Purlos SCL Privacy Notice

SCL Destination Project Privacy Notice

Thank you for your interest in participating in the SCL Destination Project, administered in partnership with Purlos. This Privacy Notice is hosted on our SCL Education website, though it also applies to you if you completed your SCL studies through SCL Professional.

Why are you doing this project?

The purpose of this project is to help SCL provide the best possible service by identifying where our former learners go once they finish their studies with SCL- whether that is continuing their education, moving into employment or anything else.

We are especially interested in how you have used what you learned and achieved through SCL within your future studies or careers, either directly (e.g. by moving into a role directly related to your qualification) or indirectly (e.g. through the use of transferable skills). By helping us with this, we will be able to better-understand our courses, strategies and delivery sites which are making the most positive lasting impact. We will also be able to see how successful we are at making positive differences to the lives of people within different categories- such as learners of ethnic minorities or those with special educational needs. This will in turn help us to make business decisions which ensure we are making the biggest positive impact for all.

We will also be able to evidence to our funding partners, such as the ESFA, how we are having a lasting impact upon those who study with us.

Of course, you are under no obligation to participate in the project, and unless you confirm with Purlos that you want to take part, we will assume you don’t.

Why are you using Purlos?

Purlos is a trusted business partner and a provider of software and services to the education sector. They have the skills, experience and infrastructure to help SCL with this project.

Purlos hold your personal data in a database hosted by Salesforce who are Cyber Essentials+ and ISO 27001-Certified. Your personal data for this project will remain within the UK/EEA. SCL have a contract in place with Purlos which limits data-sharing and Purlos’ use of your data to meeting only the purpose of the project, nothing more.

We have written a Data Protection Impact Assessment (DPIA) for this project and carefully considered all personal data risks to ensure we are handling your personal data responsibly, safely and in a manner compliant with the law.

What does Purlos already know about me?

We have only shared information from our records with Purlos which is necessary for them to make initial contact with you and to reasonably prove they are contacting you legitimately. This includes the following data:

• Your Student ID
• Your name
• Your contact phone number and/or personal email address (so you can be identified on social media)
• Your course/qualification studied
• The stage of your qualification (e.g. completed)
• Your delivery centre (if relevant)
• Your year(s) of study
• Your age group
• The funding type for your qualification

This information has been shared with Purlos securely. If you choose not to participate in the project, Purlos will receive no further information about you and the data will be automatically destroyed by Purlos after 6 months.

The lawful basis under which this data processing has been conducted is the legitimate interests of SCL. SCL have a legitimate business interest in providing the most effective positive impact for their learners, in addition to being able to provide evidence to their funding partners where this is the case. This lawful basis is listed on our general Privacy Notice.

Purlos will only process your personal data to help meet the purposes of this project as detailed in ‘Why are you doing this project?’ above.

If I choose to participate in the project, what will Purlos know about me?

If you choose to participate in the project, Purlos will collect personal data about you directly from yourself. This data may include:

• What you did straight after completing your course with SCL
• Your current career/higher education status and status 3 months post-exit from SCL
• Your opinions on the relevance of SCL qualifications to your current career/educational status
• Your opinions on skills (subject specific and/or broader) developed during your time at SCL which has helped you achieve your current destination
• Potentially, your criminal data (if you have offended and choose to share this) or health data (e.g. if you choose to share health issues which have impacted future opportunities/studies)
• Other personal data you choose to share with Purlos

The lawful basis for this personal data-sharing is your explicit consent. You can remove your consent at any time by contacting Purlos. If you do remove your consent and inform Purlos of this, they will destroy data they hold relating to yourself within 1 calendar month.

Please note that if you provide details to Purlos about what you did after you completed your studies with SCL- called your ‘Learner Destination’- SCL will add these details to the Individual Learner Record (ILR) we hold about you. We have a legal duty to hold your ILR and your ‘Learner Destination’ is a required field within this. The lawful basis for this data to be held by SCL is our legal requirement.

Purlos will only process your personal data to help meet the purposes of this project as detailed in ‘Why are you doing this project?’ above, as well as their own legitimate business interests of reporting and benchmarking. If it is possible for your personal data to be anonymised or pseudonymised as part of this process, Purlos will do so

Named SCL staff will be provided with access to the Purlos SaaS via MFA to import this data into SCL’s own hosted platforms for analytics. Your personal data will only be accessible by named SCL staff who reasonably require access to it in the ordinary course of their role, or technical support as required.

Once your personal data has been imported into SCL’s own hosted platform, it may be combined with other personal data items already held on you by SCL to support analytics. This may include special category data, such as your Special Educational Need status if relevant.

Will anybody else be able to see my personal data?

Details you provide to Purlos regarding your ‘Learner Destination’ are added to your Individual Learner Record (ILR) held by SCL. The personal data within your ILR will only be accessed by named SCL staff who reasonably require access to it in the ordinary course of their role, or technical support as required.

Your other personal data included in the project can only be accessed by named Purlos and SCL staff involved in the project.

The ESFA and OfSTED hold audit rights over SCL, so may request SCL provide them with sight on personal data relating to this project, but only if they hold a reasonable lawful basis to do so.

Nobody else will have sight on personal data relating to the project. We will ensure that all personal data relating to you is fully anonymised before being promoted into the public domain or shared with other third parties.

How long will you hold my data?

Data will be retained by Purlos/Salesforce for 6 months following end of contract before being destroyed.

Data will be retained by SCL in line with ESFA requirements (currently 7 years following course completion) before being destroyed or fully anonymised.

Where can I find out more information?

You can find general information about how SCL Group processes your personal data, including contact details for our Data Protection Officer, by viewing the SCL Privacy Notice for our Customers.

You can find general information about how Purlos processes your personal data by viewing the Purlos Privacy Notice.