Privacy Policy - Graduations

This Privacy Notice outlines how the Graduation Team at the University of Kent collects, uses, and manages the personal information of individuals for the purpose of your conferral in accordance with data protection law.

The University of Kent is registered as a ‘Data Controller’ under registration number Z6847902. View the full entry on the register

Your personal data is obtained:

• Extracted from your student record on KentVision
• Directly from you, through online forms, email or by telephone
• From third party data processors operating on our behalf who record the graduation ceremony.
• From our photography suppliers who take photos at the graduation events. 

Personal data we collect about you in connection with issuing graduation certificates and running graduation ceremonies:

• your name
• email address
• programme of study
• date of birth
• full address
• contact preferences
• the time and date of your graduation ceremony
  
  
• Photos and videos of you during the graduation events

• Your photo will be taken by a photographer appointed by Tempest Photography (our official graduation services supplier) during the ceremony when your name is called out.
• Our Communications team will also take generic photos, and video content of students and their guests, which could include you in attendance. If you do not wish to be included in these photos, please ensure you maintain distance from any pictures and filming taking place. Our Communications team will be in branded media team uniforms so that they are spotted.
  
• All ceremonies will be livestreamed via YouTube at the time of the ceremony, this will be available online as a recording following the ceremony.
  
  
• Names of your guests (if you require us to provide you with a visa letter).

Special category data we will collect about you in connection with:

• Data concerning health: If you notify us of specific requirements for you, then we will process data related to your health to ensure that arrangements for your day are suitable to your needs.  Additionally, if you notify us of specific requirements for your guests, we will process these accordingly. Information relating to disability and accessibility requirements for you, or your guests is not shared beyond the organisation of the graduation ceremony. 

Criminal offence data:

If there was an allegation of a criminal offence at the graduation ceremonies, then we would notify either the police or Cathedral security of this offence, dependent on where this incident took place. 

We will use your information in the following ways:

• Printing your full legal name (or chosen name, if advised to us via the chosen name form), division, award type, programme of study and graduation date and time in our ceremony programme
• Calling out your name and award title (but not your result) at the ceremony if you decide to attend.
• Processing your record on our Tempest Ticketing registration system, which will contain:

Added to Tempest using data extracted from KentVision:

• Your student number
• First name and surname
• Date of birth
• Full legal name
• Your programme of study
• Your Division
• Your School
• Your award type  (i.e Bachelor of Arts with Honours)
• Your graduation date
• Your graduation time

Provided by you when you sign up for your ceremony on Tempest

• Full mailing address
• Full billing address
• Email address
• Consent preferences
• Phonetic spelling of your name

 
Processing your record on our Graduate Gowning Company webpage, which will contain:

Added to the gowning site using data extracted from KentVision

• Your student number
• First name and surname
• Your Division
• Your School
• Your award type (i.e Bachelor of Arts with Honours)
• Your programme of study
• Your graduation date
• Your graduation time

Provided by you when you hire your gown from the Graduate Gowning Company

• Height
• Hat size

Processing any visa letter requests as necessary if requested by you, these will contain:

• Your full legal name
• Date and time of your ceremony
• Programme of study
• Award type
• Names of your guests who are attending the ceremony (optional)

• Adding your full legal name, and graduation date to the Campus Clothing on the day merchandise
• Adding your mailing address, provided by you on Tempest, to the DHL mailing system to send out your certificate (International only)
• Register your contact preferences with the University after your graduation, which have been provided by you on Tempest.
• Processing your degree conferral accordingly if you have outstanding financial commitments to the University. Your financial information is provided by the Income Office to the Congregations team, if you have outstanding debts then this may prevent you from graduating.
• Processing the result of your degree accordingly.
• Using images or video of you in our specific graduation social media content or sharing photos to the University of Kent Flickr which is publicly available.
• Full video live streams of the ceremonies will be shared on YouTube and sold via the Kent Store as DVDs.
• If you have provided us with information about your specific requirements on the day, we will ensure that the necessary student support plan is put in place and process this information accordingly.

We have a contractual basis to process your personal data in relation to administering the conferral of your degree, which includes personal information which is shared with Tempest, and processing by the Congregations team of your financial commitments and result.

We have a contractual basis to provide you with your certificate, which is done either on the day of your graduation ceremony, or following the ceremony it is posted to you using the information provided by you. This requires us to process your address information to send your certificate.

We have a legitimate interest to send your full legal name to our merchandise supplier, Campus Clothing so that they can add your name to on the day merchandise.

We have a legitimate interest to record and take photos of our graduation events, for marketing materials and for sale post event. 

We rely on the following lawful basis as allowed by the UK GDPR for processing your personal data as this is necessary for:

• Our contract with you – Article 6(1)(b) (creating your record on our registration system and sending you your certificate)
• The purpose of our legitimate interests or those of a third party Article 6(1)(f) (unless those interests are overridden by your interests, rights or freedoms)
• You have given your consent for one or more specific purposes Article 6(1)(a) (your contact preferences)

We have carried out a Legitimate Interest Assessment to ensure we have a fair balance between your rights and expectations and our Legitimate Interests to process your data. You have the right to object to your data being processed in this way at any time (see Your Rights). Please note that if you object to your data being processed in this way this may impact our ability to undertake certain activities and we will explain these to you at the time so that you can make an informed decision.

When relying on Legitimate Interests, the University will protect your information rights (including those related to transparency of processing) during any related processing activity.

Our legitimate interests in the processing of your personal data include:

• to fulfil our contractual obligation of conferring your degree or award and ensuring that you receive the copy of your certificate.
• to provide you with an opportunity to attend your graduation ceremony.
• to provide you with an opportunity to purchase personalised merchandise which displays your name and year of graduation.
• To share with you the images taken on the day of your graduation by our official University photographer. 

Within the University

Your data is shared with only those University staff who need access for the purpose of conferring your degree and within the University MS Office 365 tenancy. Your personal data is held securely on the University’s systems, which is restricted to access by nominated university employees. 

With external parties – data processors

As part of the process of your graduation ceremony we will need to share some information about you with our key suppliers.

We use these third-party organisations (known as data processors) who carry out services on the University’s behalf under contract. We will ensure that only the minimum amount of relevant personal data necessary for the purpose is transferred.

We will ensure that contractual agreements exist to ensure compliance with data protection regulations and that data is used solely under our instruction. In these circumstances personal data shall be deleted after the contract has terminated.

Our ticketing supplier is Tempest Ticketing, and their website is used to collect your attendance preference. i.e. whether you will be attending, graduating in absentia or deferring your graduation ceremony to a later date.

We will share with them:

• Your student number
• First name and surname
• Date of birth
• Full legal name
• Your programme of study
• Your Division
• Your School
• Your award type  (i.e Bachelor of Arts with Honours)
•  Your graduation date
• Your graduation time

When you sign up for your ceremony on Tempest Ticketing, you will provide the following information:

• Full mailing address
• Full billing address (if purchasing tickets to attend your ceremony)
• Email address
• Consent preferences
• Phonetic spelling of your name (if you are attending your ceremony)

This information is only used to administrate your graduation and send your certificate. During the registration process you can choose your contact preferences with the University after your graduation.

Please see the Tempest privacy notice.

The Graduate Gowning Company is used for you to hire your academic gown for the day.

We will share with them the following data about you which will be extracted from KentVision:

• Your student number
• First name and surname
• Your Division
• Your School
• Your award type (i.e Bachelor of Arts with Honours)
• Your programme of study
• Your graduation date
• Your graduation time

If you hire a gown for attending on the day, you will provide them with the following data:

• Height
• Hat size

Please see the Graduate Gowning privacy notice.

Campus Clothing 

Campus Clothing will print the names of students on merchandise sold on the day of the ceremony, we will send them the list of the names of graduating students and what dates they are graduating on.

Please see the Campus Clothing privacy notice.

Mailing 

Mailing If you have chosen to have your certificate posted to you after the ceremony has happened, we will need to share your data with DHL (International) and Royal Mail (Domestic). This will be your name and full address details. 

Other than as set out in this privacy notice we will not discuss your student record or any details relating to your graduation with a third party, including parents. If you would like us to discuss your details with a third party you will need to notify us in writing using our third party consent form.  

Sometimes it is necessary for your personal information to be shared:

• with competent authorities (such as the police, NCA) or action fraud for law enforcement purposes (for on substantial public interest reasons – Article 9(2)(g) – for preventing or detecting unlawful acts, safeguarding or fraud purposes.
• with our professional advisors where it is necessary for the establishment, exercise or defence of legal claims – Article 9(2)(f).

Occasionally the University may, if appropriate, legitimate and necessary, rely on relevant exemptions to UK GDPR provisions as are allowed under the Data Protection Act 2018 (in relation to crime and taxation, management forecasts, negotiations, confidential references and exam scripts and exam marks).

When it is necessary for us to transfer your personal information across national boundaries to a third-party data processor, such as one of our service providers, we will ensure this safeguards your personal information by requiring such transfers are made in compliance with all relevant data protection laws.

When it is necessary for us to transfer your personal information across national boundaries to a third-party data processor, such as one of our service providers, we will ensure this safeguards your personal information by requiring such transfers are made in compliance with all relevant data protection laws.

Tempest will destroy all information held about you after the ceremonies. The graduations team follow the University’s Documentation Retention and Archiving Policy.

We will only keep your address information if you have given us consent to contact you as a member of our alumni community. This consent will be gathered when you register for you graduation ceremony.

If you provide consent to be contacted as a member of the alumni community, your data will be added to our alumni database. Please see our alumni privacy policy for further information about how we would use the data after graduations.

Following the graduation ceremonies information provided is destroyed. 

The University of Kent will ensure that security measures are in place to prevent the accidental loss, unauthorised use, or access to your data. Access is given to staff on a ‘need to know’ basis. Our staff are required to keep your data safe and complete data protection training.

We have procedures in place to deal with any data security incidents and will notify you and the ICO in the event of a data breach where we are required to do so.

Tempest Ticketing and Graduate Gowning Company (H Tempest) data storage

All student data is stored on H Tempest’s data servers which are held on premises physically secured in their data centre monitored by CCTV.

H Tempest uses the following security mechanisms: encryption, backups, audit logs, detection and response tools and firewalls which actively detect and blocks intrusions.

Campus Clothing data storage: Campus Clothing, Unit 29, Blick Road, Heathcote Industrial Estate, Warwick, CV34 6TA.

Where our lawful basis for processing your data is Legitimate Interests, then you have the right to opt out to us undertaking this activity. 

This refers to your name being included in the Campus Clothing merchandise and the Congregations programme or photography at the ceremonies. There will be a deadline to opt out of this which is shared with you in your graduation invitation and on our webpages.

Please contact graduations@kent.ac.uk to opt out of displaying your name, when you receive your graduation invitation you will provided with the deadline by which you must let us know that you wish to opt out. 

To fulfil our contractual requirement to confer your degree or award and provide you with an opportunity to attend your graduation ceremony, we need to use your data alongside Tempest and the Graduate Gowning Company.

Please be aware of the following rights which can be accessed free of charge by contacting dataprotection@kent.ac.uk:

·       know how we are using your personal information and why (right to information)

·       access the personal data held by us (subject access request)

·       ask for correction of any mistakes (rectification)

·       to object to direct marketing

·       to complain to the ICO

In some circumstances you also have the right to:

·       object to how we are using your information

·       ask us to delete information about you (the right to be forgotten)

·       have your information transferred electronically

·       object to automated decisions which significantly affect you

·       restrict us from using your information.

For further guidance regarding your rights please see the ICO website.

Your rights- if you have given consent or explicit consent for a specific use of your personal data

You can withdraw your consent at any time.

You can do this by contacting us at graduations@kent.ac.uk.  

This does not affect the lawfulness of the processing based on consent before its withdrawal.

Your right to complain to the Information Commissioner

You have the right to lodge a complaint with the Information Commissioner's Office.

Their helpline telephone number is: 0303 123 1113.

If you are unsatisfied with how we process your data, please contact us and we will try and put things right. If you feel that we have failed to resolve the issue to your satisfaction, you can refer the issue to the Information Commissioner’s Office who can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

Web: https://www.ico.org.uk