B5c: ORMS’ iLearn Site Policy Statement: General Data Protection Regulations 2018

This site policy includes all of the following information in simple language:

  1. What information is collected.
  2. The purpose of all processing to be performed on the user’s data
  3. The identity of the data controller and contact information
  4. List of rights
  5. The period the data is stored
  6. The mechanism for withdrawing consent
  7. The mechanism for requesting corrections, or erasures of personal data
  8. The mechanism for requesting a record of all personal data
    1. List of third parties that data will be shared with (This includes integrations such as LTI, portfolios, plagiarism, repositories, authentication etc.) including the privacy policy for each.
  9. Whether the personal data will be used for any automated decision-making process, including the significance and details of the process (e.g. analytics).

Introduction

ORMS’ iLearn is the Virtual Learning Environment (VLE) used at https://iLearn.orms247.co.uk. It is based on the Moodle ‘Course Management System’ (http://www.moodle.org), a free open source software package designed using sound pedagogical principles, to help educators create effective online learning communities.  Moodle is distributed under the GNU General Public License.

ORMS’ iLearn provides a range of features for the delivery, support, administration and participation in teaching and learning activities.  The features include content delivery and collaboration between tutors and learners, such as:

  • Content creation or upload;
  • Discussion forums and chat rooms;
  • Messaging tools;
  • Assignments;
  • Quizzes; and
  • Monitoring of users’ online activity.

Privacy and personal data

At ORMS we take your privacy very seriously. In order to provide access to the service we must collect and store some personal information about you.

Minors

Children under 16 years of age are not permitted to access the services provided by https://iLearn.orms247.co.uk. By agreeing to this privacy policy, you are also agreeing that you are 16 years of age or older.

What is collected?

When you register to use this Site, we will grant access to this Site. As part of the registration process you will be required to provide us with personal information, comprising:

  • your name and contact information, including email address.
  • information regarding your personal or professional interests, demographics, experiences with our products and services and contact preferences.

The reason for collecting location details is to set the server time to your locality so that information is posted out to you at 18:00 in your location, rather than at 18:00 London time.

Additional profile information – optional

You can choose to add a description and a photo of yourself, more contact details and a telephone number. You can also add an additional name in a phonetic form.

If you are a company contact, we may add details of your Institution or Company and Department.

As you use the site, information about the users, courses, activities and resources you interact with will also be stored and linked to your profile information.

Users (students, staff and managers) are reminded that their use of the iLearn learning environment will be logged and that this information, along with other personal data about them contained within the system, will be used by their tutors to monitor their academic progress.

How is this information used?

This information is used as follows:

Who can I contact?

The GDPR Data Protection Officer for ORMS is Lewis Moulding who may be contacted at gdpr.officer@orms247.co.uk

Who is my data shared with?

In order to provide access to learning content provided by https://iLearn.orms247.co.uk, we may share your basic profile information with the following services or providers.

  • Data storage is through ICDSoft who host the servers where the databases are located. Your data is hosted in the European Union.
  • ICDSoft’s Privacy statement can be found here: https://www.icdsoft.com/en/privacy
  • Your personal details will be created into a spreadsheet which is turned into a ‘CSV’ file for uploading into Moodle. A snapshot of Moodle to include individual course archives and a copy of the master MySQL database will be taken on or around 1st May annually and retained for 6 academic years. These files are stored in a Dropbox directory.
  • Dropbox’s Privacy statement can be found here: https://www.dropbox.com/privacy
  • Portfolio services are provided through a linked portfolio platform using the Mahara application. This is accessed through a ‘Single Sign On’ (SSO) protocol used to link Moodle and Mahara together.
  • Mahara has a detailed set of privacy statements here: http://manual.mahara.org/en/18.04/faq/privacy.html
  • Turnitin is a plagiarism prevention service that allows tutors at ORMS to check student papers and written assignments for originality against Internet sources, other student submissions, and academic databases at the same time as students are electronically submitting them. Turnitin provides tutors and students with an “Originality Report,” which is a color-coded report matching student writing with matching sources that used identical strings of words.
    • The Turnitin service involves data transfer to the United States, by accepting this policy, you consent to that transfer.
    • In meeting the requirements of Directive 95/46/EC to meet data protection requirements, organisations are free to inspect or audit Turnitin’s services any time;
    • All student work and any associated personal information is encrypted and kept secure at all times.
    • Students can keep their identity secret by using a pseudonym and by submitting papers in formats that contain little if any identifying metadata.
  • Turnitin has a detailed set of privacy statements here: https://go.turnitin.com/turnitin-and-gdpr and https://guides.turnitin.com/Privacy_and_Security
  • ORMS may disclose student’s personal data and sensitive personal data/special category data to external agencies to which it has obligations; for example for council tax, electoral registration, and visa and immigration purposes, and to other arms of central or local government, to the Robert Gordon University, to the Higher Education Funding Council for England, Higher Education Statistics Agency, Student Loans Company, Office of the Independent Adjudicator for Higher Education, Research Councils, and potentially other such organisations for defined purposes. It may also disclose information to examining bodies, external examiners, legal representatives, Police or security agencies, suppliers or service providers, survey and research organisations engaged by ORMS, and regulatory authorities such as HCPC.
  • If students have unpaid debts to ORMS at the end of their course ORMS may, at its discretion, pass this information to debt collecting agencies in order to pursue the debt.

ORMS Ltd will not transfer, disclose, sell, distribute or lease your personal information to any other third parties unless we have your permission or are required to do so by law. This process may involve sending personal information to other countries, whose data protection laws may not be as extensive as in the EU. However, we have carried out appropriate steps to ensure the same level of protection for the processing carried out in these countries as within the EU.

How long is my data stored?

Your personal data is stored as long as you are enrolled in one or more online courses at https://iLearn.orms247.co.uk.  A snapshot of iLearn to include individual course archives and a copy of the master MySQL database will be taken on or around 1st May annually and retained for 6 academic years. These snapshots will be stored offline.

How do I withdraw my consent for ORMS to store and process my personal data?

If you have previously consented to allow ORMS to store and process your personal data in accordance with this privacy policy, and you wish to withdraw your consent, please send an email to the data protection officer at gdpr.officer@orms247.co.uk.

You will no longer be able to access the services provided by https://iLearn.orms247.co.uk if your consent is withdrawn.

How do I request that my personal data is corrected or erased?

You may make corrections to your basic profile information by logging into  https://iLearn.orms247.co.uk  and editing your own profile.

If you have questions or would like any other data to be corrected or erased, please send an email to the data protection officer at gdpr.officer@orms247.co.uk.

How do I request a record of all my personal data that has been collected?

You may request a record of all of the personal data relating to you that has been collected in accordance with this privacy policy. To do so, please send an email to the data protection officer at gdpr.officer@orms247.co.uk.