Summary of significant changes since last version
• We have consolidated previous supplementary privacy notices (for different activities and cohorts of students) into this one document. We have also moved sections around to make things clearer. Supplementary notices now incorporated into this document include those for Apprentices, Nursing, Social Work, non-medical prescribing and advanced clinical practice qualifications, PGCE (Wales), the Young Applicants in Schools Scheme, and Students in Secure Environments.
• We have provided further information about sharing data with, and receiving data from, curriculum and teaching partners, and we have added information about data sharing with our wholly owned subsidiaries OU Worldwide and Open University Student Budget Accounts (OUSBA).
• We have made some amendments to the lawful bases we are relying on: some activities have changed from “legitimate interest” to “public task” for consistency, we have amended our basis to “legitimate interest” where we share data with media providers to display targeted advertising; and we have provided additional information about where consent is required.
• We have made some clarifications, including:
• explaining automated calculations relating to student results.
• international processing of data relating to the UKs withdrawal from the EU.
• Data sharing with funding bodies, including organisations such as Santander.
• Data sharing with third parties for Students in Secure Environments.
• We have included bag searches and testing for illegal substance as potential activities, where personal data may be captured.
• Generally, the Open University will not be the data controller for data collected by taught students in the course of their studies.
• We have clarified where data may be shared with employers for work-based learning and apprentices.
• Minor amendments, June 2023, to make provision for students studying through The Open College of the Arts (Appendix 3); and regarding the location of our cloud-based services (5.2).
• Minor amendments, January 2024, to update information about the information we collect or create about you, share with sponsors, and use to support you.
