About us:
Pathways is a project aimed at increasing the number of young people going into Higher Education under the Office for Students’ Uni Connect programme. Pathways consists of the University of Leicester, De Montfort University, Loughborough University and the Leicester College. Pathways is the programme which is being run in partnership with schools and colleges in Leicestershire and Rutland.
The University of Leicester is our lead institution. The University of Leicester Data Protection Officer (DPO) is: Parmjit Singh Gill, DPO & Head of Information Assurance Services, Information Assurance Services (IAS), Planning, Legal & Governance Services. Email: DPO@leicester.ac.uk (https://le.ac.uk/ias).
This privacy policy explains how we collect and use your personal information when you take part in our activities and events, or when you visit our website, in accordance with the UK General Data Protection Regulation (UK GDPR).
It is important you understand this page, and read it together with any other privacy notices we may provide when we are collecting or processing personal information about you. This is so you are fully aware of how and why we are using this information.
Pathways’ Privacy Policy
EMWPREP Closure Statement
We need to tell you about some important changes to the EMWPREP project you have taken part in.
EMWPREP is a collaborative research project, which several universities and Uni Connect partnerships have used to track participation in their outreach activities over time and measure the impact of those activities. If you have taken part in outreach activities delivered by these organisations, you, your parents, or your school have likely given us permission to use your data for this research. Unfortunately, the current EMWPREP project is coming to an end. Because universities and Uni Connect partnerships still have a duty to continue this research, the data held as part of the EMWPREP project will be transferred to a larger service which conducts similar research called the Higher Education Access Tracker, or HEAT for short. This means the research carried out by EMWPREP will become part of a larger, national dataset.
HEAT will continue to support young people in their journey towards higher education by building evidence and further collective knowledge around what works for equality of opportunity in higher education and beyond.
What does this mean for you?
In accordance with your data protection rights, we want to assure you that your personal data will be handled with the utmost care and security. Your data collected as part of the EMWPREP project will be securely transferred to HEAT. Where it will continue to be used solely for the purpose of conducting educational research to check if research activities are reaching the right people and creating a positive impact.
· Data Protection: Your personal data will continue to be protected under the UK GDPR and Data Protection Act 2018, and we will ensure that all data handling practices comply with the law. You can read how the HEAT Service uses and manages the personal information of individuals, in accordance with the provisions of data protection law here.
· Right to Object: You have the right to object to processing of your personal data. If you or your parents don’t want your data to be part of the new project, please contact us at reach@le.ac.uk
Below is our full privacy notice in line with our new data collecting, processing, and storage with HEAT as of 1st August 2025. We will still be using EMWPREP as we manage this move over the Summer and only for the purposes of extracting data, auditing it, and transferring it over, but any new data collected from the 1st of August 2025 onwards will be processed and stored on HEAT and in line with the full privacy notice given below.
If you have any questions or would like more information about this change, please do get in touch at reach@le.ac.uk
1. What information are we collecting and why?
We will collect the following information from you and/or your school/college: Full Name, Date of Birth, Postcode, Gender, Ethnicity, School/College Name, and email address, for the purposes of:
· organising events/activities, including event selection;
· tracking future outcomes of event participants, including applications to Higher Education Institutions;
· monitoring and research including (but not limited to) evaluation of the impact of events/activities (including events not organised by Pathways);
· producing statistics, including event application and participation numbers, and participant outcomes; and
· sending you additional information about the Pathways programme, as well as helpful resources relating to applying to Higher Education by email.
We consider the processing of your personal information for the above purposes to be necessary for the performance of tasks we carry out in the public interest (i.e. running events to promote access to Higher Education, informing students of their educational options and carrying out related evaluation, tracking and research. See Appendix A for more information on Pathways and our use of Public Task as our legal basis for processing data where direct consent is not sought.
If you and/or your school/college are asked to provide any sensitive information about yourself, such as:
– your ethnicity,
– information about your school/ college (i.e. GCSE or post-16 results),
– your current or past eligibility for Free School Meals,
– your Pupil Premium status,
– health/disability status,
– care status,
– Young Adult Carer status,
– whether your parents/carers have served in the Armed Forces,
– your residential status.
This will be held in identifiable form and, as well as the above purposes listed at start of this Section 1, is used for research and evaluation purposes and for equalities monitoring, both by Pathways and as part of wider national research projects with appropriate conditions of access to the data.
Any other uses of this sensitive information (e.g. to make accessibility adjustments, for contact details in the event of an emergency, or otherwise facilitate your attendance) require your consent, which is given by you providing us with the information, having had the opportunity to read and understand this Notice and the Notice used at the beginning of any Pathways activity. The supply of such information will always be optional.
If we ask for your photograph to be taken at any Pathways event, we will explain what we intend to use it for and seek your consent. We may use carefully selected third party service providers to run event bookings, or to contact you by email, but will always make sure they commit to comply with the law when handling your personal data.
Unless you have been told otherwise at the point of asking, there is no statutory or contractual requirement to supply us with any of your personal information. If we asked for your consent to use your personal information, you can withdraw this at any time by contacting us as reach@le.ac.uk
2. How will my personal data be collected?
– completion of data collection forms before or during activities you take part in. This may be completed by an adult with parental consent if you are under a certain age,
– completion of additional information forms required for taking part in certain events, such a campus visits or community events, which may include photography or film footage consent, emergency contact details, medical information,
– directly from your school/ college/ community group if we are collecting this data via a Data Sharing Agreement (and using the legal basis of Public Task),
– completion of paper-based evaluation forms or surveys at the activities you take part in,
– completion of electronic evaluation forms or surveys (Pathways use Jisc) at the activities you take part in.
3. Who will my personal information be shared with?
We may share data with suppliers or partner(s) with whom we collaborate to organise Pathways’ activities, or for evaluation and research purposes. These include:
· The Office for Students (OfS),
· the National Pupil Database (NPD),
· the Higher Education Statistics Authority (HESA),
· Universities and Colleges Admissions Service (UCAS),
· CFE Research (Uni Connect national evaluator),
. the Department for Education, and
. the Higher Education Access Tracker HEAT service who provide us with data storage, analysis and research services, postcode profiling and with consent, HEAT Track.
Pathways is a subscribing member of the HEAT Service and they are a data processor (an organisation who handles personal data on our instructions) for the data we collect from you. Our Contract with HEAT includes details about the organisational and technical measures they have put in place to secure the data we share with them. All their services and Sub-processors (organisations who use personal data under contract to HEAT, and whom are bound by the contest Pathways has with HEAT) are based in the UK.
HESA and HEAT may share your data as detailed in their own privacy notices, which are accessible through the links below:
For the purposes of data-linking HEAT are the Data Controller and this is covered by their own privacy notice.
Pathways and third parties may publish aggregated data based on personal information from event applicants and/or participants, including analysis and research utilising these data, but the data will be anonymised and no information which could identify you will be published.
Anonymised or aggregated data means that the data can no longer be identified with you as an individual because all your identifiable data (for e.g. your name, address has been removed). Data Protection Legislation does not cover this data, as it is not personal data.
4. How long will my personal information be kept for?
If you attend any particular event/ activity, we will only retain certain detailed information that we need for the purposes of event/activity administration for as long as necessary to serve that purpose. In order to conduct long-term evaluation, tracking and research about access to Higher Education, and in relation to certain events/initiatives you attend requiring a HEAT data collection form, we will retain your personal information as outline below.
Where longitudinal tracking permission has been sought/obtained, and if you have:
- Attended an activity within the last 15 years
- Supplied your first name, last name, postcode and date of birth
- Not withdrawn your permission to be included in research into equality of opportunity for access and success in higher education
From the year ready to enter Higher Education, your data will be used for 15 years for the purpose of monitoring and evaluation. After this time, your information will be marked as ready for deletion by Pathways who collected it for this purpose.
Where tracking permission has not been sought/obtained and/or the personal information stored does not meet the track criteria, your data will be marked as ready for deletion to the collecting organisation within 7 years of being stored.
After these periods, any personal information will be removed from our records, but we may continue to retain and process your information in an anonymised form. Once your data is anonymised, it is no longer personal data for the purposes of Data Protection Legislation.
5. Who will process my personal information?
The information published here applies to the use of your personal information by Pathways, which constitutes the University of Leicester (https://le.ac.uk/), De Montfort University (www.dmu.ac.uk), and Loughborough University (www.lboro.ac.uk).
For the purposes of the data processing explained here, the universities are the data controllers. For the purposes of data linking by HEAT, they are the data controller.
6. What are your rights and how to enforce them?
Please find below the additional rights you have regarding the data that you have provided:
- Right of access – you can ask us what data we hold about you and be provided with that information
- Right to withdraw consent – this applies where we rely on consent to collect your data
- Right of rectification – you can ask us to correct inaccurate factual data we hold about you
- Right to Restrict Processing – you can ask us not to process any data that is inaccurate
- Right to erasure – you can ask us to delete data we hold about you (this only applies where we hold information with your Consent)
- Right to Object– you can object to processing for direct marketing purposes
7. How can I access my personal information?
You have the right to access the personal information that is held about you by Pathways. Get in contact at: reach@le.ac.uk if you want to access your data.
You also have the right to ask us to correct any inaccurate personal information we hold about you, to delete personal information, or otherwise restrict our processing, or to object to processing or to receive an electronic copy of the personal information you provided to us.
8. Who can I contact?
If you have any questions about how your personal information is used, please contact the central Pathways team (reach@le.ac.uk).
Pathways is based at the University of Leicester and is required to comply with their data protection policies and processes. All our data protection processes are reviewed and authorised by the data protection team, the Information Assurance Service (IAS), based there. You can find more details on their website, https://le.ac.uk/ias, or get in touch: ias@leicester.ac.uk
How do I complain?
If you are not happy with the way your information is being handled please let us know. If you are not happy with our response, you have the right to lodge a complaint with:
The Information Commissioner’s Office,
Wycliffe House, Water Lane,
Wilmslow, SK9 5AF (www.ico.org.uk).
Are changes made to this information?
This information was last updated in August 2025.
Appendix A – legal basis for processing
Our legal basis for collecting personal and special category data when using a Data Sharing Agreement:
Pathways collect and process personal information under the legal basis of Article 6 (1) (e) Public Interest; and special category data under Article 9 (2) (j) Research purposes, and Article 9 (2) (g) reasons of substantial public interest. This means that the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority (Office for Students and Department for Education).