Student Privacy Notice

TRACKTION  is a 3-year Erasmus + Project (September 2017 – June 2020) focused on improving VET graduate tracking at institutional level. Tracking is commonly understood here as all systematic approaches that VET institutions put in place to record information on graduates, with regard to their learning progress, skills acquired, perceptions, routes into employment, self-employment, or further training. TRACKTION is a collective endeavour comprising 6 organisations from Spain (Valnalón and Tknika), Estonia (PKHK), Italy (Cometa Formazione-Oliver Twist School), Netherlands (Alfa College) and the UK (Education & Employers).

This notice relates to information about you which will be collected by Valnalón or your VET school provider if it is a project partner and passed to Tracktion as part of a new tracking protocol, which will be piloted during 2019 and 2020.

An online questionnaire with quantitative and qualitative questions will collect destinations’ data from a sample of VET students from Estonia, Italy, the Netherlands and Spain. All VET students taking part in the pilot will be surveyed 4 to 2 months before graduation, 6 and 18 months after graduation.

Your responses will help your VET school to evaluate and improve their courses.The survey is also of european/national/regional significance as it allows policy makers, charities, journalists, researchers and others to understand the VET sector and the state of the VET graduate labour market.

This notice sets out information about who processes your information, what they use it for, the legal bases for this processing, and your rights under data protection legislation. This notice is regularly reviewed and sometimes updated, for example when organisations change their name, or to clarify how your information is used. Updates may be made at any time and you will always find the most up to date version at www.tracktionerasmus.eu/privacy-notice-tracktionsurvey.

 

About the survey

  • What will I be asked about?
  • What happens to my information if I quit the survey half way through?
  • Who carries out the TRACKTION survey?
  • How did Tracktion project get my contact details?
  • Can someone else answer the survey on my behalf?
  • Will I be contacted for further surveys?

 

What will I be asked about?

The protocol will gather data on graduates´ destinations 6 and 18 months after graduation in terms of employment, further education and training and participation in volunteering or civic engagement activities. Qualitative aspects regarding satisfaction on quality and relevance of training received, quality of employment obtained (type of contract, earnings, contrated and worked hours) and career progression opportunities will also be collected.

What happens to my information if I quit the survey half way through?

If you start the survey but don’t complete it we’ll send you an email or text reminder or try to contact you by phone to complete it later. If you don’t want to finish the survey we will keep your answers if you completed the core questions or delete everything if you didn’t get that far.

Who carries out the TRACKTION survey?

VALNALON, as TRACKTION Project coordinator, is a Controller of your information. Education & Employers Taskforce (henceforth, E&E), the research partner in TRACKTION Project,  acts as a Processor to do work on behalf of VALNALON and other partners of TRACKTION project but may also act as a Controller. VALNALON is a public company.

How did TRACKTION project get my contact details?

Contact details for the Tracktion survey are provided by the VET education provider you attended.

If your VET education provider is not a partner of the Tracktion Project, VALNALON will collect your contact information so that you can take part in the TRACKTION survey as described in this privacy notice.

Your contact details are only used by VALNALON and its data processors to conduct the TRACKTION survey. Ccopies are deleted by each organisation when they are no longer needed for the survey. We anticipate that this will be approximately 6 months after the last cohort of 2019-2020 graduates has been surveyed to allow for any audit or re-survey that might be required by the funding body SEPIE, Erasmus + National Agency in Spain. Your contact details are therefore likely to be deleted in November 2020.

Legal basis for processing your contact details information:

Processing of your contact details is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller (See GDPR Article 6(1)(e)) and for statistical and research purposes (See GDPR Article 89).

Can someone else answer the survey on my behalf?

No, if you don’t complete the online survey we’ll try to contact you by email, text message or by phone.

Will I be contacted for further surveys?

No, you will only be contacted to take part in the TRACKTION survey

 

How your information is used, and who uses it

  • Purpose 1 – Your survey responses will be provided to your VET education provider
  • Purpose 2 – Published statistics
  • Purpose 3 – Equal opportunity, research, journalism and other processing for statistical and research purposes
  • How is my Tracktion information linked to other information?

 

Purpose 1 – Your survey responses will be provided to E&E

Your responses will be received by E&E who will only use the information for research and statistical purposes to help your VET provider improve the outcomes of their courses. This research is used by VET providers to improve courses and services and to promote them to current and prospective students.

VET providers will receive regularly updated information from survey responses during the survey period. This information may only be processed for the purpose of monitoring the progress of the TRACKTION survey.

The survey asks your current contact information because this protocol is a longitudinal study, aims to collect your data in different time points. It will provide a complete picture of academic and professional career of VET graduates so as to better understand patterns of labour market entry and transitions.

Legal basis for processing your information for Purpose 1 – these cover use of personal data by VALNALÓN and E&E:

Processing of your information for Purpose 1 is necessary for the performance of a task carried out in the public interest (see GDPR Article 6(1)(e)) and for statistical and research purposes (see GDPR Article 89). Processing may also be necessary for the purposes of the legitimate interests pursued by your VET education provider except where such interests are overridden by your interests or fundamental rights and freedoms (see GDPR Article 6(1)(f)).

Purpose 2 – Published statistics

TRACKTION Project partners, your VET provider, and some of the public authorities (regional and/or national departments for the Economy and/or Education from Estonia, Italy, The Netherlands, Spain and United Kingdom) publish statistics about the outcomes of VET.

When producing this material for publication, VALNALON applies its disclosure control to ensure that no Personal Data is included and that individuals cannot be identified from published material.

Processing within this Purpose 2 may also be carried out by E&E

Legal basis for processing your information for Purpose 2 – these cover use of personal data by VALNALÓN and E&E:

Processing of your information for Purpose 2 is necessary for the performance of a task carried out in the public interest (see GDPR Article 6(1)(e)) and for statistical and research purposes (see GDPR Article 89).

Purpose 3 – Equal opportunity, research, journalism and other processing for statistical and research purposes

TRACKTION survey information is used for research into VET and the student and graduate population. This research is academic, journalistic or for personal reasons. TRACKTION prohibits the identification of individual students by those carrying out this research and information is not shared on a named basis.

VALNALON and the other Controllers may also supply information to third parties where there is a legitimate interest in doing so for statistical and research purposes. Examples of use for this purpose include:

  • Provision of information to students and prospective students
    • Equal opportunities monitoring
    • Research – this may be academic research, or other statistical research where this is in the public interest
    • Journalism – where the relevant publication would be in the public interest

Users to whom information may be supplied for Purpose 3 include:

  • VET sector bodies
    • VET providers
    • Academic researchers and students
    • Local, regional and national government bodies
    • European bodies: European Commission Expert Group on Graduate Tracking , the European Quality Assurance in Vocational Education and Training (EQAVET)

Information supplied by TRACKTION to third parties within Purpose 3 is supplied under contracts which require that individuals shall not be identified from the supplied information and this means that they also cannot use it to take decisions (based solely on automated processing including profiling) about you.

Each agreement specifies the duration for which data may be processed. This is usually one year but may be longer if necessary for the specific research purpose. Each request for Tracktion information under Purpose 3 is assessed for its compliance with data protection legislation and its compatibility with this Collection Notice.

TRACKTION ensures that only the minimum amount of information necessary for the specified research purpose is supplied to users. If the supplied information is to be published a disclosure control must be applied to ensure that individuals cannot be identified from the published material and it does not constitute Personal Data.

TRACKTION information may be linked to VET school information and supplied to researchers.

Processing within this Purpose 3 is carried out by TRACKTION Project Partners. Other controllers may also process data for this purpose where this is necessary to fulfil their public functions.

Legal basis for processing your information for Purpose 3 – these cover use of personal data by TRACKTION for statistical and research purposes:

Processing of your information for Purpose 3 is necessary for the performance of a task carried out in the public interest (see GDPR Article 6(1)(e)). Processing may also be necessary for the purposes of the legitimate interests of TRACKTION in disseminating VET information, or the legitimate interests of third parties in undertaking research in the field of VET (see GDPR Article 6(1)(f)).

In either case processing of your information is necessary for statistical and research purposes in accordance with GDPR Article 89(1).

 

Your privacy rights

  • What are my rights?
  • Is my data held securely?
  • Is my information transferred to other countries?

 

What are my rights?

Data protection legislation gives you rights over your personal data. These include rights to know what information is processed about you and how it is processed. These rights have to be met by TRACKTION  and any other organisation which takes decisions about how or why your information is processed.

You have the right to be informed about how your personal data is used. This  privacy notice is regularly reviewed to ensure that it accurately describes how your information is used. This notice may be updated from time to time, for example when new legislation is enacted, or when new policies are implemented by the public authorities listed under Purposes 2 and 3. The most up to date version can always be found at www.tracktionerasmus.eu/privacy-notice-tracktionsurvey.

Under the GDPR, you have the right of access to your personal information and rights to rectify inaccurate information; restrict processing; and object to processing. These rights are limited in certain circumstances by the GDPR where data is only processed for research or statistical purposes.

If you do not want to complete the survey there is no obligation to do so. If you don’t want to be contacted at all for the survey please email rgpd@valnalon.com.

If you think there is a problem with the way Tracktion is handling your data, you have the right to complain to your National Data Protection Authority

Is my data held securely?

All information you provide to us is stored on secure cloud-based servers provided by a third party vendor. This information is currently being hosted outside the EEA, in the US. Our third party vendor is contractually obliged to put in place protection before exporting or processing any of your personal data, and it has confirmed that the transfer of personal data to the US is in accordance with the EU-US Privacy Shield framework. Although we will do our best to protect your personal data, we cannot guarantee the security of the information transmitted to our sites. Any transmission will be at your own risk. Once we have received your information, we will use appropriate security features and procedures to try to prevent unauthorised access.

Is my information transferred to other countries?

We will not share your information with parties outside of the European Economic Area (henceforth, EEA) unless we are legally permitted or required to do so. You should be aware that certain non-EEA countries do not require the same standards of protection of personal data as are legally required in the EEA. If we send your data to these countries, we will put in place appropriate and suitable safeguards to protect your personal data.

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