Privacy Policy



Introduction and Overview

This privacy policy describes how Millar Software and Consulting Limited (MSC) collect, use, store and protects your personal information as a user of our service called eSubs (The Service) provided using the websites student.esubs.co.uk and staff.esubs.co.uk.

eSubs is an online service run from UK data centres that helps educational establishments with the setting, submission, marking, feedback, verification and processing of results for academic and vocational courses. In doing so, MSC is acting as the "data processor " and the educational establishment is acting as the "data controller" as defined in the Data Protection (Jersey) Law 2018.

This policy does not apply to information provided to MSC outside The Service (such as by email or use of our website www.esubs.co.uk). Please see the privacy policy on www.esubs.co.uk for such information.

Collection and Use of Personal Information

MSC collects the following personally identifiable information:

  • If you are a member of staff, student or work for an exam board, we will hold your name and email address (and optionally your guardian’s email address if you are a student under 19 years old) as well as details of the course you are studying, teaching or verifying. This will be provided to us by your educational establishment. You will have given your consent to them to provide us with this information. We do not hold your home address, telephone number, gender, date of birth or any financial information. The purpose of this is to allow you access to The Service and to provide you (and possibly your guardian) notification of deadlines and actions taken within The Service by email.

  • If you are a student, we will also hold work you and members of staff submit to The Service for you (which may or may not contain personal information). By agreeing to the terms of use of The Service, you have consented for this information to be shared with staff at the educational establishment on whose course you are enrolled and appropriate representatives of exam boards who have been assigned to verify the quality of the course and/or student achievement for the course. The purpose of this is to allow your work to be marked and to provide you with feedback, as well as to allow internal (teachers and lecturers) and external (exam board representatives) to verify the quality of assessment and feedback provided.

  • If you are a member of staff, we may hold internal verification verdicts and feedback. This will be shared with other members of staff at your educational institution and exam board course verifiers. You will have given your consent for this by agreeing to the terms of use of The Service. The purpose of this is to ensure academic integrity and to help improve standards within the educational provider.

  • As a user of our service, your login and logout times as well as your IP address and browser type may be recorded. You will have given your consent for this by agreeing to the terms of use of The Service The purpose of this is aid the operation of The Service, maintaining quality of The Service and providing general statistics about use of The Service.

  • All the above information will also be accessible to MSC and their agents for the purpose of ensuring the correct and efficient operation of The Service.

You may be provided with links to other websites from The Service. MSC have no control of any information collected by such sites and encourage you to read the privacy statements on them before making use of them.

Data Retention

Data retention periods will be set by your educational provider in their role as data controller. These will normally be set according to guidance from the appropriate exam board.

In the event that an educational provider stops using the service, their data may be kept for up to one year following the cessation.

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

MSC uses cookies to provide access to parts of The Service and to enhance its operation. The Service does not collect or store any personal information in cookies and does not use any third-party cookies.

You can disable the use of cookies by adjusting your browser’s settings, however, doing so will make parts of The Service inaccessible.

Security

The security of your Personal Information is important to us. We will not pass your information to any third party other than to the police, regulatory bodies or legal advisers in connection with alleged criminal offences or suspected breach of the terms and conditions of use, or where otherwise required by law.

When marking or verifying the quality of student submissions, staff at your educational establishment and at exam boards can copy work you have submitted. Where this is done, such copies are subject to the data protection policy of the educational establishment acting as data controller.

Your personal data will be stored securely and processed under our data protection obligations as specified in the Data Protection (Jersey) Law 2018.

In the event of a breach of our security that leads to a loss of personal details, MSC will advise the data protection officers of educational providers using The Service, who will be responsible for advising users at their educational establishment and follow our procedures in line with obligations specified in the Data Protection (Jersey) Law 2018.

Third Party-Processors

To provide The Service, MSC make use of facilities provided by Microsoft in the UK to process and store data including personal information.

Transfer outside the EU/EEA

While The Service stores and processes data in the United Kingdom, it can be accessed from anywhere in the world and users may access your personal information while outside the European Economic Area.

By agreeing to use The Service, you consent to such transfer of your personal data.

Know your rights

Under the GDPR you have the following specific rights relating to your personally identifiable information (PII):

  • Right to Erasure:  Every individual has the right the right to be forgotten upon request.  The data controller must remove your PII data from its systems and request the same of any third-party systems of that controller.
  • Right to Access: Every individual has the right to access the PII data held about them upon request.
  • Right to Portability:  Every individual has the right to request their PII data and use it for other parties they wish to engage with.
  • Right to be Informed:  Every individual has the right to be informed about how their PII data is being used, which may be provided upon request of the individual, or before the controller changes any use of that data, giving the individual the right to consent or object.
  • Right to Objection:  Every individual has the right to object to the use of their PII data for any purpose proposed by a controller.
  • Right to Rectification:  Every individual has the right to have errors in their PII data to be corrected.
  • Right to Restrict:  Every individual has the right to restrict the uses of their PII data for any specific type of processing.
  • Rights on automated decisions & profiling:  Every individual has the right to restrict or object to automated decision-making processes or profiling based on their PII data.

Right to Access & Right to Portability:  As a student, or member of staff, all personal information held about you is accessible to you from within The Service. As a student, you are also able to download all your PII from within The Service

Rights on automated decisions & profiling: The Service does not undertake any automated decision making or profiling.

Other Rights: If you wish to resolve an issue relating to the other rights listed above, please discuss the issue with your educational provider in their role as data controller.

Changes To This Privacy Policy

This Privacy Policy is regularly reviewed. It was last updated on 3rd October 2018.

Contact Us

If you have questions about this Privacy Policy, believe we have not adhered to it or have any other questions about The Service, please contact us by email at info@esubs.co.uk