A Privacy policy - Website

secure.sbs.ox.ac.uk (“This site”) is operated by the University of Oxford. We are committed to protecting the privacy and security of your personal information (‘personal data’).

This policy (together with our terms and conditions, together with any other documents referred to in it) describes how we collect and use your personal data during your use of our site, in accordance with the UK General Data Protection Regulation (UK GDPR) and associated data protection legislation.

B Who is using your personal data?

The University of Oxford is the “data controller" for the information that you provide to us when visiting this website. This means that we decide how to use it and are responsible for looking after it in accordance with the UK GDPR.

Access to your personal data within the University will be provided to those staff who need to view it as part of their work in connection with the operation of this website. It will also be shared with the third parties described in Sections D and J.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We may update this policy at any time.

By visiting our site you are accepting and consenting to the practices described in this policy. For further information on when it is appropriate to seek consent, please refer to the guidance on the legal basis for processing. If you are still unsure, please seek advice from the Information Compliance Team/Legal Services]

C Glossary

Personal Data

Where we refer in this policy to your ‘personal data’, we mean any recorded information that is about you and from which you can be identified. It does not include data where your identity has been removed (anonymous data).

Processing of personal data

Where we refer to the ‘processing’ of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure, or retention.

D Types of data we collect about you

We will collect, store, and use the following categories of data when you use our site:

Data you give us. You may give us data about you including:

Your name
Job title
Email address
Phone number(s)
Nationality
Date of birth
Address
Other information shared voluntarily by you on our learning platform

The last category may include more sensitive personal information such as:

Information about your race, ethnicity, or religious beliefs
Information about your health, including any disability and/or medical condition

Data we collect about you. If you consent to our use of cookies.

If you visit our site, we will automatically collect certain technical information, for example, the type of device (and its unique device identifier) you use to access our site, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform.

We will automatically collect information about your visit to our site including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

E When we collect your data.

We will collect the vast majority of data about you when you register to use our site, correspond with us by phone, e-mail or otherwise, subscribe to our service, search for a product, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, complete a form on our site, purchase a product on our site, enrol on a course on our site, join as an Alumnus or Elumnus, report a problem with our site,.

When you visit our site we may also automatically collect technical information about your visit from your computer.

F How we use your data

We process your data for one or more of the following reasons:

- To provide you with the services, products and/or information you have requested e.g. Online Programme, white papers.
- To send you marketing or other types of communication by email e.g. faculty articles or more detailed programme information.

This processing is necessary to meet our contractual obligations to you, and/or to take steps requested by you prior to entering into a contract.

Information processed for this purpose includes, but is not limited to your name, address, email address, and other information to receive information from us regarding the programme, information, or service you have enquired about.

We do this only where you have specifically indicated that you consent to receive such communications, for example completing a web form or ticking a box. You can withdraw your consent at any time by contacting us at hello@sbs.ox.ac.uk. In this event, we will stop any processing as soon as we can. However, this will not affect the lawfulness of any processing carried out before your withdrawal of consent and you may no longer be able to use the site in the same way you did before.

For purposes arising from your use of this website, for example, to ensure that we understand who uses our site and how our site is used, and to improve our site and ensure it is secure. This processing occurs because it is necessary to meet our legitimate interests in operating this website. Information processed for this purpose includes, but is not limited to the type of device (and its unique device identifier) you use to access our site, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform.

We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.

Please note that we may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

G Marketing

We would like to send you information by email about products, services and opportunities which may be of interest to you.

We will not provide your data to other businesses so they can use it for marketing purposes.

We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you sign in to our site for the first time. You will have the opportunity to clearly set out what messages you wish to receive by ticking these boxes.

You can also manage your preferences by updating your privacy settings of your account.

H Sharing your data with third parties

We may share your data with third parties who provide services on our behalf, such as for administration, content sharing, simulations, and certification purposes.

All our third-party service providers are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions. For example, we may disclose some of your personal information to third parties that integrate with the courseware to enhance learning experience, like video and chat collaboration tools, assessment and testing, and content hosting companies, among others. We may also use some personal information to issue and distribute certificates of completion upon successful completion of all course requirements, which may require sharing personal information with a digital credentials partner.

We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. We may use cookies and similar technologies in conjunction with Google Analytics, Flywire, GTM, Azure Authentication, Salesforce, and Canvas. These technologies collect information about your browsing behaviour and enable us to personalise and enhance your experience on our website. By using our website, you consent to the use of cookies and similar technologies.

You may opt out of the use of cookies by Google Analytics here. (http://tools.google.com/dlpage/gaoptout)

We may also share your personal data with third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our site terms of use or to protect the rights, property or safety of our site, our users, and others.

Where your data is shared with third parties, we will seek to share the minimum amount necessary.

Oxford Saïd Online uses the following third parties for the following reasons:

Destiny One: Destiny One, is a software platform employed by our institution to facilitate seamless registration and processing of programs for our users. By utilising Destiny One, our participants can easily access and navigate through a user-friendly interface to explore and enrol in a wide range of educational offerings. This platform enables efficient management of the entire participant, including enrolment, course selection, participant record participant billing.

Personal data in Destiny One includes direct identifiers such as:

Participant, Contact, or Proctor name, contact, and location information (names, addresses, phone numbers, email addresses, country of birth, city of birth, state/province of birth, country of citizenship, and second country of citizenship)
Participant, Contact, or Proctor historical addresses (not visible in the user interface, but exposed on profile Address Audit Report)
Participant, Contact, or Proctor demographic information (gender, date of birth, occupation)
Participant, Contact, or Proctor associations (with groups, professional associations, memberships, , employer, manager’s contact information)
Unique Participant, Contact, or Proctor identifiers (school specific IDs, user names, Salesforce Contact ID, Direct Billing Account Number, SEVIS ID, IP addresses)
Participant, Contact, or Proctor government identifiers (SSN/SIN, tax ID, passport number, visa number)

Personal data may also include the following indirect identifiers, which if used with other data sources may uniquely identify an individual:

Participant educational background
Participant credentials
Participant emergency contact information (which may include contact name, address, phone, email, relationship to participant, additional information)
Personal data may appear in application responses provided by, or on behalf of, a participant applicant; and Personal data may appear in any file attachments uploaded by, or on behalf of, a participant
Personal data may appear in the program offering admission form
Personal data may also appear in ad hoc notes that staff may enter on the: profile hold form, comments for internal use form, transaction line item, and basket notes
Personal data may appear in staff entered participant communications and tracked email messages
Personal data may appear in marketing question responses
Personal data may appear in any files uploaded to a participant’s profile
Personal data may appear in staff or instructor entered comments on the marking of assignments or attendance tracking sheets
Other data which can be used individually or in combination with other data to identify a person

Third Party Systems Managed by Saïd Business School which Personal Data Transmitted from Destiny One include:

Google Analytics: The information collected through Google Analytics helps us analyse website traffic and improve the user experience on our site. It enables us to understand how visitors interact with our website, track the effectiveness of our marketing campaigns, and make informed decisions regarding website optimisation and content.

Please see the Google Analytics Privacy Policy here: Privacy Disclosures Policy - Analytics Help (google.com)

Flywire: Personal data collected by Flywire during the payment process is used for the purpose of processing payments securely and efficiently.

Please see the Flywire Privacy Policy here: Privacy Policy | Flywire

Google Tag Manager (GTM): GTM allows us to manage and deploy tags that facilitate website analytics and tracking. It helps us ensure the proper functioning of tracking technologies and provides a centralised platform for tag management.

Please see the Google Tag Manger Privacy Policy here: Data privacy and security - Tag Manager Help (google.com)

Azure Authentication: We use Azure Authentication, a service provided by Microsoft Azure, for access management and user authentication. When you create an account and log in using Azure Authentication, we collect and process certain personal data to verify your identity and grant you access to the relevant features and functionalities of our website.

Please see the Microsoft Privacy Policy here: Microsoft Privacy Statement – Microsoft privacy

Salesforce: We utilise Salesforce, a customer relationship management (CRM) platform, to update and maintain records of user interactions and contact preferences. Personal data collected through our website may be stored and processed in Salesforce to ensure effective communication and provide personalised experiences based on your preferences.

Please see the Salesforce Privacy Policy here: Privacy Policy - Salesforce.com

Canvas and Third-Party Apps: We use Canvas, our learning management system, to facilitate teaching and learning activities. Personal data collected through Canvas, including participant names, enrolment details, course materials, assignments, grades, pass marks, discussions, and other relevant information, may be processed in accordance with the General Data Protection Regulation (GDPR). This data is shared with instructors and supporting teaching staff to enable effective teaching, assessment, and support services. Additionally, we may use third-party apps within Canvas to enhance its functionality and provide additional features. These third-party apps also process data in line with GDPR guidelines to ensure the protection and privacy of your personal information.

Please see the Canvas Instructure Privacy Policy here: Privacy | Instructure | Instructure

I Where we store or use your data

We may store data collected by the website manually or electronically. The data is stored on our secure servers and/or in our premises within the UK.

There may be occasions when we transfer your data outside the United Kingdom, for example, when we communicate with you using a cloud-based service provider that operates outside the UK. Such transfers will only take place if one of the following applies:

the country receiving the data is considered by the UK to provide an adequate level of data protection;
the organisation receiving the data is covered by an arrangement recognised by the UK as providing an adequate standard of data protection;
the transfer is governed by approved contractual clauses;
the transfer has your consent;
the transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract; or
the transfer is necessary for the performance of a contract with another person, which is in your interests.

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

J Your responsibilities

You will create one account for yourself, and you will be responsible for keeping your account information up to date and ensuring it is accurate.

You are responsible for any third-party Personal information obtained, published, or shared through this platform and confirm you have the third party's consent to provide the Data to the platform owner. Examples include, but are not limited to: if you include a case study or example from your employer, or if you elect to provide information about a business partner or collaborator as part of an assignment uploaded to the platform.

K Third party websites

Our site contains links to and from various third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. These are stated in Section H. Please check these policies before you submit any personal data to these websites.

L Retaining your data

We will only retain your data for as long as we need it to fulfil our purposes, including any relating to legal, accounting, or reporting requirements.

M Your rights

Under certain circumstances, by law you have the right to:

• Request access to your data (commonly known as a "subject access request"). This enables you to receive a copy of your data and to check that we are lawfully processing it.

• Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.

• Request erasure of your data. This enables you to ask us to delete or remove your 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 data where you have exercised your right to object to processing (see below).

• Object to processing of your data where we are relying on our legitimate interests (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 we are processing your data for direct marketing purposes.]

• Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your data to another party.

Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. However, where you have consented to the processing (for example, where you have asked us to contact you for marketing purposes) you can withdraw your consent at any time by emailing us at hello@sbs.ox.ac.uk for marketing communications and dataoso@sbs.ox.ac.uk for all other communications. In this event, we will stop the processing as soon as we can. However, this will not affect the lawfulness of any processing carried out before your withdrawal of consent and you may no longer be able to use the site in the same way as you did before.

If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, you should contact the University Information Compliance Team at data.protection@admin.ox.ac.uk. The same email address may be used to contact the University Data Protection Officer. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the UK GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/concerns/.

N Cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them please see our cookies policy.

O Changes to this policy

Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

P Contact

If you wish to raise any queries or concerns about this privacy policy please contact us by email at dataoso@sbs.ox.ac.uk or by post to Oxford Saïd Online, Said Business School, Park End St, Oxford OX1 1HP, United Kingdom.

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