The HUB for SUCCESS Privacy Policy Note 

Last updated on 12.05.2021 

This Privacy Notice provides mandatory information, required under the  European General Data Protection Regulation (GDPR) regarding the  transparency of Personal Data processing, carried out by HUB for SUCCESS. 

HUB for SUCCESS supports individuals to get in, stay in and return to  education. The support includes such services as: 

– Practical and emotional support with education plans; 

– Proving care-identity; 

– Getting evidence of care-identity; 

– Collaborating with others to improve educational outcomes for people with  care-experience. 

Data processing 

Data – any Personal Data provided to or collected by HUB for SUCCESS  (hereinafter we, us, our) which acts as a Data Controller. 

Personal Data involves information that can be used to identify directly or  indirectly a specific individual. 

The visitors of the web page or the individuals who use the HUB for  SUCCESS (hereinafter You, Yours, Data Subject) are not required to provide  us with the Personal Data that we request. However, if you choose not to do  so, we may not be able to provide you with our services or respond to the  queries you may have. 

Principles of data processing 

While processing personal data, HUB for Success is following principles,  mentioned in GDPR art.5: 

  • Personal Data shall be processed lawfully, fairly, and in a transparent  manner (lawfulness, fairness, and transparency);
  • Personal Data shall be adequate, relevant, and limited to what is  necessary in relation to the purposes for which they are collected and/or  processed. Personal Data shall be accurate and, where necessary, kept  up to date (purpose limitation, data minimization, accuracy); 
  • Personal Data shall only be retained for as long as it is required to fulfil ours and your requirements while implementing the appropriate  technical and organisational security measures in order to safeguard  the rights and freedoms of the data subject (storage limitation); 
  • Personal data shall be processed in a manner that ensures appropriate  security of the personal data, including protection against unauthorised  or unlawful processing and against accidental loss, destruction, or  damage, using appropriate technical or organizational measures  (integrity and confidentiality). 
  • Data Controller (HUB for SUCCESS) shall be responsible for, and be  able to demonstrate compliance with, principles mentioned above  (accountability). 

What Personal Data is processed? 

We may collect Personal Data from a variety of sources. This includes: 

– Personal Data you give us directly; 

– Personal Data we collect from other partners or collaborators or other  professionals in order to provide you with support from the HUB. 

The data we collect may include the following personal information: 

If you have any inquiry, and want us to help we will request you to provide  your: 

  • name; 
  • personal email address; 
  • contact phone number 

If you decide to use the HUB for SUCCESS, we may request you to  provide your: 

  • full name (current) 
  • birth name or other names known by if different from current name date of birth 
  • age 
  • personal email address 
  • college or university email address 
  • phone number 
  • local authority 
  • social workers contact details and name
  • carer/guardians contact details and name. 
  • type of care-experience. 
  • qualifications gained 
  • current place of study 
  • school attended 

Purposes of Personal Data processing 

HUB for Success is processing Personal Data for the following purposes: 

  • to keep the records of partners met during the events 
  • to record feedback from individuals and partners for evaluation  purposes 
  • to manage enquiries/referrals and provide services (fulfilling conditions  of the agreement); 
  • to send personalised communications to potential and current HUB  individual users. 
  • to send personalised communications to potential and current HUB  stakeholders and interested parties 
  • to analyse our work and share anonymous statistics for reporting  purposes 

Legal basis for Personal Data processing 

Legitimate interest – data processing is necessary for the performance of our  work in providing a service to the individual. It is also necessary for reporting  on our work to funding providers, steering group and advisory board members 

(personal details will be anonymised but numbers of those worked with and  purpose of work will be outlined). 

Consent – data, that is not used to fulfil the conditions of the contract, is being  processed only with received permission from the Data Subject. 

Transfer of the Personal Data 

HUB for Success may transfer Personal Data to third parties such as social  workers, teachers, lecturers, college, and university staff, third sector  professionals and professional services in order to provide a service to the  individual. The HUB for SUCCESS may transfer personal data within  Edinburgh Napier University to support robust monitoring, reporting and  outcomes framework. We ensure that these data recipients protect the  confidentiality and security of Personal Data, and ensure that Personal Data 

is processed only for the provision of services and in compliance with  applicable law. 

Security and Access to Personal Data 

Personal Data will be stored in Edinburgh Napier University servers.  

Only HUB for SUCCESS employees, who use the Personal Data to offer  services or support, can access Personal Data. 

The HUB for SUCCESS implements appropriate organisational and  information security measures to protect Personal Data against accidental or  unlawful destruction, loss, alteration, or unauthorised access and disclosure. 

The transfer of Personal Data to data processors is allowed only when there  are appropriate contracts that regulate the data transfer and processing  between the controller and the processor. Data processors are required to use  appropriate technical and organizational measures to ensure the security of  Personal Data. 

Data retention 

When an individual has finished working with the HUB, all Personal Data will  be stored for a maximum of 5 years.  

Data Subject rights 

  1. The right to be informed. This means anyone processing Your  Personal Data must make it clear for what purpose data is processed,  security measurements applied, 3rd parties that the data is shared with,  etc. 
  2. The right of access. You have the right to request information about  what data company holds about You. 
  3. The right to rectification. You can request to correct or amend the  data if it is inaccurate. 
  4. Right to be forgotten. Under certain circumstances, you can ask for  your Personal Data to be deleted. This would apply if the Personal Data  is no longer required for the purposes it was collected for, or Your  consent for the processing of that data has been withdrawn, or the  Personal Data has been unlawfully processed. 
  5. The right to restrict processing. You have the right to ask for a  temporary halt to processing of Personal Data
  6. The right to data portability. You have the right to ask for any data  supplied directly to the Data Controller to be provided to You in a  structured, commonly used, and machine-readable format. 
  7. The right to object. You have the right to object to the further  processing of the data if it is inconsistent with the primary purpose for  which it was collected, including profiling, automation, and direct  marketing. 

Links to Other Websites 

Our website or service may contain links to other websites that are not  operated by us. If You click on a third-party link, you will be directed to that  third party’s site. 

We strongly advise you to review the Privacy Policy of every site you visit. 

We have no control over and assume no responsibility for the content, privacy  policies, or practices of any third-party sites or services. 

Changes to this Privacy Policy 

We may update our Privacy Policy from time to time. We will notify you of any  changes by posting the new Privacy Policy on this page. 

We advise you to review this Privacy Policy periodically for any changes.  Changes to this Privacy Policy are effective when they are posted on this  page. 

Dispute resolution 

Disputes relating to the processing of Personal Data are settled through contacting 

Edinburgh Napier: Data Protection Officer/Information Governance Manager Email: 

Tel: 0131 455 6257 

HUB for SUCCESS, Manager 

249 High Street 

Floor 6

Customer HUB Edinburgh