Privacy notice

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

The University has a legal obligation to ensure that all students have immigration permission to study with us. As part of this, we need to collect and store some personal and immigration information. 

Your personal data is obtained in the following ways when necessary to comply with our legal obligations around immigration rules:

• directly from you, through online or paper forms, email or by telephone when you apply to us for a course of study, and at registration when you apply for a CAS or visa
• from you directly (or your school) where we need medical evidence relating to prolonged periods of absence or you make an appeal
• from UK Visas and Immigration at the Home Office when information is required to establish your immigration permission as a new entrant or continuing student
• from the Foreign and Commonwealth and Development Office (where clearance is required under the Academic Technology Approval Scheme ‘ATAS’)
• from your parents or other financial sponsors
• from Kent Vision or your school or department when we require information about your attendance and academic engagement
• From HR if you are student who is also employed by the University of Kent (so that we can comply with legal obligations).

Personal data we collect about you in connection with ensuring immigration permissions:

• your name
• your address (home and term time)
• telephone and mobile number
• email address (Kent and personal)
• financial information (bank account statements or confirmation of financial sponsorship)
• your student ID or your Confirmation of Acceptance for Studies (‘CAS’) ID
• birth certificate, passport number and expiry date, permit, ATAS certificates and visa documentation or correspondence required to meet immigration rules
• your appeal form and evidence (if applicable).

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

• racial or ethnic origin
• physical or mental health data

Criminal offence data: details of any criminal court proceedings or sentencing data (where applicable or raised in correspondence with us). 

The Student Immigration Compliance Team have a legal obligation to ensure that all students have immigration permission to study at the University of Kent.  This includes the following categories of immigration permission:

• Students holding a Student route visa
• Students holding time limited immigration permission
• Students holding short term study visas
• Students holding any other type of immigration permission.

We will use your information in the following ways:

• to ensure the University is complying with and discharging its duties under all aspects of the Immigration Rules and sponsor guidance. 
• In accordance with the terms and conditions of sponsorship or registration waiver (whichever is applicable)
• to consider your case or appeal
• for management reporting.

As we have a statutory basis to process your personal data if you do not provide this information we will be unable to process your application to the University. If information regarding UK immigration permission is not provided, this may result in deregistration from the University.

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 (terms and conditions of student sponsorship)– Article 6(1)(b)
• a legal obligation – Article 6(1)(c)
• the performance of a task carried out in the public interest or in the exercise of official authority -Article 6(1)(e)

As we also use your special category data, we must identify a further basis for processing that data. The processing is necessary for: 

• reasons of substantial public interest (as defined within the Data Protection Act 2018)– Article 9(2)(g). 

Our substantial public interest reason(s) is/are:

• statutory purposes
• prevention or detection of crime

As we also use your criminal offence data, we additionally rely on the employment condition in section 1 Part 1 and the extension of the public interest conditions in section 36, Part 3 of Schedule 1 of the Data Protection Act 2018.

We have a Special Category and Criminal Offence Data Appropriate Policy document in place throughout the time that we use your data and for 6 months after we cease to use it. This Appropriate Policy Document can be viewed on our policies and procedures webpage.

Sometimes it is necessary to share your personal information to ensure that we meet our legal sponsorship obligations.  For example, we share internally with:

• University of Kent employees for the purposes of acting as your immigration sponsor.

We use third party organisations (known as data processors) who carry out services on the University’s behalf under contract and on our instructions. 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 is deleted after the contract has terminated

• Microsoft. 

We share your personal data with:

• UK Visas and Immigration (UKVI) for the purposes of discharging our legal obligations.

For more information please see their privacy notice: 

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.

Microsoft store Kent data within the EEA although may transfer the data if necessary to one of its third party sub-processors elsewhere.

The transfer is authorised by:

• adequacy regulations made by the Secretary of State
• safeguards prescribed by the UK GDPR

We keep most information until the end of your visa sponsorship +2 years. 

Financial evidence details are only kept until your CAS application is granted and your CAS application is kept only until  your visa is granted (at which point these are securely destroyed).

Management reporting information (reports from UKVI or spreadsheets reporting to management) are kept until the last action on the file + 6 years

We 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.

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.

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

Their helpline telephone number is: 0303 123 1113.

If you have any questions or concerns about the way the University has used your data, or wish to exercise any of your rights, please consult our website.

The University’s Data Protection Officer can be contacted at: dataprotection@kent.ac.uk

This privacy notice will be reviewed at least annually.