[Last updated: May, 2023]
1. Important information and who we are
Name: Carlos Sá, Executive Director, LSDM
Email address: [email protected]
Postal address: Tower 42, 25 Old Broad St, London EC2N 1HN, United Kingdom
Telephone number: +44 788 348 4763
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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 do contact us in the first instance.
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.
2. The data we collect about you
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:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth, gender, nationality and passport or other identity documents.
- Contact Data includes contact address, email address and telephone numbers.
- Academic Qualifications includes school, college, university qualifications and any other educational qualifications requested or submitted and proof of them, other previous qualifications and educational institutions attended.
- Academic Progress includes your participation in learning and assessment activities and your use of LSDM courses, information about your academic progress, grades and academic appeals.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services, including online study courses, you have purchased from us.
- 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 this website.
- >Profile Data includes your username and password, purchases or orders made by you, including online study courses, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and service.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). In particular we may ask for information about any health conditions or disabilities to enable us to provide our courses and services to you in an accessible way. Information you give us about any health conditions or disabilities and special requirements will also be used to inform the provision of reasonable adjustments for your study.
You may submit additional Special Categories of Personal Data to us, for example information about your religion relating to special circumstances for an examination, or information pertinent to an enquiry or complaint. We only just this information for the purpose for which it was provided in order to perform the contract we have with you and to comply with our legal obligation to provide adjustments for students with disabilities and a duty to advance equality of opportunity.
We may collect information about criminal convictions and offences in line with the requirements in place from our degree issuing partners and regulators (example: University for the Creative Arts, Office for Students). We use this information to ensure a safe environment and may need to restrict your access to our services as a result of this information. We treat information about criminal convictions and offences with the same level of protection as the Special Categories of Personal Data.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with information about our courses or enrol you on a course). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. 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 Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to enrol in one of our courses/online study modules;
- apply for any other of our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- carry out a student satisfaction survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Identity, Contact and Qualification Data from our agents outside the UK in your country or region who pass your details to us where they have identified you as a potential student and/or you have expressed an interest in our courses to our local agents.
- Technical Data from the following parties:
- analytics providers such as Google based outside the UK;
- advertising networks such as Kwanko based outside the UK; and
- search information providers such as Google based outside the UK.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and Paypal, as detailed under External Third Parties in the Glossary, based outside the UK.
- Identity and Contact Data from publicly available sources such as the Electoral Register based inside the UK.
4. 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 contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sharing your data with our group companies for marketing purposes or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing 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 of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please be aware 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.
|Type of Data
|Lawful basis for processing including basis of legitimate interest
|To book an interview or appointment
|Performance of a contract with you (pre-contractual arrangements)
|To register and enrol you as a new student
|Performance of a contract with you
|To process and deliver your registration and enrolment including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage, administer and deliver the course(s) to you
(a)Notifying you with information about the course(s) you have enrolled on
(b)Administering and delivering the course(s) to you
Maintaining your student record
(d) Academic Qualifications
(e) Academic Progress
|(a)Performance of contract with you
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how students and users use our courses/services, to improve the quality of teaching and learning)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(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 and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how students and users use our courses/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about courses or services that may be of interest to you
Marketing and Communications
|(a) Necessary for our legitimate interests (to develop our courses/services and grow our business)
(b) Consent (with your explicit consent to pass your details to other LSDM group companies)
|To allow our local agent in your country or region to contact you about the interest you have shown in LSDM and/or our courses
(c) Marketing and Communications
|Necessary for our legitimate interests (to grow our business)
|To ensure you receive an accredited degree qualification from the University for the Creative Arts
(c) Academic Qualifications
(d) Academic Progress
|(a) Performance of contract with you
(b) Necessary for our legitimate interests (as a provider of accredited Masters and Bachelors degree courses)
Contacting you where you have expressed an interest in LSDM
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We aim to only send you relevant marketing information that accords with what you have told us you want to know and receive and in line with the interest you have shown in our courses. You can contact us at any time to let us know you want to change any of your marketing preferences.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or applied to enrol on a course at LSDM or become a student of LSDM by paying any applicable course fees, and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your enrolment in a course or any other service we are currently providing to you.
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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- Internal Third Parties as set out in the Glossary: https://lsdmlondon.com/global-privacy-policy/glossary/internal-third-parties
- External Third Parties as set out in the Glossary: https://lsdmlondon.com/global-privacy-policy/glossary/external-third-parties
- Specific third parties such as:
- local agents in your country or region as explained above in the section Contacting you where you have expressed an interest in LSDM;
- The University for the Creative Arts who is the awarding body for LSDM’s Masters and Bachelors courses and which accredits, validates and approves these undergraduate and postgraduate courses; and
- other LSDM parent group companies who wish to be able to send you marketing information about the educational courses or similar services they offer. We only share your details in this way where you have given your explicit consent to such sharing.
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, with the exception of our local agents with whom we may share your personal data and our local agents are data controllers for this purpose. This is because they decide how to use your personal data as appropriate for your country or region in order to contact you or to ensure you are not contacted both by LSDM directly and the local agent at the same time, which may be annoying.
6. International transfers
We share your personal data within the LSDM Group. This will involve transferring your data outside the UK but within the EEA.
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. We only use external third parties that are based within the EU and your data is not transferred outside the EU.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring your personal data is only transferred to countries that have been deemed to provide an adequate level of protection for personal data and this includes all countries in the EU.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. 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, 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Records of potential new students are kept for one year after the information is collected. At the end of this period a new consent request is sent to maintain or delete the record.
Student records will be stored according to the following categories:
Medium Term Retention (up to five years after completion of the course): upon leaving the study programme, LSDM will maintain records of students regarding participation, mentoring, assessments, results, general and specific feedback of the assessment; and
Permanent Retention: LSDM will retain only the data necessary to identify the student and confirm the dates they took the course, the grade received and the transcript of their grades.
By law we have to keep basic information about our students (including Contact, Identity, Financial and Transaction Data) for six years after they leave LSDM for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information. https://lsdmlondon.com/global-privacy-policy/glossary/
In some circumstances we will 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.
9. Your legal rightsUnder certain circumstances, you have rights under data protection laws in relation to your personal data. To find out more about legal rights go to https://lsdmlondon.com/global-privacy-policy/glossary/
To request changes regarding your personal data, use the following link: https://support.lsdmlondon.com/support/tickets/new~
- Request access to your personal data
- Request correction 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
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 could 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 could 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.