Berlin School of Business and Innovation (“BSBI”), respects your privacy and is committed to protecting your personal data. This privacy notice tells you how we look after your personal data when you visit our websites (regardless of where you visit from) and tells you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how BSBI collects and processes your personal data including any data you may provide through this website when you.
This website is not intended for children and we do not knowingly collect data relating to children on this website. However where BSBI processes personal data of children in its business operations, we ensure that appropriate safeguards and consents are obtained from parents or caregivers. You may contact dpo@berlinsbi.com for further information about this.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and does not replace them.
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 Potsdamer Strabe 180-182, 10783 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.
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: Potsdamer Strabe 180-182, 10783 Berlin, Germany.
Telephone number: +49 3058 584 0959
You have the right to make a complaint at any time to the Berlin Commissioner for Data Protection and Freedom of Information for data protection issues (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 13 Jan 2020 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.
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.
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:
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:
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:
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) |
|
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 GUS |
(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 GUS |
(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 GUS |
(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 GUS |
(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 |
For All |
|
|
Recruitment (Academic job applications performed via webform) |
(a) Identity Data (b) Contact Data
|
Performance of a contract with candidate |
Relationship management Updating privacy policy and notify you of the same Updating terms and conditions and notify you of the same Seeking your feedback Processing complaints
|
(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 (continuous improvement / updating records/ analyse customer behavior patterns) |
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) |
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity Data (b) Contact Data (c) Technical Data |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity Data (b) Contact Data (c) Profile Data (d) Usage Data (e) Marketing and Communications Data (f) Technical Data |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, student and partner relationships and experiences |
(a) Technical Data (b) Usage Data |
Necessary for our legitimate interests (to define customer types for our products /services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Profile Data |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
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:
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 GUS |
Nationality data Immigration status (information from visas and passports) |
|
To make required adjustments and necessary support for applicable learning needs
|
Disability data Special learning needs |
|
To:
|
Medical / health data Doctors’ notes Medical Records (potentially) |
|
To monitor and report on equal opportunities |
Data relating to race and ethnic origin |
|
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.
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:
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.
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:
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, Potsdamer Strabe 180-182, 10783 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.
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.
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.
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
© Berlin School of Business & Innovation January 2020
© Berlin School of Business & Innovation January 2020