1. Introduction
1.1 Phronesis International College is a Data Controller for your personal data as a prospective, current, and former student.
1.2 The College will only be able to exercise and fulfil its education, training, development, and support obligations if it collects, holds, and uses your personal data.
1.3 This privacy notice sets out how the College processes your personal data as prospective, current, and former students.
1.4 Collecting your personal data enables the College to understand your training needs or interests and allows it to stay in contact with you and keep you informed of its activities and developments.
1.5 Your personal data will be processed in accordance with the College's Data Protection Policy and this privacy notice as revised from time to time.
1.6 This notice also explains how you may control the use of your personal data in accordance with your rights under Section 30 of the Data Protection Act.
1.7 The College holds and processes your personal data in all formats for purposes set out in this privacy notice.
1.8 The College will at all times strive to ensure that your personal data is accurate and up to date, and it is therefore important that you always inform the College of any changes in your personal data and/or update your personal information.
2. How the College collects your personal data
2.1 The College may collect your personal data direct from you when interacting with you as a prospective student and as you submit enquiries e.g., during the College's recruitment drive initiatives like open days or at career fairs.
2.2 Personal data is collected directly from you at application and enrolment stage or from third parties like your sponsor or employer.
2.3 If you become a student, the College further collects your personal data through transactional activities as part of your learning, teaching and engagement with College's services.
2.4 The College may collect your information (directly from you) after graduation if there is an intention to engage you in various engagements or opportunities.
3. Personal Data Collected and Processed by the College
3.1 The College collects and processes different types of information from application through enrolment and throughout your stay at the College:
Data Category: Administrative - Examples: Applications records, student identity number
Data Category: Biographical - Examples: Date of birth, gender, marital status and dependents' names and ages, education, your qualifications achieved and currently being undertaken, dates of study and examination results. nationality, Identity number, passport number, country of domicile and/or origin.
Data Category: Compliance - Examples: Botswana Qualifications Authority, Human Resources Development Council, health and safety records
Data Category: Contact - Examples: Name, title, addresses, telephone numbers, and personal email addresses
Data Category: Financial - Examples: Sponsorship records, proof of payment
Data Category: Grievance or Disciplinary - Examples: Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence
Data Category: Examination and assessment - Examples: Details of your assessments and examinations results during your time at the College including transcripts and certificates.
Data Category: Security Data - Examples: CCTV images, security incident reports and IT system login and usage
Data Category: *Special category ("Sensitive") Personal Data - Examples: Racial or ethnic origin, Religious beliefs, Trade union membership, Data concerning health (including disability), Sexual Orientation. Data relating to criminal convictions and offences.
Data Category: Third Party - Examples: Marital and dependent status.
Data Category: Student welfare - Examples: Guidance and counseling records, sporting activities and accommodation
4. How does the College use your personal data?
4.1 The College processes your personal data to:
- Recruit you and tell you about its programmes, courses and invite you to study at the College.
- Consider your application to study with the College and enroll you.
- Administer academic assessments and monitor your progression.
- Arrange for your certification and/or graduation.
- Administer fees and paid for services.
- Provide accommodation services.
- Provide security, safety and health services.
- To make special arrangements for your needs e.g., your special ability and education needs.
- Manage your access to the College's services and facilities.
4.2 Personal data may also be processed where it is necessary for the purposes of legitimate interests pursued by the College or students.
4.3 Where you have given consent for the processing of your personal data especially where it is not related to your application or study, you can withdraw consent or object to your data processing at any given point in time.
4.4 Your personal data, including your photos or video footages will not be used for direct marketing purposes without your explicitly written consent.
5. What is the legal basis for processing your personal data?
5.1 Your consent is necessary if the College is to assess your eligibility to undertake any of its academic programmes and for contracting with you.
5.2 By submitting your application, you are an applicant and your personal data will be processed for the performance of contract with you or in order to take steps at your request prior entering into a contract. This is called contractual necessity.
5.3 Where processing is necessary for compliance with the College's legal obligations e.g., to comply with Botswana Qualifications Authority Act.
5.4 The College will process personal data for its legitimate interest and by consent for marketing, fundraising, and maintaining alumni network.
5.5 Should the College wish to use your personal data for any purpose other than to fulfil its legal or contractual obligations, the legal basis for this would be your explicit written consent, which you are free to withdraw at any time.
6. Sharing your personal data with third parties
6.1 The College may, under legal obligation, share your personal data with the government through its legal agencies and/or oversight authorities.
6.2 Unless required by law, your personal data will not be shared with any third party outside the College, however, personal information may be shared to support and provide academic services to you.
6.3 The College may share your personal data with your employer or sponsor detailing how you are performing academically including your attendance. Where there is no legal or contractual obligation for the College to share your personal data, your explicitly written consent or permission will be used as a legal basis for sharing.
6.4 Information is passed between various business units of the College for operational reasons.
6.5 Where sharing of personal information involves international transfer, information will only be transferred if it meets the conditions set down under the Data Protection Act.
7. How long does the College keep your personal data?
7.1 Unsuccessful applications are disposed 2 years after end of enrolment cycle.
7.2 Student records will be retained for six (6) years after the end of your relationship with the College or your graduation.
7.3 Core student data will be retained permanently e.g., full names, student identity number, academic achievement/grades, academic programme undertaken and duration of study, and academic awards.
7.4 Your personal data as an alumnus will be retained in support of your lifelong relationship with the College until there is no longer a legal basis for holding it or you withdraw your consent.
8. Your rights and further information
8.1 Where the College processes data based on your consent, you have the right to withdraw that consent at any time.
8.2 You have the right to access, rectify or object to processing and erase your personal information.
9. How to contact the College
9.1 Please contact us with any requests related to your personal information, or with any questions or queries you may have about this statement. Our email address is administration@phronesisbw.com
9.2 If you are not satisfied with how the College manages your personal data, you have the right to make a complaint to the Information and Data Protection Commission.
10. Review of privacy notice
10.1 The College will review this privacy notice every five (5) years or from time to time to meet data protection requirements.
