The Access Platform is a Data Processor

The Access Platform is a Data Processor. Therefore, as a customer using the service, you are the Data Controller. This means that we collect and process data from your users and you are ultimately in control of and responsible for that data. We are responsible for handling that data on your behalf in an appropriate manner.

To help you manage your responsibility as a Data Controller, we have created a 'Privacy Extract' that you can edit and add to your website Privacy Policy should you feel it is appropriate. This 'Privacy Extract' is available in the Legal Setup on The Access Platform article. Please then add a link to your Privacy Policy on the Legal Page in the Dashboard. Your Privacy Policy will then be displayed automatically in our user click-through terms when they sign up.

Note that whilst The Access Platform is a Data Processor, there is one processing activity for which we position ourselves as a Data Controller. This process is the anonymisation of all user activity on The Access Platform into a central and separate database. We perform this processing to better understand our users, which helps us to both improve our service and provide greater insight for our customers. This is made clear in our Standard Terms and Privacy Notice that we provide your users with so that they can read and accept it at their discretion. We perform this processing under the Lawful Basis of Legitimate Business Interest and have created a Balancing Test document that explains how we have come to this conclusion in conjunction with our legal counsel.

Data Collection Options
The Access Platform gives customers a range of data points they can collect from prospective students. You can simply adjust these options through 'Optional Data' in 'Settings' to collect the data that is most relevant and useful for you. Read more about Data Collection on The Access Platform.

IP Assignment
All content that Ambassadors submit to the service is automatically owned by the institution they represent through IP Assignment. Read more about IP Assignment on The Access Platform.

Standard Terms and Order Form Process
The Access Platform operates in the same way for all customers and we operate on Standard Terms for all customers. These Standard Terms are accepted upon account creation and can be downloaded from the Dashboard at any time. Please contact our Customer Success Team if you have any questions about our Standard Terms.

The commercial arrangement between The Access Platform and our customers is managed through an Order Form that describes the arrangement with a simple, easy-to-understand table.

Your Data Rights
As The Access Platform is a Data Processor and you are the Data Controller, you are able to process the data you collect from users according to your own Privacy Policy. You can then integrate it with your wider marketing and communications strategy provided you have received appropriate marketing consents.

Marketing Consent
The Access Platform seeks marketing consent on your behalf. This data point is available as part of the information you can see and export from the Prospect List on the platform. Note that we only seek to collect marketing consent for you via email. Previously we collected marketing consent for communications via phone, SMS, and email. As we found a very low acceptance rate on every option apart from email, we believe that by focusing solely on this option we can drive a higher overall marketing consent rate.

Age of Users
Our Standard Terms state that users must be over the age of 13 to use The Access Platform unless they are a citizen of an EU Member State which requires them to be older when creating an online account without parental guidance (please see diagram below). We collect the nationality of users in order to assess the minimum age they should be to create an account on our service and then adjust our age consent terms in real-time to ensure we give a GDPR-compliant minimum age. We rely solely on users consenting that they are the appropriate age for the service and do not have built-in checks. We think this as appropriate based on current GDPR precedent and the low-risk nature of our service to users for a standard term. 

The latest minimum ages for citizens to create online accounts without parent guidance from EU Member States:

If you have any questions about any of the points raised in this article, please get in touch.

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