Video Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Performance of a contract.
  • Compliance with a legal obligation.

 

  • Administration of LSBF policies.

Category: Identity Data, Contact Data, Course Data, Financial Data, Marketing Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Performance of a contract.
  • Compliance with a legal obligation.

 

  • Administration and provision of LSBF email address and IT services.

Category: Identity Data, Contact Data, Course Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Performance of a contract.
  • Legitimate interests to ensure and enhance quality of services provided by LSBF.

 

  • Provision of data to governmental authorities, including Ministry for Education, the Authority responsible for regulating further and higher educational institutions and education providers, the National Research Statistics Office, the National Audit Office.

Category: Identity Data, Contact Data, Course Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Compliance with a legal obligation.

 

  • The provision of data to Identity Malta to support visa applications for international students.

Category: Identity Data, Contact Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Legitimate interests to facilitate enrolment and attendance by international students.

 

  • Academic assessment (examinations), supervision and monitoring of attendance. This includes verifying your identity as the candidate, ensuring your compliance with our student byelaws and regulations (e.g. plagiarism) and to contact you to provide assistance in connection with exams.

Category: Identity Data, Contact Data, Course Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Compliance with a legal obligation.
  • Legitimate interests to ensure quality control.

 

  • Graduation and granting of awards.

Category: Identity Data, Contact Data, Course Data, Marketing Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Performance of a contract.

 

  • Processing of appeals, complaints and disciplinary issues.

Category: Identity Data, Contact Data, Course Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Performance of a contract.
  • Legal claims.

 

  • Administration of research programmes and funding.

Category: Identity Data, Contact Data, Course Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.

 

  • Surveys, submission forms and student feedback.

Category: Identity Data, Contact Data, Course Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Legitimate interests to ensure quality control.

 

  • The provision of medical, counselling and disability services.

Category: Identity Data, Contact Data, Course Data, Health Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Consent or explicit consent.
  • Vital interests of the individual.

 

  • The provision of reasonable accommodations.

Category: Identity Data, Contact Data, Financial Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Statutory requirement – Disability and Equality Legislation.
  • Vital interests of the individual.

 

  • The provision of careers services and mentorship.

Category: Identity Data, Contact Data, Course Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Legitimate interests to ensure and enhance quality of services provided by LSBF.

 

  • The use of sports and recreational facilities.

Category: Identity Data, Contact Data,

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Legitimate interests to ensure and enhance quality of services provided by LSBF.

 

  • The provision of student accommodation.

Category: Identity Data, Contact Data, Financial Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Performance of a contract – accommodation agreement.
  • Legitimate interests to incentivise and facilitate enrolment by international students.

 

  • If necessary due to a medical emergency.

Category: Identity Data, Contact Data, Health Data

Legal basis for processing:

  • Vital interests of the individual.
  • Statutory requirement.

 

  • Billing, tuition and processing and recovery of fees and payments.

Category: Identity Data, Contact Data, Financial Data

Legal basis for processing:

  • Performance of a contract.
  • Legitimate interest of LSBF.

 

  • Vetting for placements on specific courses.

Category: Identity Data, Contact Data, Financial Data, Marketing Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Legitimate interests to ensure quality control and that students can meet course demands.

 

  • Provide information about LSBF events and activities.

Category: Identity Data, Contact Data, Marketing Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Legitimate interests to ensure increased student participation.

 

  • Retention of academic data and data of archival value in the public interest.

Category: Course Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Compliance with a legal obligation.

 

  • Provision of education and contact data to Alumni Office for the purposes of alumni engagement and fundraising.

Category: Identity Data, Contact Data, Marketing Data

Legal basis for processing:

  • Necessary for LSBF to carry out the objects and functions under the Maltese Education Act, Chapter 327 of the laws of Malta.
  • Legitimate interests.

 

Where we need to collect personal data about you by law, or pursuant to our terms of business, and you fail to provide that data when requested, we may not be able to process or maintain your enrolment.

 

We will duly inform and notify you if this is the case at the time.

 

Aggregated Data

We also collect, use and share data in an aggregated form such as statistical or demographic data to improve our educational services and for statistical and benchmarking purposes, including enabling comparisons within the same industry to enhance the insights collected through the student academic experience.

Aggregated Data could be derived from your personal data but will not be considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your course data to calculate the percentage of students enrolling in a specific course. 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.  

 

  1. DATA SHARING

LSBF will only share your data with third parties where necessary for purposes of the processing and where there is a legal basis to do so. We may share relevant data with the following categories of third parties:

 

  • Governmental authorities and bodies including, the Ministry responsible for Education; the Authority responsible for regulating further and higher educational institutions and education providers; Jobsplus; the National Research Statistics Office; the National Audit Office; Identity Malta.
  • IT or Cloud service providers that provide essential services to LSBF e.g. Google and Zoom.
  • Firms that provide professional services to the LSBF such as legal firms, banks and auditors.
  • Firms that provide archiving and storage and disposal of confidential waste.
  • Research and academic partners.
  • Organisations and public services entities that provide placements for students.
  • The Maltese Police Force, Interpol or any other organisation when we are required to do so by law.

 

When we share your data with the third parties, as outlined above, we will endeavour only to share the data that is needed and that the same standards of confidentiality and security are maintained.

  1. DATA RETENTION

In keeping with the data protection principles, we will only store your data for as long as is necessary and in accordance with the LSBF Records Management Policy and Records Retention Schedule.

To determine the appropriate retention period for personal data, we consider the nature and sensitivity of that personal data, our purposes for processing that data (including any applicable legal obligations) and the potential risk of harm from its unauthorised processing.

In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such data without further notice to you. In some circumstances you can ask us to delete your data. See Request erasure below for further information.

 

  1. DATA MINIMISATION

Whenever and to the extent possible, we anonymise the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you.  In some circumstances, we may even anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Kindly contact us at dpo@lsbf.edu.mt for further details about the retention periods that we apply.

 

  1. DATA SUBJECT RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction (rectification) of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

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 data subject 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 or facilitate our response.

We try to respond to all legitimate requests within the period of one (1) month from receipt of the request. 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.

These rights are explained below.

 

  • Access: You have the right to obtain confirmation that your information is being processed and to obtain access to your information, e.g., by receiving a copy of it.

 

  • Rectification: You have the right to have your information corrected if it is inaccurate or incomplete.

 

  • Erasure: You have the right to request the deletion or removal of your information in certain circumstances.  Please note that there may be circumstances where it is not possible to fulfil the request for your information to be deleted, e.g. if there is a legal reason to retain it.

 

  • Object: You have the right to object to processing of your data where we are relying on a legitimate interest or those of a third party, and you wish to object as you feel it impacts your fundamental rights or freedoms. You also have the right to object where we are processing for marketing purposes.

 

  • Restrict: You have the right to request that the processing of your information is restricted in certain circumstances.  Again, there may be cases where we are legally entitled to refuse such a request.

 

  • Data Portability: You have the right to request the transfer of your personal data to you or to a third party. We will provide that personal data in a structured, commonly used, machine-readable format. 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.

 

  • Withdrawal: In the rare case that we are relying on consent to process your personal data, you may withdraw it at any time. This will not affect the lawfulness of any processing carried out before you withdrew your consent and any processing activities not based on your consent will remain unaffected. Once we have been made aware of your withdrawal, we will no longer process your data for the purpose/s you originally agreed to, unless we have another legitimate basis for doing so.

Kindly note that none of these data subject rights are absolute and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override your data subject request, you will be informed of this by our data protection team along with the reasons for our decision.

  1. COMPLAINTS

If you have any questions about this Notice or how we handle your personal data, please contact dpo@lsbf.edu.mt   

You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as the supervisory authority in the place of your habitual residence or place of work. In the case of Malta, this is the Information and Data Protection Commissioner (“IDPC”), whose website is set out below:

https://idpc.org.mt/en/Pages/Home.aspx.

We would, however, appreciate the opportunity to deal with your concerns internally before you approach the supervisory authority, so please bring the matter to our attention at the first instance.

 

  1. CHANGERS TO THIS PRIVACY NOTICE

We reserve the right to update this Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.

We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this Notice, the DPO will be happy to address them.

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