DSA-QAG ("DSA-QAG") are committed to protecting and respecting your privacy.
This Privacy Notice tells you what to expect in relation to personal information about you which is collected, handled and processed by DSA-QAG of Central Chambers, 4th Floor, Suite 350, 93 Hope Street, Glasgow, G2 6LD, who is the Data Controller.
We acknowledge and agree that any personal data of yours that we handle will be processed in accordance with all applicable data protection laws in force from time to time.
The General Data Protection Regulation ("GDPR") is a new regulation which replaces the Data Protection Regulation. The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Your rights under GDPR are set out in this notice and apply from 25 May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how DSA-QAG will treat it.
Who DSA-QAG is and what we do
DSA-QAG are a quality assurance organisation who undertake audits on behalf of the Department for Education and Welsh Government in line with the quality assurance frameworks for assessment centres and non-medical help providers. DSA-QAG collect the personal data of the following types of people to allow us to undertake our business, this list is not exhaustive however covers the main subjects:
- Students in receipt of the Disabled Students Allowance (DSA)
- Registered practitioners, including staff and support worker details
- Our Trustees, employees, consultants, temporary workers
DSA-QAG collect information about you to carry out our core business.
Information you give to us or we collect about you
This is information about you that you give us by visiting our website https://www.dsa-qag.org.uk (“Website”) or by corresponding with us by phone, e-mail, SMS or otherwise. It includes information you provide when you:
- Register as a practitioner
- Provide comments or feedback via our website
- Report a problem with our Website
The information you give us or DSA-QAG collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience.Information DSA-QAG collect about you when you visit our Website
When you visit our Website DSA-QAG will automatically collect the following information:
- Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL) of each page visited, clickstream to and through our Website including date and time, download errors, length of visits to pages, and any information submitted through forms.
Purposes of the processing and the legal basis for the processing
DSA-QAG use information held about you in the following ways:
To carry out our obligations arising from any contracts DSA-QAG intend to enter into or have entered into between you and DSA-QAG to provide you with the information and services that you request from us or DSA-QAG think will be of interest to you because it is relevant to your organisation.
Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although DSA-QAG will also rely on contract, legal obligation and consent for specific uses of data.
DSA-QAG will rely on legal obligation if DSA-QAG are legally required to hold information on to you to fulfil our legal obligations.
DSA-QAG will rely on your consent for particular uses of your data and you will be asked for your express consent, if legally required.
Our Legitimate Interest
Our legitimate interest in collecting and retaining your personal data is described below:
DSA-QAG is a quality assurance organisation whose primary role us to ensure the services provided to students’ who are in receipt of DSA funding is delivered in line with the standards laid down in the quality assurance framework for each of the registered practitioner groups.
To provide a full and comprehensive audit programme, DSA-QAG need to record the personal data of practitioners, students and staff, as a minimum.
Should DSA-QAG want or need to rely on consent to lawfully process your data, DSA-QAG will request your consent orally, by email, by SMS or by completing an online process for the specific activity (e.g. when completing online surveys or when you apply for a job) when DSA-QAG will require your consent for and to record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses DSA-QAG will make of your data:
Use of our Website
- to notify you about changes to our service
- to ensure that content from our Website is presented in the most effective manner for you and for your computer.
DSA-QAG will use this information:
- to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- to improve our Website to ensure that content is presented in the most effective manner for you and for your computer
- to allow you to participate in any interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Website safe and secure
- to measure or understand the effectiveness of the information and news DSA-QAG serve to you and others, and to deliver relevant information and news to you
DSA-QAG do not undertake automated decision making or profiling. DSA-QAG do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
- Disclosure of your information inside and outside of the EEA
DSA-QAG will share your personal information with:
Selected third parties including:
- analytics and search engine providers that assist us in the improvement and optimisation of our Website
DSA-QAG will disclose your personal information to third parties:
The lawful basis for the third-party processing will include:
- Their own legitimate business interests in processing your personal data, this may relate directly to any fraud investigation being undertaken by either the DfE, Welsh Government or SLC.
- satisfaction of their contractual obligations to us as our data processor
- for the purpose of a contract in place or in contemplation
- to fulfil their legal obligations
- Where DSA-QAG store and process your personal data
- to allow continuity of access to registered practitoners data whereby we will share data we hold about your organisation, including personal data of your staff, with the Department for Education(“DfE”) to allow DfE to administer Disabled Students’ Allowances (DSAs) efficiently and effectively. This will include providing information to students and stakeholders, identifying and selecting goods and services to be funded through DSAs, and undertaking audit and quality assurance functions, for the purpose of ensuring the proper use of public funds. We require a lawful basis for sharing personal data. This is in our legitimate interests and also the legitimate interests of the DfE and of the data subjects in continuing to respectively administer and receive DSAs. The key information we share can include but will not be limited to, name, address, contact details, cost of service provision, support worker details (NMH providers only) and types of service being offered.
All information you provide to us is stored on our secure servers in the UK. Where DSA-QAG have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. DSA-QAG ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although DSA-QAG will do our best to protect your personal data, DSA-QAG cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once DSA-QAG have received your information, DSA-QAG will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
DSA-QAG will retain your personal data for as long as necessary in order to provide the quality assurance service and for purposes of satisfying any legal, accounting, regulatory or reporting requirements.
DSA-QAG do the following to try to ensure our data is accurate:
- DSA-QAG check that the information provided by you is displayed correctly.
- DSA-QAG keep in touch with you so you can let us know of changes to your personal data
The criteria DSA-QAG use to determine whether DSA-QAG should retain your personal data includes:
- the nature of the personal data
- its perceived accuracy
- our legal obligations
- DSA-QAG may archive part or all of your personal data. DSA-QAG may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our Website may, from time to time, contain links to and from the websites of our partner networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that DSA-QAG do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights
- Request correction of the personal information that DSA-QAG hold about you. This enables you to have any incomplete or inaccurate information DSA-QAG hold about you corrected
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below)
- Object to processing of your personal information where DSA-QAG 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. You also have the right to object where DSA-QAG are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office, however, we appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Access to information:
GDPR gives you the right to access information held about you. A subject access request should be submitted by email to email@example.com, noting in the subject: Subject Access Request. In line with GDPR a response will be provided within one calendar month of receipt of the request.
Changes to our privacy notice
Any changes DSA-QAG make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to Operations Manager, who is our Data Protection Officer and can be contacted by email via firstname.lastname@example.org, noting in the subject ‘Privacy Notice Clarification’.