RE: Is this international transfer?
by charles oppenheim - written 05/11/2010 08:55:09
Helen Williamson wrote (03/11/2010 16:10:02):
We have a student information system which is used by our staff to record information about applicants and students. It allows us to process applications, deal with assessment requirements and progression to the next year, create a transcript at the end of their degree course etc. We have 4 international offices which deal with applicants from different geographical areas (all outside the EEA). Some staff are emplyed directly by us and others via an agent. If we gave access to the staff in these overseas offices, would this constitute international transfer outside the EEA?
It may well be, but the way round this would be to have each international student applicant give his/her explicit written permission for the transfer to take place. Then the problem, if it is a problem, is by-passed in a legal fashion. Also, of course, you should require all the overseas agents to abide by the data protection principles.
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