Thomas More considers the protection of your privacy very important. We want to inform you as well as possible, respect your privacy and give you control over what happens to your personal data (hereafter also: data). Below you will find information about what data we collect, why we collect it, how long we store it, what your rights are and how you can exercise them.
In order for Thomas More to function, the retrieval and processing of personal data is sometimes necessary. The university college collects personal data from its threefold assignment (education, research and services) and, of course, also as a regular employer and contractor. This includes personal data of students, participants in training courses, participants in surveys and visitors to our website.
Personal data will only be processed in accordance with the applicable regulations, in particular the General Data Protection Regulation (GDPR).
Thomas More may amend this privacy statement from time to time, for example after legislative changes. Changes will be published on thomasmore.be/privacy. By regularly consulting the website, you remain informed of the changes.
Who is responsible for the processing of personal data?
The person responsible for processing the personal data is:
VZW Thomas More Mechelen-Antwerp, registered office at Zandpoortvest 60, 2800 Mechelen, company number 0455.411.733.
VZW Thomas More Kempen, registered office at Kleinhoefstraat 4, 2440 Geel, company number 0409.667.028
"Thomas More" is understood to mean the full operational collaboration between and operational unification of the Flemish universities of applied sciences VZW Thomas More Mechelen-Antwerp and VZW Thomas More Kempen. Both non-profit organizations have identical privacy rules.
What personal information might we process about you?
Data of prospective students
We process personal data of candidate students who register via our website. This concerns information that you give us yourself: your contact details, date of birth and study interests.
We process the following personal data of our students:
Study guidance: identification data, financial data, personal characteristics, health data, migration background (nationality), education and training.
- For study counselling: based on legal and/or contractual principles.
- For study facilities for disadvantaged groups (students with disabilities / / scholarship students): on the basis of permission.
Student facilities: identification data, financial data, personal characteristics, health data, migration background (nationality), education and training, lifestyle, family composition, leisure activities, housing characteristics, occupation.
- On contractual basis or on the basis of consent.
Research: e-mail address.
- Based on the legitimate interest.
Data from participants in training sessions
We process personal data of participants in our training sessions. This concerns identification data that you give us yourself. This data is processed by the training/research group that provides the training.
Data from participants in survey
We process data from participants in surveys. Personal data in the context of research can take very different forms. Sometimes the information is linked to specific persons and in some cases the information is anonymised or pseudonymised. The data is processed by the research group involved.
Supplier and customer data
We process supplier and customer data. It concerns identification data. This data is processed by the financial services or by the Marketing and Communication Department.
Information from alumni
We process personal data from Thomas More alumni. This concerns identification data for which you give your consent to processing. In addition, we store your e-mail address for making inquiries. The aforementioned data will be processed by the course programme you have followed and the central research department.
Data of contacts with the work field
We process personal data from our contacts with the professional field. This includes, for example, identification data or data required for the internship assessment. This information is processed by the course programmes and researchers.
On what grounds do we process personal data?
In most cases we will process your data to be able to execute the contract that exists between you and Thomas More.
In addition, in many cases we process data because we are legally obliged to process your personal data. For example, we are obliged to pass on certain data to the Higher Education Database because of decreed rules on study progress monitoring.
Furthermore, some of the processing operations fall under the legitimate interest of Thomas More. Examples include combating fraud and direct marketing. In doing so, we always check whether your interest in the protection of your privacy and your rights with regard to your personal data do not outweigh the interest of Thomas More.
Finally, a number of processing operations are based on consent. This is the case, for example, when placing photos of you on social media. You are always free to refuse your permission or withdraw it again.
What do we use your data for and what is the storage period?
Data of prospective students
We use data that you have passed on to us through your registration on the website in order to adapt our info-moments to you as well as possible. In addition, we can keep you informed of the info-moments that suit your interests. On behalf of Thomas More, selected third parties can help us with a correct execution.
The details of prospective students are kept for 1 year.
We use student data to be able to carry out our teaching assignment properly, namely conducting student administration and supervision.
In addition, research on the student data is carried out by staff of the general services of Thomas More with the aim of optimizing the student support and progression and evaluations of course programmes.
Student data is exchanged with the government. This is done with a view to financing the student and decreed rules on study progress monitoring and reducing administrative inconvenience.
We can also share student data with your internship. This always happens with your knowledge.
Commissioned by Thomas More, selected third parties can participate in the execution of the teaching assignment. A processing agreement is always concluded with these parties in order to ensure a careful handling of personal data.
On an individual basis, external exchange is only possible if the student has declared his agreement, following a court order or in case of non-payment by the student. In the latter case, personal data will be communicated to a collection agency.
Student data is kept as long as the student is connected to Thomas More. Study results are not deleted. In this way, Thomas More can issue a certificate later in the event of loss of documents by the former student. Student data is never kept longer than necessary for the purpose of the above mentioned objectives.
Data from participants in training sessions
The personal details of participants in training sessions are used to ensure that the registration and training themselves take place correctly.
This data is kept up to and including the end of the training or as long as relevant legislation requires it.
Based on the legitimate interest, participants in direct marketing training can be re-approached for similar training courses. Participants can unsubscribe at any time in the manner provided under the heading 'privacy rights'.
Some research groups/course programmes choose not to delete data for attestation. In this way, Thomas More can issue a new certificate in case of loss of documents by the former participant.
Data from participants in surveys
Research data serve the research and service assignment of Thomas More. More information about the processing of research data by Thomas More can be found in the privacy statement for research and services.
Supplier and customer data
Supplier and customer data are managed by administrative services with the aim of conducting correct administration.
The name and address details of customers of our web shops are processed with the aim of providing the delivery. This data can also be passed on to selected third parties for the same purpose.
Data from customers of the webshops can be maintained in the context of direct marketing activities. Participants can unsubscribe at any time in the manner provided under the heading 'privacy rights'.
These personal data are kept for as long as the legislator requires this or as long as the data are necessary for the purposes mentioned above. Information from customers of the webshop can be kept in the context of direct marketing activities.
Information from alumni
Data from alumni are processed in the context of research, vacancies and newsletters.
This data is saved until the given permission is withdrawn.
Based on the legitimate interest of Thomas More, alumni can be approached by e-mail up to 2 years after their graduation to take part in surveys about the course programme they have followed and the match with the professional field. The purpose of these surveys is to improve the quality of our education. Alumni can unsubscribe at any time for the surveys in the manner provided under the heading 'privacy rights'.
Data of contacts with the work field
Data from contacts in the field are mainly processed in the educational context, for example in the context of internships, quality of the programmes or quality of research.
This data is kept for as long as is necessary for these purposes.
What about placing data on the website?
We consider anything you place on the public section of the Thomas More website as non-confidential information. Thomas More may use this information for its own purposes. Of course, we take into account the restrictions stipulated in the GDPR.
How do we deal with images?
Photographs and film shots can be made during activities within the university college or in function of the university college. This material can be used for internal and external publications, such as for publicity, promotional material, websites, press releases, etc .. It is possible that students also appear on these images. When publishing this visual material, the student's privacy interest is weighed against Thomas More's interest in publishing the material.
For external publications of targeted visual material of students, the relevant student(s) is (are) always first asked for permission.
In order to make our education as accessible as possible, video recordings are sometimes made of the lessons, for example to enable a sick student to follow the lesson. Students are informed before class starts that the lesson will be recorded. We make every effort to keep students out of the picture as far as possible. The recordings of the lessons are only placed on internal platforms.
We can continue to use images of the students, as indicated above, after the students have left the university college, if this is in the interest of our education.
How do we protect your personal data?
The number of Thomas More employees who have access to your personal data is limited. Thomas More staff can only access your personal data to the extent that they need this information to perform their tasks properly.
In addition, Thomas More has appointed a Data Protection Officer who advises us about the privacy rules and who checks whether Thomas More complies with the privacy rules.
We use technical measures to protect your personal data against unauthorized access, unauthorized use and loss or theft of your data, such as: password protection, firewalls, antivirus, encryption, etc.
What are your privacy rights and how can you exercise them?
If you want to exercise one of the following rights you can submitting an application via email@example.com.
Right to access
You have the right to obtain a definite answer from Thomas More about the processing or not of your personal data and, if so, to gain access to this personal data.
Right to rectification
If your personal details are incorrect, you have the right to have them corrected by Thomas More.
Right to erasure ("right to forgetfulness")
You have the right to obtain from Thomas More the deletions of your personal data without any unreasonable delay in the following cases:
- When your data is no longer required for the purposes for which it was collected or processed; or
- When you withdraw your permission and there is no other legal basis for the processing; or
- When you object to the processing and there are no prevailing compelling justified grounds for the processing; or
- When your data has been processed unlawfully; or
- When your data must be deleted due to a legal obligation.
Right to withdraw consent
You have the right to withdraw your consent at any time. It is not possible to withdraw your permission with retroactive effect.
Right to restrict processing
You have the right to obtain from Thomas More restrictions on the processing of your data:
- During the period that Thomas More needs to check the accuracy of your data, in case of dispute; or
- If the data processing is unlawful and you request a restriction of processing instead of erasing the personal data; or
- When Thomas More no longer needs your data, but you need the data for legal action; or
- During the period that Thomas More needs to assess the presence of the grounds for deleting the personal data.
Right to object
You have the right to object to the processing of your data at any time due to the reasons associated with your specific situation.
Right to transfer data
You have the right to obtain the data you have provided to Thomas More in a structured, standard and machine-readable form. You have the right to transfer this information to another controller, if the processing is based on your consent or on an agreement and if the processing is carried out by automated processes.
Right to file a complaint
You have the right to file a complaint regarding the processing of your data with the Belgian Data Protection Authority.
Addendum Privacy Statement for online proctoring (16-04-2020)
Below you will find a supplement to the privacy statement as a result of the organization of digital exams with the online proctoring tool in times of the Corona measures imposed by the government.
In this supplement to the privacy statement we describe what happens to your personal data and how your privacy is safeguarded when you take a digital exam with online proctoring.
1. Who is responsible for processing my personal data with online proctoring?
Thomas More is responsible for the data processing described in this document. The personal data is processed in accordance with the applicable privacy legislation, including the General Data Protection Regulation (GDPR). Proctorio is bound by a processing agreement with Thomas More and is therefore bound by the GDPR.
2. Which (categories of) personal data are processed?
If you take a digital remote examination where Thomas More monitors online, Thomas More processes the following personal data:
a. first name and surname;
b. email address;
c. image of your student card or identity card;
d. your photo taken via the webcam of your computer/laptop;
e. video and sound recordings of the room you are in while taking the exam, made via the webcam of your computer/laptop;
f. video recording of the on-screen activities while taking the exam;
g. keystrokes and mouse movements while taking the exam;
h. video recording of you while taking the exam made via the webcam;
i. the IP address of the computer network to which your computer/laptop is connected;
j. the web pages you visit during the exam;
k. your answers to the exam questions.
3. for what purpose will my personal data be processed and on what legal basis?
Personal data will only be used for the following purposes:
a. authentication. After making the exam, we will check whether you have taken the exam for which you have registered;
b. fraud prevention. After taking the exam, it will be checked whether you have abided by the applicable rules and have not used unauthorized sources such as cheat sheets, chats and the internet unless the sources allowed by the teacher;
c. time frame check. After making the exam, we will check whether you have taken the exam within the set time frame;
4. Legal basis of the processing
We process your personal data on the basis of "a task carried out in the public interest or in the exercise of official authority of the controller" (Article 6.1 (e) GDPR). This means that the processing is necessary for the performance of a task carried out in the public interest in the exercise of official authority vested in Thomas More with a view to the legitimate interests pursued by Thomas More, and that your rights and freedoms are sufficiently safeguarded.
In cases in which Thomas More chooses to make use of online monitoring for remote examinations, it is necessary that Thomas More
- checks who's the person taking the exam;
- can establish that no fraud was committed during the examination; and - can establish that the examination was taken within the set time limit.
When taking an exam on the campus of Thomas More, these aspects are guaranteed by physical supervision.
With due observance of the guarantees mentioned in this document, the rights and freedoms of students are adequately safeguarded.
5. Who has access to my personal data?
The personal data collected when taking a remote exam with online proctoring is evaluated using artificial intelligence and is only viewed by Thomas More employees who, by virtue of their position, play a role in the processing of personal data for the above-mentioned purposes and for whom it is necessary to have access to the personal data in case of suspicion of fraud (e.g. members of examination committees, exam appeals committee).
6. Will my personal data be shared with third parties?
The personal data collected in the context of online proctoring (see question 2) are stored on a secure server of the company Proctorio. This is the company that provides the tool Thomas More uses for online proctoring. Proctorio's encryption algorithms have proven safe through years of testing and are used by the world's most critical and impenetrable applications. They use dual-encryption, zero-knowledge technology to encrypt personal data during transfer and in storage with end-to-end protection for every piece of information that leaves a student's computer during an exam. Thomas More has entered into a processing agreement with Proctorio to ensure that your personal data is carefully processed.
7. How long will my personal data be stored in the proctoring tool?
Personal data will be stored until the appeal period after the results have been communicated has expired in accordance with the education and examination regulations. In the case of fraud files, personal data is stored until the fraud file is processed.
How can I contact Thomas More?
For more information about this privacy statement or for complaints related to the processing of your personal data, you can contact the Data Protection Officer of Thomas More via firstname.lastname@example.org.