Privacy Policy

DATA Controller

This website is operated on behalf of Berlin School of Business and Innovation, a company registered in Germany with number 190515 with its registered office at Alte Post Karl-Marx-Straße 97-99 12043 Berlin Germany.

Berlin School of Business and Innovation is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found here (https://www.globaluniversitysystems.com/).

We have appointed a data protection officer (DPOs) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Full name of data controller legal entity: Berlin School of Business and Innovation

Name or title of DPO:  FAO Data Protection Officer (Alina Gog)

Email address: dpo@berlinsbi.com
Postal address: Alte Post Karl-Marx-Straße 97-99 12043 Berlin Germany
Telephone number: +49 3058 584 0959

You have a right to complain to the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit) about the way in which we process your personal data. Complaints can be filed in electronic form at  https://www.datenschutz-berlin.de//. We consider this the lead supervisory authority for BSBI.

We would always prefer that you come to us to help address any concerns of a privacy nature however before you go to the Berlin Commissioner for Data Protection and Freedom of Information, so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 09 November 2021 and historic versions can be obtained by contacting us.

We may from time to time change the detail in this notice.  Any changes we may make in the future will be posted on this page.  Please check back frequently to see any such updates or changes.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. Anonymous data is therefore not treated as personal data.

We have grouped together different kinds of personal data which we may collect, use, store and transfer as follows:

Academic Data includes eligibility data including education and academic history, training records, qualifications, personal statements, CVs, personal achievements and references.

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, NI number, Unique Learner Number, nationality, residency status, disability declaration, criminal conviction declaration, third party student reference number where that third party shares your data with us, (eg UCAS, HESA and similar such organisations), photographic images.

Contact Data includes billing address, term-time and permanent residential address, country of residence, email address and telephone numbers.

Emergency Contact Data about next of kin names and contact details for use when there is an emergency that has involved you.

Employment Data (if you are sponsored by your employer) includes employer details, start date, end dates, NI number, your job title, contact details at work (email address, telephone number and postal address).

Financial Data includes student loan information, bank account and payment card details.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences as part of the BSBI community as a prospective student, enrolled/current student or alumni, staff, applicant or former employee.

Profile Data includes any of your usernames and passwords, enquiries made by you, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Student Data includes your term time and home address, ID photo, subject of interest, chosen BSBI course or BSBI programme, your progress data and your results (coursework and exam, including mocks), other results from before final study years, exam scripts and transcripts, your attendance, lecturers’ and tutors’ feedback on you or your staff (if you are a corporate) (student references), communications with BSBI, the extent of your use of any learning facilities / services by BSBI, information relating to your use of the BSBI library resources (including materials checked out and overdue items), data about your membership of student groups, associations and any event attendances), information regarding mentor and mentee data, and your membership of any relevant alumni network, data around your taking part in events hosted by us or advertised by us, learner analytics and profiling data, any disciplinary data, student, course, or tutor- related complaints data and any claims involving you of any nature whatsoever, extenuating circumstances, appeals, additional information as required by professional/accreditation/awarding body

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes your 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.

Usage Data includes URL data, web analytics data in relation to how you arrived at our sites, from where, what search items you looked for, which pages you visited on our sites, the duration of your visits and such other information about how you use our websites and the information provided on them, and how you use our products and services so as to assist us to improve our website offering to you.

Visa Data for international students, including passport and previous visas data, bank statements or other financial information for satisfying ourselves that visa requirements are met.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Category Data, when you make an application on our website for a course or programme we will ask whether you have any disabilities. You are not obliged to inform us but any information you do provide will assist us to assess how we will meet our statutory obligation in relation to your disability.

Criminal Offence Data, for the purposes of compliance with our Safeguarding Policy, we may ask for DBS checks or seek criminal records information.  This type of data is regulated under the GDPR and we ensure that we limit the use of any such data both in time and in scope and that we meet appropriate lawful grounds for processing such data.

For further information please contact us at dpo@berlinsbi.com

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 goods or services). 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.

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 communicating with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Apply for our products or services;
• Create an account on our website;
• Use our site;
• Subscribe to our service or publications;
• Request marketing to be sent to you;
• Enter a promotion or survey; or
• Give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

 

Technical Data from the following parties:

• Analytics providers such as Google analytics, Google optimizer, Google Webmaster tools, Google tag manager, Facebook, Instagram and Conversant based out of Europe & Convertr Media based in UK and other similar services which we will be using in the future;
• Advertising networks such as Google Advertising Network, Facebook, Instagram, Bing and Linkedin based outside the EU and similar network we will be partnering with; and
• Search information providers such as Google, Bing and other search engines based inside and outside the EU, social media networks such as Facebook, Linkedin and Instagram, based inside the EU and others providing similar services.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Conversant, Google Analytics, Facebook, Instagram, Bing, Linkedin and Stripe, based outside the EU and Convertr Media based inside the UK including similar services we will partner with in future.
• Identity and Contact Data from data aggregators. 
• Identity and Contact Data from publicly available sources such as the Electoral Register based inside the EU.
• Student Data from staff, administrative functions of other educational establishments, mentees or mentors, complainants.
• Academic, contact, identity, marketing and communications and technical data from:
  • Publishers, who are owners of private websites, and are based in and outside Europe and
  • Agents, referring organisations such as other universities and UCAS.

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 or regulatory obligation.

Please see the table below to find out 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 other than in relation to sending direct marketing communications to you via email or SMS. You have the right to withdraw consent to marketing at any time by contacting us at dpo@berlinsbi.com or by clicking the unsubscribe link in the relevant emails.

We have set out below 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.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
Students or prospective students
To respond to your request for a call (or email) back, course enquiries, applications	(a) Contact Data	Performance of a contract with you (in our anticipation of entering into such contract with you)
To enroll / register you as a new candidate and provide student number / identity card	(a) Identity Data (b) Contact Data (c) Academic Data	Performance of a contract with you
Direct marketing of or about student benefits and opportunities, University activities and events, services or career opportunities and professional and industrial bodies wishing to communicate with students about career opportunities. Promotion of University or school via prospectus containing images of current students. Direct marketing may include cookie based remarketing services intended to deliver targeted marketing to you based on your internet searches	(a) Contact	Consent
To process your application including for the provision of services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) accounting for VAT purposes	(a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data   (e) Marketing and Communications Data (f) Academic Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Provision of learning materials (c) Asking you to leave a review or take a survey (d) Monitor attendance or any change in student status. (e) Administration of appeals, complaints, and matters relating to health and conduct and to cheating and plagiarism (unfair means). (f) Granting of awards (g)Administration of alumni membership	(a) Identity Data (b) Contact Data (c) Profile Data (d) Marketing and Communications Data	(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 use our products/services) (d) Necessary for the candidate’s legitimate interests (to receive the benefit of the award)
Equal opportunities monitoring (for some but not all of our institutions)	Gender ethnicity religion and nationality	Legal Obligation
Enrolment	(a) Identity Data (b) Student Data	Necessary for the performance of a contract
Make adjustments to meet disability requirements / medical conditions	Health Data	Consent
Provide health and safety first aid assistance emergency evacuation, hazard risk assessment, accident monitoring	Health Data	Vital interests Consent
Emergency accident / health management	Emergency contact / next of kin details	Vital interests Consent
Improvements in service offering, profiling students based on their performance and other	Student Data (specifically learner analytics)
To enable you to complete a survey	(a) Identity Data (b) Contact Data (c) Profile Data (d) Usage (e) Marketing and Communications Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (continuous improvement / updating records/ analyse customer behavior patterns)
Customers (or prospective customers) of[ online courses and published media
Register new customer of online materials	(a) Identity Data (b) Contact Data	Performance of a contract with you
Process / fulfil / deliver customer order Manage payments, fees and charges Collect/ recover monies owed Accounting records Defence of legal claims brought against us	(a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data (e) Marketing and Communications Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us or defend legal claims) (c) Necessary to comply with a legal obligation
Clients of BSBI (including employer clients)
To register you as a client of BSBI	(a) Identity Data (b) Contact Data	Performance of a contract with you
To process, fulfil and deliver our service to you Manage payments, fees and charges Collection/ recovery of monies owed Accounting purposes Defence of any legal claims brought against BSBI	(a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data (e) Marketing and Communications Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us or defend legal claims) (c) Necessary to comply with a legal obligation
Suppliers to BSBI
To register you as a supplier of BSBI	(a) Identity Data (b) Contact Data	Performance of a contract with you
To process and receive goods/services: (a) Manage payments, fees and charges Accounting purposes Defence of any legal claims brought against BSBI	(a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data (e) Marketing and Communications Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to defend legal claims) (c) Necessary to comply with a legal obligation

BSBI graduation ceremonies are significant events for our graduates, their guests and our staff. These ceremonies are public events and therefore there is no expectation of privacy under data protection legislation for any attendees. This statement explains how personal data will be processed for and during the event and provides guidance should you not wish your personal data to be processed in this way. This applies to all students who are intending to graduate or may be eligible for an award, whether they attend a ceremony or not. Please note the following important information and ensure your invited guests are also aware of the information relevant to them:

• Your name will appear in the Graduation brochure. If you do not want your name included for these purposes you must tell us be emailing dpo@berlinsbi.com no later than 5 weeks prior to the date of your ceremony*.
• If you graduate in person your name and award title will be read out at the ceremony immediately prior to you walking across the stage.
• Your photograph will be taken whilst you cross the stage and receive your ‘parchment’.
• Crowd shots will be taken by the College photographers at the venue and at our graduation receptions and these may include images of you and your guests.
• Your consent will be sought for smaller group or individual photographs prior to these being taken. If you do not wish to be photographed, you should tell the photographer before the photo is taken.
• Live film feed may be used to stream the ceremonies externally.
• If you do not wish to have your photograph taken/ video filmed/streamed when crossing the stage, including being handed your parchment you must tell us by emailing dpo@berlinsbi.com no later than 5 weeks before the date of your ceremony*.
• Videos of the ceremonies may be produced and screened at relevant post-graduation receptions and, at a later date, will be made available for viewing from the College website.
• Television companies may be present to interview our honorary graduands and other VIPs or film the event generally. If you do not wish to appear on television, you should maintain your distance from any filming that may take place.
• Appropriate photographs and films of these events may be used to promote the activities of BSBI and these may appear in any of our promotional materials, in printed or electronic format, including worldwide web sites, multimedia productions, course leaflets or prospectuses. Please note that websites can be seen worldwide.
• Visual images will be used and retained strictly in accordance with the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit) and the College records retention schedules.

If you have any queries or concerns about the use of your personal data for/at our Graduation ceremonies, please email dpo@berlinsbi.com no later than 5 weeks prior to the date of your ceremony. Please see the full privacy notice below:

*When emailing please ensure that you include your Student ID and Programme of Study.

 

Identity of controller

Berlin School of Business and Innovation (BSBI)

 

Purpose for collection/processing

The College processes personal data for the purposes of arranging graduation ceremonies, conferring awards on graduands and documenting the event for the purposes of celebrating graduands achievements and for the future promotion of the College.

 

Legal basis

Article 6(1) of the General Data Protection Regulation refers:

Article 6(1) (a) consent is the basis for including names in the press.

Art 6(1) (f), legitimate interests, is the basis for processing personal data for the purposes of photography and filming where this is for future promotion of the College. Please see the photography statement provided for further information. It is in the legitimate interests of the controller to use images of successful graduates and ceremonies for future promotion of the College. To balance the individual’s interests, rights and freedoms the College provides a fact sheet of all photography and filming activities to individuals prior to the event which details how they can avoid inclusion in the photography and filming and exercise their rights in the event that they are included. It is in the interests of both the College and individual graduands involved to document these auspicious occasions which are important life events to be celebrated.

 

Whose information is being collected/processed

Students, College employees and all other ceremony attendees, including those invited by students/graduands.

 

What information is being collected

Name, identifying numbers, contact details, educational details, photographs and moving images.

 

How is the information collected

College systems for the event organisation and images by camera on the day of the event.

 

Who is the information shared with outside the College

Publicly – the publication of names in graduation brochures, photographs online and in any of the College’s promotional materials, in printed or electronic format.

 

How is the information kept securely

Information/photographs are kept securely on College processing equipment in line with the College’s information security and data protection policies.

 

How is the information kept up to date

Students are required to keep their information up to date during the course of their studies to ensure that the personal data used at the time of graduation ceremonies is accurate, as this will be recorded at this point as a record of the event.

 

How long is the information kept

Please see the College’s Records Retention Schedules.

 

Will the information be used for any automated decision making

No

 

Is the information transferred outside the European Union?

Ceremony live video streams are broadcast over the internet and may be accessed out with the EU.

Individual photographs and graduation brochures may be transferred outside the EU by third party individuals.

 

Your rights

Attendance at a Graduation Ceremony is optional and students can choose to graduate in-absentia (without attending). This selection is made at the time of registering a student’s intent to graduate.

Graduands can request that they are not photographed/captured on video while crossing the stage during the ceremony.

This request must be made in writing to dpo@berlinsbi.com submitted no later than 5 weeks prior the date of the ceremony.

Graduands can request that their name does not appear on the official Graduation Brochure.

This request must be made in writing to dpo@berlinsbi.com and submitted no later than 5 weeks prior the date of the ceremony.

What personal information do we collect?

We may hold a range of personal data about you from a number of sources. The majority of the personal data that we hold is information provided to us by you. If you are an alumna/ alumnus of BSBI, personal data collected during your time as a student is transferred from your student record such as your name, date of birth and gender to BSBI’s alumni database when you complete a course of over 12 months’ duration. We may also add information provided by you during interactions with you. If you are a supporter of BSBI, the personal data we hold may be information provided by you during your interaction with us.

Examples of categories of personal data which we may hold are:

• Personal identifiers – e.g. your name, gender, student/ alumni numbers and your date of birth;
• Contact details – e.g. your postal/ email address, telephone number and contact preferences;
• Information about your time at BSBI – e.g. the courses you completed and your membership of clubs and societies;

Career details – e.g. job role;

• Records of donations – including financial details and Gift Aid status, where applicable (as required by Finanzamt);
• Communications between the Alumni and Development Department and you;
• Information about your interactions with BSBI – e.g. records relating to volunteering activities on behalf of the College, online interactions with us on social media, information about your use of College resources or facilities (e.g. the online library), information on your engagement with College meetings, events, groups or networks;
• Results of automated decision making and profiling processes to focus our interactions with you

We may also hold information collected from publicly available sources, such as social network posts, internet searches and websites, and may augment this information with the personal data you provide to us.

 

Why are we collecting your personal data/what are we doing with it (purposes)?
We only process data for specified purposes and if it is justified in accordance with data-protection law. In general terms, we process your personal data for the purposes of increasing alumni involvement with the student experience at BSBI, fundraising, alumni/ supporter communications and related activities by the Alumni and Development Department. More specifically, these activities may include:

 

• sending you publications (e.g. alumni magazines and email newsletters about BSBI and fundraising activities);
• inviting you to alumni and supporter events, reunions and college events;
• informing you of benefits available to alumni and supporters;
• asking you to support BSBI (e.g. contributing to student mentoring schemes or donations);
• fundraising programmes;
• wealth analysis and research in order to improve our understanding of our alumni and supporters, inform our fundraising strategy and target our communications; and
• internal record-keeping and administration (e.g. to process a donation or administer an event which you are attending).

 

There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter. Use of our websites, including our use of cookies, is covered by our website privacy notice: https://www.berlinsbi.com/privacy-policy

 

Do we use any automated decision making or profiling?

Automated individual decision-making means making a decision solely by automated means without any human involvement and profiling means the automated processing of personal data to evaluate certain things about an individual. We may use automated or manual analyses including segmentation or profiling to link data together to send you communications which are relevant and timely, to identify opportunities which may be of interest to you, to help us identify your potential for supporting BSBI and to avoid approaching you with opportunities which are not of interest. We may carry out wealth screening to focus our conversations with you and ensure we provide you with an experience which is appropriate for you.

 
What legal bases do we rely on for processing your personal data?
Depending on the activity being carried out, we will rely on one of the following conditions for processing: a legitimate interest; a legal obligation; or your consent to process your data, as explained below.

 

• GDPR Article 6(1) (a) – Consent of the data subject
  Unless mentioned below, we will only process your personal data in relation to alumni and development purposes where we have your consent. This means we will only email you, or call TPS registered numbers, if we have your express consent to do so. We may contact you by post, unless you have asked us not to. We will also only contact you about College news, events or to ask for a donation if we have your express consent to do so.
• GDPR Article6 (1)(c) – Processing is necessary for compliance with a legal obligation
  If you make or have made a charitable donation we will process your name, address, and donation information under 6(1)(c) of the GDPR for the purpose of administering your donation and claiming Gift Aid / tax relief on your behalf. We may also use available sources to carry out due diligence checks to meet money laundering regulations. If you withdraw consent, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. The College has a legal obligation to supply some of the information we hold about you, as a graduate, to local authorities such as the Ausländerbehörde, the Berlin Senate or other governmental bodies as requested.
• GDPR Article 6.1(f) -Processing is necessary for the pursuit of our legitimate interests.
  Processing of student record data for alumni under legitimate interests for the purpose of monitoring our academic services and providing you with information (e.g. copy of transcript, confirmation of degree etc.) is covered in this Student Privacy Notice.

Who do we share your personal data with? What data do we share?

On occasion we may need to share your data internally and with third parties. The following table lists what information we may share with whom.

 

Recipients	Data which we may share with them
Our staff in the Alumni and Development Department	Contact details, course information, and, where necessary for the implementation of reasonable adjustments and/or the provision of other support and subject to your consent, health information.
Our administrative/ IT staff associated with alumni/ supporter activities	Contact details, course information, and, where necessary for the implementation of reasonable adjustments and/or the provision of other support and subject to your consent, health information.
Volunteer partners associated with alumni/ supporter activities	Contact details and course information
College clubs and societies	Contact details and course information
Event providers	Registration details, accessibility and assistance requirements and related information including dietary requirements.
Third parties engaged by BSBI to provide alumni and fundraising related services including potential for wealth analysis and research or to carry out automated or manual analysis to link data together to identify your potential for supporting BSBI	Contact details and course information
Data processors i.e. third parties who process personal data on our behalf e.g. software providers, event booking providers etc. (e.g. Survey Monkey, Eventbrite)	Contact details and course information

 

 

How are we protecting your personal data?

Your personal data is held securely on BSBI’s alumni and supporter database, which is accessible by a limited number of staff and is secured.

We ensure we have appropriate data sharing agreements in place before sharing your personal data.

We do not sell your personal data to third parties under any circumstance or permit third parties to sell on the data we have shared with them.

BSBI is committed to working in a transparent, ethical, responsible and honest way.

 

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data processed by us:

 

• to gain access to your personal data;
• to rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
• to have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
• to object to the processing of your personal data for marketing purposes;
• to object to the processing of your personal data when such processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing;
• to restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period; and
• to ask for the transfer of your data electronically to a third party.

 

How long is your personal data kept?

Personal data in support of your alumni relationship with BSBI will be kept until there is no longer a legal basis for holding it, until you object to the processing of your data (e.g. for direct marketing purposes) or until you withdraw your consent.

If you ask us to delete your personal data, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. We may also need to retain some financial records for statutory purposes.

 

How can you maintain your personal data?

You can update, amend or correct the data we hold about you by contacting the Alumni and Development Department by email, phone or post (studentservices@berlinsbi.com). You can also change your communication preferences at any time to restrict how we process your data, or opt out of some or all communication. We will also review your consent and preferences at least every two years.

 

Exercising your rights, queries and complaints

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Officer:

Data Protection Officer

Address: Potsdamer Straße 180-182. 10783 Berlin, Germany

Email: dpo@berslinsbi.com

 

Complaints to the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit)

You have a right to complain to the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit) about the way in which we process your personal data. Complaints can be filed in electronic form at https://www.datenschutz-berlin.de//.

The law requires us to meet additional conditions for collecting, storing and using personal data that is considered ‘special category’ data. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

Students or prospective students

Purpose/Activity	Type of data	Lawful basis for processing
Students or prospective students
To enroll you as a student we need to determine your immigration status with BSBI	Nationality data Immigration status (information from visas and passports)	·       Performance of a contract with you ·       Compliance with a legal obligation eg to the German immigration authorities (and others)
To make required adjustments and necessary support for applicable learning needs	Disability data Special learning needs	·       Performance of a contract with you ·       Complying with our legal obligations ·       Explicit consent (information is voluntary)
To: ·       Monitor student absences* ·       Deal with applications for mitigating circumstances ·       Deal with applications for interruptions of studies or deferrals ·       Confirm any dietary requirements	Medical / health data Doctors’ notes Medical Records (potentially)	·       Performance of a contract with you ·       Explicit consent (this information is voluntary) ·       *Sometimes a visa will stipulate that a student must keep a minimum attendance level; in this case we will ask for medical evidence to support absence and thus to avoid breaching our obligations to the German immigration and other authorities.
To monitor and report on equal opportunities	Data relating to race and ethnic origin	·       Compliance with a legal obligation

 

Alumni and Supporters

 

Who do we share your personal data with? What data do we share?
On occasion we may need to share your data internally and with third parties. The following table lists what information we may share with whom.

 

Recipients	Data which we may share with them
Our staff in the Alumni and Development Department	Contact details, course information, and, where necessary for the implementation of reasonable adjustments and/or the provision of other support and subject to your consent, health information.
Our administrative/ IT staff associated with alumni/ supporter activities	Contact details, course information, and, where necessary for the implementation of reasonable adjustments and/or the provision of other support and subject to your consent, health information.
Volunteer partners associated with alumni/ supporter activities	Contact details and course information
College clubs and societies	Contact details and course information
Event providers	Registration details, accessibility and assistance requirements and related information including dietary requirements.
Third parties engaged by BSBI to provide alumni and fundraising related services including potential for wealth analysis and research or to carry out automated or manual analysis to link data together to identify your potential for supporting BSBI	Contact details and course information
Data processors i.e. third parties who process personal data on our behalf e.g. software providers, event booking providers etc. (e.g. Survey Monkey, Mail Chimp)	Contact details and course information

 

The above information may also need to be used using the lawful basis of pursuant to a legal claim or to protect your interests (or someone else's interests) (where you are not capable of giving your consent (for example if you suffer a medical problem preventing your ability to communicate).

Consent

It is not a condition of becoming a student with us that you give us consent for any particular type of processing. However, should you choose not to give consent, then you may not benefit from certain support services for example.

We do not need your consent in circumstances where we use special categories of your data in accordance with our legal obligations (and we set this out in our written policies).

On rare occasions we may ask for your explicit (written) consent to use certain special categories of data. If we do this we will make sure you have a detailed explanation of the data we need and why. This will enable you to make an informed decision whether you wish to consent.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will always give you options to determine how we use your personal data in this regard. 

Promotional offers from us

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you filled out a survey or feedback form and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out / unsubscribe links on any marketing message sent to you at any time on dpo@berlinsbi.com.

Where you opt out of receiving these marketing messages, this will not stop us storing your data provided to us as a result of a applying for a course or programme or buying some other service or materials from us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click here.

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 our DPO.

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.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties identified in the Glossary.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

We share your personal data within the GUS Group. This will involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them using similar protection for personal data as is required by GDPR.
• You have explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for you due to the absence of an adequacy decision and appropriate safeguards.
• The transfer is necessary for the performance of a contract between you and us as the data controller or for the implementation of pre-contractual measures taken at your request.
• The transfer is necessary for the conclusion or performance of a contract concluded in your interests between us as the data controller and another natural or legal person.
• The transfer is necessary for important reasons of public interest.
• The transfer is necessary for the establishment, exercise or defence of legal claims.
• The transfer is necessary in order to protect your vital interests or the vital interests of other persons, where you are physically or legally incapable of giving consent.

The transfer is made from a register which according to Union or Member State law is intended to provide information to the public and which is open to consultation either by the public in general or by any person who can demonstrate a legitimate interest, but only to the extent that the conditions laid down by Union or Member State law for consultation are fulfilled in the particular case.

Please contact our DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Types of personal information we collect

We collect, use and store different types of personal information about you, which we have grouped together as follows:

Types of personal information	Description
Publicly Available Data	Details about you that are publicly available, such as on Companies House or elsewhere on the internet
Marketing Data	Details about your preferences in receiving marketing communications from us
Consents Data	Any permissions, consents or preferences that you give us
Usage Data	Information about how you use our website, products and services

How we use your information

Cookies

Our website https: https://www.berlinsbi.com/ uses cookies. For more information on our cookies use, please read our cookies statement on our website.

Generally

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.

What we use your information for	Our reasons	Our legitimate interests
To provide you with information you may ask for	Consent Legitimate interests	To fulfil enquires you might make of us
To allow you to register for updates or for notifications of blog posts on our website	Consent Legitimate interests	To provide you with information that you may request from us
To allow you to register for events that we may be hosting	Consent Legitimate interests	To hold events, such as seminars, webinars, open days or corporate hospitality to promote our business and its services
To allow you to register as a member of our alumni network	Consent Legitimate interests	To operate and develop our alumni network and the activities of our alumni programme
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Legitimate interests	To provide efficient client care and services To ensure that our technology operates efficiently and without error To assess which of our services may be of interest to you and to tell you about them To develop new products and services and improve existing ones
To manage our relationship with you which will include notifying you about changes to our privacy notice and our website terms and conditions	Legitimate interests Contract performance	To provide efficient client care and services To keep you updated about changes in the legal terms that apply to the use of our website For record keeping and firm management
To manage the systems that contain our marketing database To manage marketing preferences and keep our records up to date	Legitimate interests	For data management for marketing and business development purposes To improve our systems and services To seek feedback To seek your consent when we need it to contact you
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Legitimate interests Consent	To improve our marketing strategy and the services that we provide
Sharing information with third parties - to facilitate data-gathering to improve our educational services, our website, and our marketing efforts.	Legitimate interests	For the purposes of BSBI's legitimate business interests such as managing and developing its business

Where we collect your personal information from

We may collect personal information about you from the following sources:

• Directly from you
• Cookies – see our cookie statement which can be accessed from our website
• Analytics providers, such as Google Analytics

Who we share your information with

We may share your personal information with the following third parties:

• Our agents and service providers who we use to help us with marketing.
• Event organisers (if we are organising an external event which you are attending)
• The police and other law enforcement agencies
• Relevant regulators, including the German Federal Data Protection Authority (Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit) in the event of a personal data breach
• Other companies owned or jointly owned by Global University Systems
• Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business.

How long we keep your personal information

Where we use your personal information for marketing purposes we will retain your personal information for so long as we have your consent to do so (where we use your personal information with your consent in order to send you marketing messages) or, in other cases, for so long as we have a legitimate business or commercial reason to do so (unless you ask us to stop).

Where you withdraw your consent to receiving marketing materials or otherwise ask us to stop marketing we will add your details to a suppression list which ensures that we remember not to contact you again. You can request this by emailing us at dpo@berlinsbi.com.

If you withdraw your consent to receiving marketing materials or ask us to stop our marketing activities, we will still communicate with you for other purposes in the normal course of any other relationship we may have with you.

International transfers

As a global company, we hold some personal information concerning our suppliers and their affairs within the United Kingdom. We do work with agents and service providers who may process your personal information on our behalf outside the EEA. If your information is processed outside the EEA, we will ensure that it is protected to the same standards as if it were being processed within the EEA by putting in place a contract with our agents and service providers that provides adequate safeguards.

If you require more information or have any queries, please contact our Data Protection Officer at: dpo@berlinsbi.com.

Privacy Notice

If you are a Job Applicant

What is this notice?

This is the 'Recruitment Privacy Notice' of Berlin School of Business and Innovation GmbH

This notice applies to individuals applying to work with us, including prospective directors, employees, trainees, apprentices, work experience students, workers, consultants and contractors. It applies whether the work applied for is part time or full time; or permanent, temporary or for a fixed term.

We are a data 'controller', which means we are responsible for deciding how we hold and use your personal information.

This notice explains how and why we will collect and use your personal information in the context of the recruitment process and your rights in relation to your personal information. We may amend this notice at any time.

Your personal information

In this privacy notice, 'your personal information' means your personal data i.e. information about you from which you can be identified. The sections below set out your personal information that we may process.

Your 'personal information' does not include data where the identity has been removed (anonymous data).

It is important that your personal information is accurate and up to date. Please inform us if your personal information changes during the recruitment process.

Special categories of personal information

'Special categories of personal information' means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purpose of uniquely identifying you.

Data marked * in the table at section 5 below, and data described at section 6, falls within these 'special categories' or might disclose special categories of personal information. We must have additional legal grounds for processing special categories of personal information, and these grounds are set out at sections 5 and 6 below.

Where does your personal information come from?

Your personal information will come from you or us, and may also come from the following sources:

• Recruitment agencies and apprenticeship providers may provide us with the following personal information: personal contact details, qualifications, schools attended, details of previous employment(s), skills and experience, hobbies and interests, and interview notes.
• Credit reference agencies may provide us with the following personal information: personal contact details, date of birth, details of credit accounts and usage and an overall credit score.
• Former employers or other referees, whom you have given us permission to contact, may provide us with the following personal information: role(s) held, dates of employment, details of skills and capabilities and any other information that helps to assess your suitability for the position applied for.
• BSBI staff may provide us with: personal information about you if they are referring you for recruitment.
• Medical professionals may provide us with the following personal information: information relating to any disability that you may have, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability
• Professional bodies such as the Deutscher Buchprüferverband (DBV) [German Certified Accountants Association], Wirtschaftsprüferkammer (WPK) [Chamber of Public Accountants], The Bundesrechtsanwaltskammer (German Federal Bar) may provide us with the following personal information: qualifications, registrations, practising certificates, accreditation details and membership details.
• Google and social networking accounts (such as LinkedIn): as part of the recruitment process we may source personal information relating to roles you have held, details of skills and capabilities and any other information that helps us to assess your suitability for the position applied for.
• Disclosure Scotland: as described at section 6 below.

Some of the sources above will only be relevant in certain circumstances, or if you have applied for a particular role. If you would like more information on the source of your personal information please contact the HR department.

Processing your personal information

We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.

In general, we process your personal information for the reasons, and on the legal grounds set out in the following table, and also to:

• Retain records relating to the recruitment process;
• Establish, exercise or defend legal claims;
• Comply with the law or requirements of any regulator; and
• Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).

Reasons for processing your personal information	Legal ground(s) for processing, and legitimate interest (where applicable)	Your personal information
Contact you regarding the recruitment process and any offer of work	To enter a contract	Personal contact details (including name, address, email, telephone number)
Make a decision about your recruitment or appointment, including assessing your skills, qualifications and suitability for the work	To enter a contract For our legitimate interests: to select suitable employees, workers and contractors	Information provided in your application form, CV, any covering letter or email, and interview notes Information sourced from google and social networking accounts (such as LinkedIn) relating to roles you have held, details of skills and capabilities and other information that helps us to assess your suitability for the work.
If you have accepted an offer of work from us that is subject to such checks: Take up references (from referees whom you have given us permission to contact); Carry out credit checks; and / or Confirm your professional memberships, registrations and / or qualifications.	To enter a contract For our legitimate interests: to select suitable employees, workers and contractors	References and details of previous employers (including role(s) held, dates of previous employment, details of skills and capabilities and other information that helps to assess your suitability for the position applied for) Results of credit check: personal contact details, date of birth, details of credit accounts and usage and credit score Professional qualifications, registrations, practising certificates, accreditation details, and membership details
Determine the terms of any potential contract between you and us	To enter a contract To comply with a legal obligation	Offer letter, and proposed contract between you and us
If you have accepted an offer of work, check you are legally entitled to work in the UK	To enter a contract To comply with a legal obligation	Documentation confirming your right to work in the UK
Consider reasonable adjustments to the recruitment process for disabled applicants	To enter a contract To comply with a legal obligation For our legitimate interests: To select suitable employees, workers and contractors *For special categories of information: To exercise or perform employment law rights or obligations	Information about a disability, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability*
Carry out equal opportunities monitoring.	For our legitimate interests: to review equality of opportunity or treatment *For special categories of information: To review equality of opportunity or treatment To exercise or perform employment law rights or obligations	The following information you have provided via our equal opportunities monitoring form: Health data, including disability information* Information regarding pregnancy and maternity* Age and date of birth Marriage or civil partnership status* Gender Information on gender reassignment* Data revealing race, religious beliefs or sexual orientation*

Information about criminal convictions

To enable us to make recruitment decisions and assess suitability for particular work, we will process information about criminal convictions and offences (including alleged offences) as described in this section.

We will process this information to enter a contract with you, to comply with a legal obligation, for our legitimate interests (in selecting suitable employees, workers and contractors), and to exercise or perform employment law rights or obligations.

If you have accepted an offer of work from us that is subject to a criminal record check, we will ask you to obtain a disclosure check (at the appropriate level) and provide us with a copy of this.

Data necessary for the contract

The sections above identify personal information that we may need to enter a contract with you. You are not obliged to provide this information, but if you don't provide it, we may not be able to proceed with the recruitment process or enter into the contract.

Statutory requirement to provide your personal information

In some circumstances, the provision of your personal information relates to a statutory requirement. This includes:

• Documentation confirming your right to work in Germany – you are not obliged to provide this information, but if you don't provide it, we will not be able to enter into a contract with you.

Sharing your personal information with third parties

We may share your personal information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

• Health professionals and occupational health providers involved in your care, and in order to consider reasonable adjustments to the recruitment process for disabled applicants.
• Relevant regulators such as Deutscher Buchprüferverband (DBV) [German Certified Accountants Association], Wirtschaftsprüferkammer (WPK) [Chamber of Public Accountants], The Bundesrechtsanwaltskammer (German Federal Bar) or others as relevant.
• Our professional advisors.
• Other third parties as necessary to comply with the law.

Automated decision-making

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

Transferring your personal information outside the EU

We share your personal data within the GUS Group. This will involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with the German Federal Data Protection Act (Bundesdatenschutzgesetz – 'BDSG'), we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

Data retention

If you don't start work with us following the recruitment process, we will retain your personal information for six months thereafter:

• to allow us to establish, exercise or defend legal claims; and
• for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for becomes available again.

If you ask us to retain your personal information so that we can contact you to discuss future work opportunities, we will write to you separately, to obtain your explicit consent to retain your personal information for a fixed period of two years on that basis.

If you start work with us following the recruitment process, we will give you a copy of our Staff Privacy Notice and will retain your personal information as detailed in the Staff Privacy Notice.

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data processed by us:

• To gain access to your personal data.
• To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed.
• To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest.
• To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
• To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
• To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
• To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month

If you require more information or have any queries, please contact our Data Protection Officer at: dpo@berlinsbi.com.

You have a right to complain to the German Federal Data Protection Authority (Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit) about the way in which we process your personal data. Complaints can be filed in electronic form according to § 14(3) BDSG at bfdi.bund.de (in German).

Berlin School of Business and Innovation [BSBI] ("we", "our", "us") are committed to protecting and respecting your privacy.

This privacy notice applies to former employees of BSBI.

It is important that you read this section together with our entire privacy notice on this site or any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you. This is so that you are fully aware of how and why we are using your data.

Information we collect

BSBI does not collect personal data from former employees after they have left our employment, but it may hold the information that was collected before and during the employment relationship, including:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Date of birth
• Gender
• Marital status and dependants
• Next of kin and emergency contact information
• Social security contributions number
• Tax ID number
• Copy of identification (Passport/driving licence)
• Bank account details, payroll records and tax status information
• Salary, annual leave, pension and benefits information
• Start date
• Location of employment or workplace
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
• Employment records (including job titles, work history, working hours, training records and professional memberships)
• Compensation history
• Performance information
• Disciplinary and grievance information
• CCTV footage and other information obtained through electronic means
• Information about your use of our information and communications systems
• Photographs

Our lawful basis for processing

The lawful bases for processing personal data will be:

Article 6(1) (b) Contract
Article 6(1) (c) Legal obligation
Article 6(1) (f) Legitimate interest

How we process your information

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

1. Where we need to perform the obligations in a contract we have entered into with you, such as the employment contract, or a settlement agreement. Some of the contractual obligations in these contracts continue after your employment has terminated, such as the duty to observe confidentiality.
2. Where we need to comply with a legal obligation.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your vital interests (or someone else’s vital interests). Article 6(d).
2. Where it is needed in the public interest. Article 6(1) (e).

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may process your data for the following purposes:

• Paying you and deducting tax and social security contributions and other lawful deductions.
• Providing you with any employee related benefits to which you are entitled after the termination of your employment.
• To reimburse you for expenses incurred in the course of your employment.
• Liaising with your pension provider and the trustees/administrators of pension schemes.
• Administering any contract we have entered into with you.
• Business management and planning, including accounting and auditing.
• Gathering evidence for possible grievance or disciplinary hearings.
• Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
• To prevent and detect fraud.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• To conduct data analytics studies (such as the staff survey) to review and better understand employee retention and attrition rates.
• Equality and diversity monitoring
• Publicising our activities (e.g., group photos of events, site visits, etc.).

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

How we process “special categories” of more sensitive personal information

We may also store and use the following “special categories” of more sensitive personal information that we have collected from you:

• Information about your race or ethnicity
• Information about your health, including any medical condition, health and sickness records.
• Biometric data.
• Information about criminal convictions and offences.

These “special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for storing and using this type of personal information. Our data protection policy contains details of the safeguards which we are required by law to maintain when processing such data.

We may process special categories of personal information in the following circumstances:

1. Where we need to carry out our legal obligations or exercise rights in connection with employment.
2. Where it is needed in the public interest: for example, we will use information about your race or national or ethnic origin to ensure meaningful equality and diversity monitoring and reporting. Where possible, we would seek to anonymise this data.
3. In limited circumstances, with your explicit written consent. However, we do not need your consent to use special categories of your personal information to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Who is the information shared with

We may share your data with third parties, including third-party service providers, Government departments and agencies.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

BSBI shares your data with:

• Occupational Pension Scheme Trustees and Administrators.
• Occupational Health providers screening
• Bundesagentur für Arbeit
• Finanzamt
• Any other governmental bodies in order for BSBI to meet its legal obligations

Retention

BSBI will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected.

BSBI has a records retention schedule that outlines how long we will retain information.

To determine the appropriate retention period for personal data collected as part of your employment, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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.

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee we will retain and securely destroy your personal information after the following periods

• 12 months from date of leaving for employees; except
• Payroll, tax and NIC records which must be retained required for 6 years. This is a legal requirement.
• When litigation is likely or ongoing

However, these periods only apply to your employment records and not for example to images and materials created and use for marketing and communication purposes (e.g. group photographs taken etc.)

Your rights

Under certain circumstances, you may have the following rights in relation to your personal data:

Right 1: A right to access personal data held by us about you.

Right 2: A right to require us to rectify any inaccurate personal data held by us about you.

Right 3: A right to require us to erase personal data held by us about you. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).

Right 4: A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.

Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organization.

Right 6: A right to object to our processing of personal data held by us about you.

Right 7: A right to withdraw your consent, where we are relying on it to use your personal data.

Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at: dpo@berlinsbi.com.

Changes to our privacy Policy

Any changes we make to this privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Who regulates the use of my personal information?

The German Federal Data Protection Authority (Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit).

Who do I contact with questions?

The data controller for the purposes of the General Data Protection Regulation is Berlin School of Business and Innovation GmbH. If you have any questions or concerns about how your personal data is used, please read this entire privacy policy, and if you have a complaint please email our Data Protection Officer at: dpo@berlinsbi.com.

You have a right to complain to the German Federal Data Protection Authority (Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit) about the way in which we process your personal data. Complaints can be filed in electronic form according to § 14(3) BDSG at bfdi.bund.de (in German).

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.

 

How long will you use my personal data for? 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.

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.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may 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.

 

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data: You have the right to access your personal data (known as an “access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
  
  

To make a request: If you wish to make a request for access to your information, please contact us at Berlin School of Business and Innovation, Alte Post Karl-Marx-Straße 97-99 12043 Berlin Germany or by email at dpo@berlinsbi.com.

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.

Request correction of your personal data
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data
  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data
  You may raise an objection to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data
  You may request to restrict our processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:(a) if you want us to establish the data's accuracy;(b) where our use of the data is unlawful but you do not want us to erase it;(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data
  You may exercise your right to transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent
  This applies only where we rely on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

In certain circumstances, you can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also contact us at dpo@berlinsbi.com if you wish to exercise your rights.

If you wish to exercise any of the rights set out above, please contact our DPO.

Complaints to the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit)

You have a right to complain to the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit) about the way in which we process your personal data. Complaints can be filed in electronic form at https://www.datenschutz-berlin.de//.

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DPO.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take preliminary pre-contractual steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the GUS Group acting as joint controllers or processors and who are based throughout the world and provide shared services such as IT, legal services, system administration services and leadership reporting.

External Third Parties

• Service providers acting as processors based in UK, Belarus, Spain and America who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based throughout the world who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and other countries who require reporting of processing activities in certain circumstances.
• Employers who request a reference from BSBI
• External Examiners for examination, assessment and moderation purposes
• Awarding body partners – in order to process the administration of student enrolment onto programmes
• Professional/Funding bodies, Student Loans company
• Marketing Service Providers
• Other universities, employers, prospective employers, providers of training contracts or pupillages