Introduction
Welcome to the University Canada West (“UCW”) privacy notice.
UCW respects your privacy and is committed to protecting your personal data. This privacy notice tells you how and why we collect, use, disclose, and protect your personal data in compliance with legislation when you visit our websites or use our services, and tells you about your privacy rights.
This privacy notice is provided in a layered format so you can click through to the specific areas, including the Glossary in section 12 (other capitalized terms are defined throughout this privacy notice).
Purpose of this privacy notice
This privacy notice provides information on how UCW processes your personal data, including any data you may provide through this website when you:
- arrive from a social media site;
- complete a callback or enquiry form;
- apply for a course or program, whether online or campus-based, and whether you are applying for yourself or on behalf of someone;
- sign up for marketing materials; or
- provide us with your personal data by any other means.
This website is not intended for children and we do not knowingly collect data relating to children. However, where UCW processes personal data of children, we ensure that appropriate safeguards and consent are obtained from parents or caregivers as applicable.
UCW provides updates to this privacy notice on this webpage. You must read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions about the purposes for processing your personal data. This privacy notice supplements the other notices and does not replace them.
This website is operated on behalf of Learningwise Education Inc., a company registered in British Columbia (C0849692).
Contact Details
Data Controller: University Canada West
Contact: Privacy and Data Protection Officer
Email address: [email protected]
Please contact us at [email protected] prior to challenging compliance with the Office of the Information & Privacy Commissioner (OIPC).
PERSONAL DATA
We collect personal data about users of this website and other individuals who contact us about our programs. “Personal data” or “personal information” means any information about an individual from which that person can be identified.
The personal data that we collect, use, disclose, transfer, process through this website and our business activities include:
- Academic Data includes eligibility data (e.g., education and academic history, training records, qualifications, personal statements, résumés, curricula vitae (CV), personal achievements, references).
- Contact Data includes temporary and permanent residential addresses, postal address, email address, and telephone numbers.
- Emergency Contact Data includes the contact information of your next of kin that allow us to communicate with them in an emergency. It is your responsibility to obtain their authorization before providing their information to us.
- Employment Data includes the contact details of your employer, start date, end date, and job title (e.g., student is sponsored by their employer).
- Financial Data includes billing address, payment information, loan information, financial account information, and records about products and services that you have purchased from UCW. This information is collected for processing financial transactions between you (or others on your behalf) and UCW.
- Health Data includes information on your health, doctor’s notes, medical records, allergies, dietary requirements, medical conditions, disabilities, and requests for accommodation.
- Identity Data includes first name, maiden name, surname, username or similar identifier, title, birthday, gender identity, marital status, Unique Learner Number, nationality, residency status, disability declaration, criminal conviction declaration, photographic images, and third party student reference number where that third party shares your data with us.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Profile Data includes your usernames and passwords, enquiries, orders, interests, preferences, feedback, and survey responses.
- Student Data is collected when you apply or enroll in our programs and it is used to deliver, manage, and terminate educational services. Student Data includes your:
- Contact Data
- identification photo;
- subject, course, or program of interest;
- chosen program of study;
- progress data;
- coursework results;
- exam results (including mocks);
- other results prior to final study year;
- exam scripts;
- transcripts;
- attendance;
- feedback or references from lecturers;
- communications with UCW;
- use of learning facilities or services;
- use of library resources;
- membership in student groups and associations;
- attendance at any event hosted or advertised by UCW and its partners and affiliates;
- mentorships;
- membership in any alumni network;
- learner analytics and profiling data; and
- disciplinary data.
- Student Data also include any:
- complaints regarding a student, course, tutor, faculty member, or employee;
- claims of any nature and appeals;
- extenuating circumstances;
- additional information as required by a professional, accreditation, or awarding body; and
- other information that is required by law to report about your program participation.
- Technical Data includes your Internet Protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform, and other technology on the devices you use to access this website or our electronic systems.
- Transaction Data includes payment and related details.
- Usage Data includes URL data, web analytics data (e.g., browsing actions, websites usage, information provided on websites), and how you use our products and services for system maintenance and improvement purposes.
- Visa Data includes passport information, visa information, bank statements, and other financial information to validate Canadian visa requirements.
Some personal data that we collect, use, and disclose may also be used to generate aggregated information (“Aggregated Data”) that allows us to improve our websites, electronic systems, programs, and services. When personal data is used in this way, we use reasonable efforts to remove your personal identifiers and combine it with the information of other individuals so that the Aggregated Data cannot be used to, directly or indirectly, identify you. In some circumstances, we may anonymize your personal data for research or statistical purposes (so that it can no longer be associated with you or identify you, directly or indirectly). In such cases, we may use this information indefinitely without further notice to you.
SPECIAL CATEGORY DATA
Special Category Data refers to categories of data that are considered sensitive (section 6). The law requires us to meet additional conditions for collecting, storing, and using personal data that is considered Special Category Data.
For example, when you apply for a course, program, or service, we may provide you with the option to provide other information about yourself that may be relevant, such as whether you have disabilities or medical conditions that may require accommodation. You are not obliged to share this information, but any information you provide allows us to assess how we meet our legal obligations to you. We recognize that such information is sensitive, and we make reasonable efforts to ensure that it is protected and not used or disclosed for purposes unauthorized by law.
It is not a condition of becoming a student that you give us consent for the processing of Special Category Data. However, should you refuse to give consent, this may limit your ability to benefit from certain support services at UCW. On rare occasions, we may ask for your written consent to use certain Special Category Data with an explanation to enable you to give an informed consent. We do not need your consent where we use Special Category Data in accordance with our legal obligations.
YOUR DUTY TO INFORM US OF CHANGES
The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.
IF YOU REFUSE TO PROVIDE PERSONAL DATA
You have the right to refuse to provide personal data to us. However, this might impact our ability to provide services to you.
We use different methods to collect data from and about you, including through:
- Direct interactions.We collect personal data directly when you contact us or submit forms and provide your Identity Data, Contact Data, and Financial Data. This includes personal data that you provide when you:
- use our website;
- create an account on our website;
- subscribe to our services or publications;
- request that marketing materials be sent to you;
- apply for our programs, courses, and services;
- enter a promotion or survey; or
- give us feedback.
- Automated technologies or interactions. As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions, and patterns by using cookies, server logs, and other technologies. We also receive Technical Data if you visit other websites that employ our cookies.
- A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our website and identify repeat visitors. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time.
- Cookies also enable us to track and target the interests of users to enhance the user experience (see Cookie Policy).
- 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, then some parts of this website may become inaccessible.
- Third party vendors, including Google, may use cookies to serve ads based on a user’s prior visits to the UCW website. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.
- Third parties or publicly available sources.We receive personal data from third parties and public sources as set out below.
PERSONAL DATA WE COLLECT FROM THIRD PARTIES:
- Analytics providers such as Google Analytics, Google Optimizer, Google Webmaster tools, Google tag manager, Facebook, Instagram, Conversant (based in Europe), Convertr Media (based in the United Kingdom), and similar services.
- Social media and advertising networks such as Google Advertising Network, Facebook, Instagram, Bing, LinkedIn, and similar networks.
- Search information providers such as Google, Bing, and other search engines.
- Providers of technical, payment and delivery services such as Conversant, Google Analytics, Facebook, Instagram, Bing, LinkedIn, Stripe (based outside of British Columbia), Convertr Media, and similar services. These third parties may provide Contact Data, Financial Data, and Transaction Data to UCW.
- Data aggregators may provide Identity Data and Contact Data to UCW.
- Staff, administrators, and faculty from other educational institutions, mentees or mentors, referees, and complainants may provide Student Data to UCW.
- Publishers, as owners of private websites throughout the world, may provide Academic Data, Contact Data, Identity Data, Marketing and Communications Data, and Technical Data to UCW.
- Agents and referring organizations (e.g., employers and other universities) may provide Academic Data, Contact Data, Identity Data, Marketing and Communications Data, and Technical Data to UCW.
THIRD PARTY LINKS
This website may include links to third party websites, plug-ins, and applications. Clicking on such 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 or policies. When you leave our website, we encourage you to read the privacy notice of every website that you visit.
We only use your personal data as permitted by law. Most commonly, we use your personal data for the following Lawful Basis (section 5):
- Performance of Contract;
- Legitimate Interest;
- Legal obligation; and
- Consent
CHANGE OF PURPOSE
We only use your personal data for the purposes of our collection, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose or if that other purpose is permitted or required by law.
If we need to use your personal data for an unrelated purpose, then we will explain the legal basis that allows us to do so.
MARKETING
We strive to provide you with choices about the use of your personal data for marketing, communications, and advertising.
PROMOTIONAL OFFERS
You receive marketing communications from us if you have:
- requested information;
- purchased products or services; or
- completed a survey or feedback form; and
- provided your Consent.
You may withdraw consent to receiving these communications by accessing the “unsubscribe” mechanism in our electronic communications.
We may process your personal data for more than one Lawful Basis depending on the specific purpose for which we are using your data.
For Students and Prospective Students:
| Purpose | Data Type | Lawful Basis |
|---|---|---|
| Responding to your requests, course enquiries, or applications. |
|
|
| Registration and providing student number and UCW identity card. |
|
|
Providing information on:
|
|
|
Processing applications including:
|
|
|
Managing relationships including:
|
|
|
| Monitoring legal compliance and reporting to government authorities. |
|
|
For Alumni and Research Participants:
| Purpose | Data Type | Lawful Basis |
|---|---|---|
Providing information on:
|
|
|
| Facilitating academic research. |
|
|
Managing relationships including:
|
|
|
For All:
| Purpose | Data Type | Lawful Basis |
|---|---|---|
| Recruitment. |
|
|
| Updating terms and conditions and notification of same. |
|
|
| Seeking feedback. |
|
|
| Complaint resolutions. |
|
|
| Administering business including troubleshooting, data analysis, testing, system maintenance, support, fraud prevention, network security, IT services, reporting and hosting of data. |
|
|
| Managing and improving our programs and services, including using data analytics to improve websites, systems, products, marketing, relationships, and experiences. |
|
|
| Delivering website content, advertisements, and measuring effectiveness, usage of products, programs, and services. |
|
|
| Direct marketing may include cookie-based remarketing services intended to deliver targeted marketing based on internet searches. |
|
|
| Legal defence. |
|
|
Responding to emergencies and health concerns, including:
|
|
|
We may process Special Category Data (section 2) in the following circumstances:
| Purpose | Data Type | Lawful Basis |
|---|---|---|
| Immigration status for enrolment. |
|
|
| Accommodations for learning needs, disabilities, and medical conditions. |
|
|
| Monitoring student attendance. |
|
|
| Applications for mitigating circumstances including deferrals. |
|
|
| Confirming dietary requirements. |
|
|
| Reporting on diversity, equity, and inclusion metrics and on equal opportunities. |
|
|
In some circumstances, we may share your personal data with third parties:
- Internal Third Parties;
- External Third Parties; and
- Third parties to whom we may choose to sell, transfer, acquire, or merge parts of our business.
We require all third parties to respect the security of your personal data in compliance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
In some circumstances, we share personal data with organizations based outside of Canada (see GDPR). UCW is a part of Global University Systems B.V. group of companies (“GUS”), and UCW shares personal data with GUS and third party service providers or processors.
We comply with the guidelines set by the Privacy Commissioner of Canada on PIPEDA, which have been deemed to provide an adequate level of protection for personal data by the European Commission (see Guidelines).
We ensure the transfer is necessary for one of the following reasons:
- Consent.
- Legal obligations.
- Performance of Contract.
- Legitimate Interests.
- Public interests.
- Vital interests.
We utilize appropriate security measures to prevent your personal data from being accidentally lost, used, altered, shared, disclosed, or accessed in an unauthorized way. In addition, we limit the access to and the use and sharing of your personal data to those employees, agents, contractors, and third parties on a “need-to-know” basis. They only use, process, share, and access your personal data upon our instructions, and they are subject to a duty of confidentiality. We have put procedures in place to deal with any known or suspected personal data breach.
We only retain your personal data for as long as necessary to fulfil the purposes for our collection, including the fulfillment of legal, accounting, or reporting requirements.
We may need to request specific information from you to confirm your identity.
- RIGHT TO ACCESS YOUR PERSONAL DATAYou may access your personal data. This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.UCW endeavours to provide access to your personal data, but may refuse to disclose such information where legally permitted, such as where the data:
- is personal data of a third party;
- is privileged, such as legal advice;
- constitutes UCW’s confidential or commercial interests; or
- would threaten the mental or physical health of another person.
- RIGHT TO RECTIFY YOUR PERSONAL DATA
You may rectify any incorrect or incomplete personal data we hold about you. - RIGHT TO OBJECT PROCESSING OF YOUR PERSONAL DATA
You may object to our processing of your personal data in some circumstances. - RIGHT TO RESTRICT PROCESSING OF YOUR PERSONAL DATA
You may restrict furthering processing of your personal data in some circumstances. - RIGHT TO ERASE YOUR PERSONAL DATA
You may delete your personal data in some circumstances, including:- there is no good reason for us to continue to process it;
- you have successfully exercised your right to object to processing;
- we may have processed your information unlawfully; or
- we are required to erase your personal data to comply with law.
- RIGHT TO TRANSFER YOUR PERSONAL DATA
You may transfer your personal data that you provided to us (data portability). We will provide to you, or to a third party that you have chosen, your personal data in a structured, commonly used, machine-readable format. This right applies to automated personal data that you provided to us based on Consent or Performance of Contract. - RIGHT TO WITHDRAW CONSENT
You may withdraw consent to process your personal data. If you withdraw your consent, then we may not be able to provide certain services to you. We will advise you if this is the case when you withdraw your consent.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.
Consent means a person’s voluntary agreement to the collection, use, or disclosure of their personal information. Consent may be express, deemed, or implied.
- Deemed consent exists where we give an individual prior notice of a proposed collection, use, or disclosure of their personal information and an opportunity to object, and we receive no objection from them.
- Express consent exists where we receive a deliberate written or verbal agreement for the collection, use, or disclosure of an individual’s personal information.
- Implied consent exists where an individual volunteers their personal information for a purpose that would, at the time, be considered obvious to a reasonable person.
GDPR means the European Union’s General Data Protection Regulation. It applies to organizations that have an established presence in the EU, offer goods and services to individuals in the EU, monitors the behaviour of individuals in the EU, or processes personal data of individuals in the EU on behalf of someone else.
Lawful Basis means a valid lawful basis for processing data in accordance with the GDPR, and includes certain specific purposes such as:
- Consent.
- Legal obligations.
- Legitimate Interest means processing your personal data as you would reasonably expect in the interest of our business to give you the best service, program, course, product, and experience.
- Performance of Contract means processing your personal data as necessary for the performance of a contract to which you are a party, or taking preliminary pre-contractual steps at your request before entering into such a contract.
PIPEDA means Personal Information Protection and Electronic Documents Act, S.C. 2000, c 5.
Privacy and Data Protection Officer means the position with overall management responsibility for the privacy policy and procedures at UCW. This is a functional description, not title. The Privacy and Data Protection Officer is appointed by the President of UCW.
Record means information in any form and recorded or stored in any manner, including paper, electronic, digital, audio, and video, but does not include a computer program or a mechanism that produces records on any storage medium.
Third Parties
- Internal Third Parties means other companies within GUS acting as joint data controllers or processors, based throughout the world and provide shared services such as IT, legal services, system administration services, and leadership reporting.
- External Third Parties include the following, based throughout the world:
- service providers acting as processors or joint data controllers that provide student recruitment, IT, marketing, system administration, and other services;
- professional advisers acting as processors or joint data controllers, including legal counsel, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services;
- governmental authorities and regulators acting as processors or joint data controllers who require reporting of processing activities (e.g., Immigration, Refugees and Citizenship Canada, Canada Revenue Agency, governments);
- employers and potential employers who request a reference from UCW;
- other post-secondary institutions and providers of supervised training who request documentation from UCW;
- external examiners for examination, assessment, and moderation purposes;
- award partners;
- professional and funding bodies; and
- National Student Loans Service Centre, financial institutions, and companies providing student loans.
