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About Us and this Policy

Hibernia College Unlimited Company is a private unlimited company incorporated in Ireland with company number 328066 and having its registered office at Block B, The Merrion Centre, Merrion Road, Dublin 4, Ireland (“Hibernia College” or “we” or “us” or “our” and is inclusive of any member company within our group, which means any subsidiary or holding company with the meaning of section 7 and 8 of the Companies Act 2014). We are Ireland’s first and only accredited online third-level institution. We are an established leader in pioneering new education technologies.

Hibernia College is committed to protecting and respecting your privacy and we take our responsibilities seriously in relation to the processing of personal data. This Privacy Statement (the “Policy”) (together with our Terms and Conditions of Website Use and any other documents referred to) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the Policy carefully as it sets out important information about how we process your personal data and your rights.

For the purpose of the General Data Protection Regulation EU 2016/679 (the “GDPR”) and the Data Protection Act 2018, and unless we have entered into a different arrangement or agreement with you, Hibernia College is the controller of the personal data you provide to us.

Any questions relating to or requests under this Policy should be directed to our Data Protection Officer, whose contact details are below:

Data Protection Officer
Hibernia College Unlimited Company
Block B
The Merrion Centre
Merrion Road
Dublin 4
Ireland
DPO@hiberniacollege.net

Your Personal Information

We will collect and process the following data about you:

Information you give us

This is information about you that you give us by filling in forms on our web-sites or by corresponding with us by telephone, by post, by e-mail or online via any platform, or by submission of papers or other documents to us. It also includes information about you that you provide to us when you:

  1. use or register to use our web-sites;
  2. search for or make enquiries in relation to any of our educational programmes, courses, projects, events or services;
  3. apply, register for, undertake and/or attend any educational programme, course or project with us, undertake a work placement (including during or in relation to any application, course, placement or assessment);
  4. make comments or provide feedback, suggestions or other submissions to us in relation to our web-sites, our educational programmes, courses, projects, events or services;
  5. report a problem with our web-sites or our Services.

More specifically, and depending on the nature of your query or relationship with us, this can include the following information:

  • Identity Data: your name, address, e-mail address, home or work address or telephone number, date of birth, country of birth, PPS number, personal description and photograph.
  • Medical Data: your medical certificate, medical reports and data concerning your health.
  • Financial Data: your financial data, including bank account details you may provide to us.
  • Assessment Data: the transcripts of any assessment undertaken by you, as a registered student of Hibernia College, during the course of your studies with us to the extent it relates to you and incorporates your personal data.
  • Testimonial Data: interviews, questionnaires and testimonials you may provide to us in relation to our educational programmes, courses, projects, events or services and your experience with, or views of, them or us.
  • Professional and/or Academic References: provided by third parties in respect of your professional or academic performance.
  • Engagement and Attendance Data: a record of your attendance in person or online in any class, or form of instruction; and a record of your participation in teaching, learning and assessment activities.

 

Information we collect about you

Technical information and usage data, including cookies.

Our web-sites use cookies. This means when you visit our web-sites we collect certain technical information and usage data about your visit to and use of our web-sites.  This is described more below.

  • Technical Information: including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, domain names, operating system and platform, how often you use the website and other performance data.
  • Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our web-sites (including date and time), materials you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any telephone phone number used to call us.

Cookies:   Our websites uses cookies to distinguish you from other users of our web-sites. This helps us to provide you with a good experience when you browse our web-sites and also allows us to improve our web-sites. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you register with a Hibernia College web-sites or services, a cookie helps the web-sites to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses and so on. When you return to the same web-sites, the information you previously provided may be retrieved.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Hibernia College services or web-sites you visit.

 

Information we receive from other sources about you

Postgraduate Applications Centre

The Postgraduate Applications Centre processes applications to some of our programmes and we may receive the following information about you:

  • Identity Data: your name, address, e-mail address, home or work address or telephone number, date of birth, country of birth, PPS number, personal description and photograph.
  • Medical Data: your medical certificate, medical reports and data concerning your health.
  • Assessment Data: the transcripts of any assessment undertaken by you, during the course of your previous studies to the extent it relates to you and incorporates your personal data.
  • Professional and/or Academic References: provided by third parties in respect of your professional or academic performance.

 

Garda Vetting

We have a responsibility to ensure that persons who will carry out work or an activity with children or other vulnerable persons are vetted to ensure they are suitable for that role. This involves making an application to the appropriate law enforcement authorities, which in Ireland is An Garda Síochána or its scheduled organisation.

This process involves making enquiries with the authorities to establish whether there is any criminal record or specified information relating to that person. This will be relevant, for example, for our staff, teachers and student teachers who will carry out work or an activity with children or other vulnerable persons, during the course of any student teacher training or practice.

This type of information is categorised and referred to in this Policy as:

  • Garda Vetting Data: information about you received from the National Vetting Bureau which we are obligated to obtain by law. This data relates to criminal records and/or related information.

How we use your Personal Information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform a contract we are about to enter into or have entered into with you.
  • where it is necessary for our legitimate interest (or those of a third party, to include but not be limited to Quality and Qualifications Ireland; the Higher Education Authority; the Department of Education and Skills; the Nursing and Midwifery Board of Ireland; any other Professional, Regulatory or Statutory Body) and your interests and fundamental rights do not override those interests.
  • where we need to comply with a legal or regulatory obligation.

We have set out in the table below a description of the ways we plan to use your personal data and the legal basis we rely on to do so. We have also identified our legitimate interests where appropriate:

How we use your personal information
Purpose/ActivityType of dataLegal basis for processing

To respond to your queries and to provide you with the information you request from us in relation to our programmes, courses, events, projects or services (together the “Services”)


  • Identity Data
  • Technical Data
  • Usage Data


  • Necessary for our legitimate interests (to respond to new or existing customer queries and grow our business)
  • Performance of a contact with you


To provide the Services, including but not limited to Services in relation to the provision of higher education


  • Identity Data
  • Assessment Data
  • Financial Data
  • Technical Data
  • Usage Data
  • Garda Vetting Data
  • Medical Data
  • Professional and/or Academic References Data
  • Engagement and attendance data


  • Necessary for our legitimate interests (to respond to new or existing customer queries and grow our business)
  • Performance of a contract with you
  • Compliance with a legal obligation
  • Consent, and in the case of Medical Data explicit consent

To obtain from our insurers a learner protection bond


  • Identity Data


  • Necessary for our legitimate interests (to ensure appropriate protective cover in relation to enrolled students’ fees)
  • Performance of a contract with you
  • Compliance with a legal obligation


To process your application and registration for higher education courses


  • Identity Data
  • Financial Data
  • Garda Vetting Data
  • Medical Data
  • Professional and/or Academic References Data


  • Performance of a Contract
  • Consent, and in the case of Medical Data explicit consent
  • Compliance with a legal obligation


To recruit and engage with you as an adjunct faculty member


  • Identity Data
  • Garda Vetting Data
  • Professional and/or Academic References Data
  • Financial Data
  • Engagement and Attendance Data


  • Performance of a Contract with you
  • Compliance with a legal obligation


To vet persons who will carry out work with children or vulnerable adults and to make enquiries with the relevant authorities for these vetting purposes


  • Identity Data
  • Garda Vetting Data


Compliance with a legal obligation


To assess learner’s performance and attainments in the provision of the Services


  • Identity Data
  • Assessment Data


Performance of a Contract


To manage payments, fees and charges, to make payments and to collect and recover money owed to us.


  • Identity Data
  • Financial Data


  • Performance of a contract with you/li>
  • Necessary for our legitimate interests (to recover debts due to us)


To manage our relationship with you, including notifying you about changes to the Services, or our Privacy Policy.


  • Identity Data
  • Technical Data
  • Usage Data
  • Engagement and Attendance Data


  • Performance of a contract
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services).


To provide you with information about services we offer that are similar to those that you have enquired about.


  • Identity Data
  • Technical Data
  • Usage Data


Necessary for our legitimate interests (to develop our products or Services and grow our business)


Where you have given us your consent to do so, to provide you with information about other services we feel may interest you.


  • Identity Data
  • Technical Data
  • Usage Data


Consent


To ensure that content is presented in the most effective manner for you and for your computer or device.


  • Identity Data
  • Technical Data
  • Usage Data
  • Engagement and Attendance Data


Necessary for our legitimate interests (to keep our Site and the Services updated and relevant and to develop and grow our business).


To administer and protect our business, our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.


  • Identity Data
  • Technical Data
  • Usage Data
  • Engagement and Attendance Data


Necessary for our legitimate interests (for running our business and as part of our efforts to keep our Site and the Services safe and secure)


To use data analytics to improve or optimise our Site, programmes, marketing, customer and student customer relationships and experiences.


  • Technical Data
  • Usage Data
  • Identity Data
  • Assessment Data
  • Engagement and Attendance Data


Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).


To measure or understand the effectiveness of advertising we serve to you and others, and, where applicable, to deliver relevant advertising to you.


  • Identity Data
  • Technical Data
  • Usage Data


Necessary for our legitimate interests (to study how customers use our products or Services, to develop them, to grow our business and to inform our marketing strategy).


To conduct surveys, questionnaires and carry out research in relation to the Services and improvements that can be made to the Services


  • Identity Data
  • Assessment Data
  • Engagement and Attendance Data


  • Necessary for our legitimate interests (to improve the Services offered by us)
  • Consent, where the research may involve the participation of others, including students and children

Research Projects

As a higher education institution and as individual academics, we undertake programmes of research to explore and investigate new methodologies, technologies and practices that are relevant to and may improve, or deepen our understanding of the discipline fields or knowledge areas in which we participate.

Specifically, within the School of Education, research may be undertaken in collaboration with our research partners and participating schools, including for example, in relation to student-teachers’ “opportunit[ies] to learn about teaching and learning, to gain practice in teaching, to apply educational theory in a variety of teaching and learning situations and school contexts and to participate in school life in a way that is structured and supported”.  (Teaching Council (2013), Guidelines on School Placement.)

In all cases these projects are undertaken on consultation with the schools and ensuring that all parties are fully informed before deciding to participate. This is especially important to us where children are concerned and ensuring that parents and guardians are fully informed and that they, and indeed their children, are willing to participate.

We publish general details about our research projects at https://hiberniacollege.com/research/ or if you require more information about a particular research project please contact us at info@hiberniacollege.net.

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 at DPO@hiberniacollege.net.

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 this Policy, where and to the extent this is required or permitted by law.

How long we keep your Personal Information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

This means that the period of time for which we store your personal data may depend on the type of data we hold. 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 requirements.

For more information about our data retention policies, please contact us at

Our servers are currently located in Ireland and those of our authorised third party SaaS providers are currently located in Ireland, the UK and the US.

In certain circumstances or for certain projects, the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by persons operating outside the EEA who work for us or for one of our suppliers or educational partners. This includes staff engaged in, among other things, the assessment of examinations, the processing of your payment details and the provision of relevant placements (including secondments or collaborations with other (including international) schools or universities) and/or the provision of support services.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. There are special requirements set out in Chapter V of the GDPR (with which we comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer.

For more information about this and the safeguards in place relating to any such data transfer that may be relevant to you, please contact us by email at DPO@hiberniacollege.net.

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Who we share your Personal Information with

We do not sell, rent or lease our student lists to third parties. With your permission, we may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. We may also share data with trusted partners to help us perform statistical analysis, send you e-mail or postal mail, provide technical support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your information.

Please also keep in mind that if you disclose personally identifiable information or personally sensitive data through any Hibernia College or other public message boards, this information may be collected and used by others, and as such Hibernia College has no control or responsibility over this information.

Message boards provided on MyHELMS are password protected and open to registered students, staff and faculty members of Hibernia College, who as part of their relationship with Hibernia College, undertake to treat information sensitively mindful of privacy obligations.

We do not use or disclose sensitive personal information about you, such as race, religion, or political affiliations, without your explicit consent. To the extent your medical information or health data is provided to us in connection with any application, registration, performance, examination or placement by you under any course offered by Hibernia College, this sensitive personal information will not be disclosed without your explicit consent.

 

You agree that we have the right to share your personal information with the following recipients or categories of recipients:

  • any department or appointed authorised person within our company or any member company within our group, which means any subsidiary or holding company within the meaning of sections 7 and 8 of the Companies Act 2014;
  • any governmental, financial or regulatory body, agency or department;
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in relation to the Services, including insurers; adjunct faculty;
  • research partners including participating schools, healthcare providers and/or higher education institutions in Ireland and abroad in relation to any project or placement you undertake or agree to participate in;
  • Selected third parties including the Garda Vetting Unit and educational partners, including but not limited to Quality & Qualifications Ireland, the Teaching Council and the Nursing and Midwifery Board of Ireland, as well as other Professional, Regulatory or Statutory Bodies in connection with the performance of any contract we may enter into with you;
  • analytics and search engine providers that assist us in the improvement and optimisation of our web-sites, as contemplated above.

 

We will disclose your personal information to third party recipients:

  • in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
  • if Hibernia College or substantially all of its assets are acquired by or transferred to a third party whether in the event of a merger, reorganisation, transfer of undertakings, receivership, liquidation or other winding up or any other similar circumstances, in which case personal data held by us will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or court order, or in order to enforce rights under the law, our Terms and Conditions of Website Use or any other agreements;
  • to protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of maintaining the security of the web-sites and services.

Keeping your Personal Data accurate and up-to-date

To help ensure that the personal information you give to us is accurate and up-to-date, you agree to notify us of relevant updates or changes, as required.

Where we store your Personal Data

Our servers are currently located in Ireland and those of our authorised third party SaaS providers are currently located in Ireland, the UK and the US.

In certain circumstances or for certain projects, the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by persons operating outside the EEA who work for us or for one of our suppliers or educational partners. This includes staff engaged in, among other things, the assessment of examinations, the processing of your payment details and the provision of relevant placements (including secondments or collaborations with other (including international) schools or universities) and/or the provision of support services.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. There are special requirements set out in Chapter V of the GDPR (with which we comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer.

For more information about this and the safeguards in place relating to any such data transfer that may be relevant to you, please contact us by email at DPO@hiberniacollege.net.

Security of your Personal Data

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. For example, all information you provide to us is stored on our secure servers. Any payment transactions will be protected through the use of encryption, such as Secure Socket Layer (SSL) protocol and SSL technology.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our web-sites; any transmission is at your own risk. 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.

Your Personal Data and Your Rights

Accessing your personal data. You may seek access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to DPO@hiberniacollege.net. We will need to verify your identity and request more information or clarifications from you if needed to help us locate and provide you with the personal data requested.

There is usually no charge applied to access your personal data (or to exercise any of your other rights within this Policy). However, if we believe your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.

 

Right of Restriction. You may restrict us from processing personal data in any of the following circumstances:

  • you have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data;
  • the processing of your personal data is unlawful and you request the restriction of use of the personal data instead of its erasure;
  • we no longer require your personal data for the purpose of processing but you require this data for the establishment, exercise or defence of legal claims; or
  • where you have contested the processing (under Article 21(1) of the GDPR) pending the verification of our legitimate grounds.

 

Corrections or Erasure (Right to Rectification and Right to be Forgotten). If we hold personal data concerning you which is no longer necessary for the purposes for which it was collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at DPO@hiberniacollege.net.

 

Your Right to Object. You have the right to object to the processing of your personal data at any time:

  • for direct marketing purposes
  • for profiling to the extent it relates to direct marketing
  • where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights and freedoms or in connection with the enforcement or defence of a legal claim.

To exercise your right to object at any time, please email DPO@hiberniacollege.net.

Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.

 

Data Portability. Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller.

 

Profiling. Profiling is an automated form of processing of personal data often used to analyse or predict personal aspects about an individual person. This could relate to a person’s performance at work, economic situation, health, personal preferences, reliability, behaviour, location or movements. An example of this would be where a bank uses an automated credit scoring system to assess and reject a loan application.

We do not engage in profiling or automated processing for profiling purposes.

 

Personal Rights. The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned.

Marketing Communications

General. We will not use your data to send marketing communications to you about promotions, competitions, updates and new products or services that may be of interest to you, unless we have your permissions to do so.

 

Your right to object. You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at DPO@hiberniacollege.net. You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal.

Third Party Material

We always endeavour to deal with vendors and other third parties who are GDPR compliant or, in the case of the third parties located outside of the EEA, who are certified as compliant with the EU-US Privacy Shield, as applicable, or who have adequate security measures in place to safeguard the security of personal data. That said we, our employees, agents, holding company and subsidiaries, accept no liability howsoever arising for the content or links to and from the websites of our partner networks, advertisers (including recruiters) and affiliates and other links to educational and informational material and updates that may be helpful or relevant to you or your course of study, the reliability of any third party materials or websites referenced by hyperlink or other means on the web-sites or for the data collection and use practices or security measures used by such third parties. If you submit personal data to any of those web-sites, your personal data is governed by their privacy policy. We encourage you to carefully read their privacy policies.

Changes to this Policy

Any changes we make to our Policy in the future will be posted on this site.

Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data, will be notified to you in advance by email. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights under the GDPR in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit.

Contact Information

Contact us. If you have any questions or complaints relating to this Policy, please contact our Data Protection Officer at:

Data Protection Officer
Hibernia College Unlimited Company
Block B
The Merrion Centre
Merrion Road
Dublin 4
Ireland
Email: DPO@hiberniacollege.net

 

Supervisory Authority. We are committed to complying with the terms of the GDPR and to the processing of personal data in a fair, lawful and transparent manner. If, however, you believe that we have not complied with our obligations under the GDPR, you have the right to lodge a complaint with the Data Protection Commission, Canal House, Station Road, Portarlington, County Laois, Ireland.