Data Protection Notice - Students

This additional Privacy Notice for Students and Academic Services (“Privacy Notice”) should be read in conjunction with INSEAD’s Personal Data Protection Charter.

This additional Privacy Notice applies to all individuals who are enrolled as a student in any INSEAD Programme, PhD students of INSEAD or any individual undertaking any Academic Services at INSEAD, hereinafter collectively referred to as “student(s)”. It applies throughout a period of study, where it leads to an award or recognition of any kind from INSEAD (either standalone or in collaboration with a partner institution), regardless of their location of study.

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INSEAD requires to process and retain certain personal data relating to you, by virtue of your being a student of INSEAD.

Sources of Data

The personal data INSEAD holds about you is obtained from a number of sources, including the following:

• Information you have provided when making enquiries to INSEAD or as part of recruitment events
• Information you have provided on your application form as part of the admissions process, including information from referees
• Information you provide us with during the enrolment process
• Information you provide us with during the course of your study
• Information that INSEAD requires to record about you during your studies e.g. grades
• Funding organisations such as Brain Capital or other sponsors
• Public authorities and other institutions.
• Partner institutions or organisations such educational partners, professional bodies or employers.

What Personal Data INSEAD processes

Personal data about students is processed in different data systems of INSEAD and manually.

INSEAD processes the following data:

• Personal details and identification data e.g. name, surname, given student number, home town, gender, nationality, native language, study language, language when using services, personal identity number, names, copies of passport or identity documents, date of birth, CV;
• Contact details e.g. email, phone number, social network if relevant;
• Family, lifestyle, social circumstances if relevant, e.g. personal data of your family present in our of INSEAD campuses;
• Education & training e.g., targeted degree/course/training, faculty, validity and status of the right to study including programs with other institutions, study period, notifications of absence and, generally, data about student’s plan, performance and completed degree and related certificates/transcripts of studies;
• Employment details if relevant;
• Financial details, e.g. bank details, obligation to pay a tuition fee, studies subject to a fee and information about fees paid;
• Specific conditions requesting tailored support;
• Feedback on studies collected through the feedback system;
• Breaches and alleged breaches of the Code of Conduct and generally documents related to disciplinary action taken against students.

Purposes of Processing

INSEAD requires to process the personal data it collects about you for the purposes delivering a relevant educational programme of study to you, any other service you receive from INSEAD and to execute all the administrative and ancillary tasks relevant to our service delivery. This includes but is not limited to the following:

• Organising teaching and examinations and delivering student’s programme of study (both face to face and online, including streaming and/or recording of courses and lectures);
• Administration of student’s life and academic attainment e.g. maintain personal data and contact information, administration of visas and immigration requirements, absence management, marks and grades, plagiarism identification, computing, library, careers service, web, communication and sports centre;
• Management and administration of INSEAD’s property (including access to INSEAD’s locations and preventing and detecting crime e.g. by use of video surveillance or access monitoring);
• Administer the financial aspects of studying e.g. payment of fees and collection of debts owed even via external debt collection agencies, as well as managing scholarships, studentships and prizes;
• The provision of advice and support to students, including welfare, coaching and counselling, and academic services and careers services;
• Management of behavioural or disciplinary issues and complaints;
• Collect data, records and statistics for research purposes, management information and to monitor fulfilment of applicable policies;
• Publicity and marketing including the use of images and photographs;
• Organization on in person and virtual events.

Legal Basis for Processing your Personal Data

The right of INSEAD as the data controller to process personal data about students is based on a number of legal basis that legitimise its processing activities. Given the wideness and ramifications of matters for which INSEAD processes your personal data to provide the relevant academic services, the majority of INSEAD’s processing activities in are based upon the following grounds:

• To fulfil the agreement for educational or academic services (Art. 6.1(b) GDPR): If you have accepted an offer to become a student of INSEAD you are required to accept our student terms and conditions, Code of Conduct and other documents. This acceptance results in a contract being formed between you and INSEAD.  
• To perform tasks carried out in the public interest (Art. 6.1(e) GDPR) or INSEAD’s legitimate interest (Art. 6.1 (f) GDPR): INSEAD may process personal data to carry out certain functions required to operate as an Academic Institution. This includes for example processing related to teaching, examining, promoting research, granting of awards, disciplining students and collaborating with other institutions. 
• Compliance with a Legal Obligation (Art. 6.1(c) GDPR): Sometimes INSEAD may need to process your personal data to comply with a legal obligation imposed upon INSEAD.
• Your Consent (Art. 6.1(a) GDPR): Some processing may trigger your explicit consent. In such cases, your consent will be sought as and when required. You have the right to withdraw consent at any time without prejudice to your status within INSEAD.

Retention of Your Personal Data

Once you become an enrolled student, INSEAD retains your personal data in line with INSEAD’s data retention policy. Where some of your Personal Data are no longer needed, these will be securely deleted from the systems. Please note that once you have enrolled as a student, some personal data will be retained on a permanent basis. This is needed for INSEAD to maintain a permanent archive of alumni and diplomas awarded and provide services to its alumni community, including certificates as well as to comply with relevant laws and regulations.

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For other information on INSEAD’s processing activities, including your rights, the third parties your personal data may be shared with and the relevant contact details please refer to INSEAD’s Personal Data Protection Charter.

Last update: 28 September 2020