Higher education institutions must provide the HEA Student Data Collection notice to their students.
Article 13 of the General Data Protection Regulation requires information to be provided, or made readily available, to data subjects so that they are not deceived or misled as to the purposes for which their data is to be processed. In order to satisfy this principle, the HEA supply text for use by HEIs.
The student data collection notice can be supplied to students in any of the following areas:
•Providing the text with the registration form and the HEI's own data protection statement;
•Including the text on a website with the HEI's own data protection information;
•Including the text in a student handbook or other reference source for students.
The collection notice is published each year for Students commencing and resuming their studies in that calendar year. The data collected pursuant to that notice will then be shared with the HEA with the following years returns. In accordance with the principle of fair obtaining, the HEI should at all times ensure the correct and current Data Collection notice is published and for the avoidance of doubt the notice below is relevant for the 2019/2020 academic year.
HEA Student Data Collection Notice 2019
The Higher Education Authority (HEA) with an address at 3 Shelbourne Buildings, Shelbourne Road, Ballsbridge, Dublin 4. The HEA is a public body with authority derived from the Higher Education Authority Act 1971 (the 1971 Act).
The HEA are responsible for funding higher education institutions and advising the Minister for Education and Skills on policy formulation to develop the highest standards in our higher education system.
This notice sets out the basis on which any personal data collected from you, or from others, will be processed by the HEA. Please read the following carefully to understand HEA practices regarding your personal data and how the HEA will treat these data.
Data are collected by each higher education institution, including at registration, and are shared with the HEA via annual returns to the student records system in the HEA pursuant to a data sharing agreement, a copy of which is available on request from the HEA Data Protection Officer
The HEA Data Protection Officer (“DPO”) may be contacted at firstname.lastname@example.org
University of Limerick
The HEA collect student record, equal access survey and graduate outcome data from higher education institutions so that the HEA can perform their statutory functions under the 1971 Act. The HEA collect and process the following personal data:
Student record system data (SRS) based on institution’s registration data;
Equal Access Survey data based on the voluntary equal access survey presented to students;
About nine months after you graduate, the higher education institution may contact you to ask you to fill in the HEA Graduate Outcomes Survey. This is voluntary, and the higher education institution will not give your phone or email contact details used for this survey to the HEA.
During your studies, you will be invited to participate in the Irish National Survey of Student Engagement. Some of your information may be sent to the HEA to ensure that the survey is offered only to relevant target groups. Your information may be matched to your survey responses in order to allow for anonymous analysis of results, for example, by gender or full-time / part-time. Your responses will be treated confidentially and no individual student will be identifiable in any reports or results generated as a result of this survey.
The purpose for which the HEA uses this data is
for assessing the funding needs of HEIs, and,
for fact-based statistical analysis to help understand the real needs that higher education should meet, to promote equality of opportunity in higher education and to assist the Government in developing future higher education policies and investment.
The HEA does this by linking data from the Student Records System, the Equal Access Survey and information from the Graduate Outcomes Survey through student ID number and/or PPSN for more accurate statistical analysis to help improve education services and policies.
The HEA use student records to produce anonymised aggregate data in annual statistical publications.
The legal bases for the processing of your data are:
You have given your consent to the processing of your personal data for one or more specific purposes as set out in this document or,
The processing is necessary for compliance with a legal obligation to which the HEA and HEI are subject, in particular, but without prejudice to the generality of the obligations of the Higher Education Act 1971 or,
The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the HEA pursuant to the Higher Education Act 1971 and the Social Welfare (Consolidation) Act 2005, or,
The processing of special category data is necessary for reasons of substantial public interest, on the basis of EU or Irish law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject or,
Statistical data may be processed in accordance with Article 89 of the GDPR and Section 42 of the Data Protection Act 2018.
The HEA shares records with other official bodies such as the City of Dublin Education and Training Board (CDETB) and the Central Statistics Office for the following purposes:
Student Grant Application Verification
The HEA will provide your student record to CDETB (SUSI - Student Universal Support Ireland), an agent of the Department of Education and Skills. This record will include data on any previous enrolment in higher education in the Republic of Ireland. The HEA record is provided to CDETB (SUSI) for the purposes of verifying data supplied as part of grant applications, verifying that a student is enrolled or registered in accordance with the rules of an approved institution, assisting in the processing of applications for grants and determining an applicant’s eligibility for grant support under the education progression requirements of the Student Grant Scheme and the Student Support Act 2011.
Statutory Statistical functions
The HEA records are also used by the Central Statistics Office in order to carry out their statutory functions of measuring population levels and monitoring public expenditure.
Research, equal opportunity, journalism, other legitimate interest/public function
HEA student data is provided to the Department of Education and Skills to allow for research and analysis using this data within the Department, for instance for transition rate analysis and third level demand projections.
Public Service Identity (PPSN, name, address, date of birth) is sent to the Department of Employment Affairs and Social Protection Client Identity Services to verify PPSN for data quality purposes
HEA administrative graduate data is linked via PPSN to Revenue administrative employment data, Department of Employment Affairs and Social Protection administrative benefits data and Department of Education and Skills administrative student data in the Central Statistics Office to analyse graduate outcomes and evaluate higher education effectiveness.
HEA administrative data are also shared with SOLAS and the Department of Public Expenditure and Reform to allow for policy formulation and statistical analysis.
Anonymised aggregate (non-personal) data to third parties:
The HEA will also supply anonymised aggregate data to third parties for the purposes of equal opportunities monitoring, Freedom of Information, research and journalism in the public interest. The data shared does on its own identify any individual.
The time periods for which the HEA retain your information depends on the type of information and the purposes for which it is used. The HEA will keep your information for no longer than is required or permitted.
For further details on the applicable retention periods, please contact the HEA Data Protection Officer at email@example.com
You have the following rights:
The right to access the personal data the HEA holds about you.
The right to require the HEA to rectify any inaccurate personal data about you without undue delay.
The right to have the HEA erase any personal data held about you in circumstances such as where it is no longer necessary to hold the personal data or, in some circumstances, if you have withdrawn your consent to the processing.
The right to ask the HEA to provide your personal data to you in a portable format or, where technically feasible, to port that personal data to another provider provided it does not result in a disclosure of personal data relating to other people.
The right to request a restriction of the processing of your personal data.
Where HEA processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that the HEA have carried out before you withdrew your consent remains lawful.
You may exercise any of the above rights by contacting the HEA Data Protection Officer at firstname.lastname@example.org
You may lodge a complaint with the Office of the Data Protection Commission in respect to our processing of your personal data. The website is www.dataprotection.ie
To ensure your privacy and to protect the integrity of your data, the HEA will require you to verify your identity with a photographic ID before releasing or correcting your information.
This notice may change each year. This notice is applicable to the 2019/20 academic year. A revised notice will issue in the event of any future changes.
The HEA Data Protection Officer can be contacted by email at email@example.com
By phone: 01 2317100
Address: 3 Shelbourne Buildings, Shelbourne Road, Ballsbridge, Dublin 4.
Data Collection Notice: Schedule 1
The table below sets out a list of third parties with whom the HEA share your data.
Third party name
Description of services provided
The Department of Education and Skills
The HEA may share, subject to a data sharing agreement in 2019/20, identifiable microdata with the Department of Education and Skills to allow for transitions rate analysis from 2nd level to 3rd level and to produce 3rd level demand projections.
The Central Statistics Office
The HEA share identifiable microdata with the CSO to analyse graduate outcomes and to measure the effectiveness of the higher education system. HEA data is linked to other Government administrative datasets in the CSO.
SUSI – part of the CDETB (City of Dublin Education and Training Board)
The HEA match SUSI grant application data to HEA student record data using PPSN to verify previous attendance at HEA funded institutions.
The Department of Employment Affairs and Social Protection
The HEA share PPSN, name, address and date of birth data to verify PPSN data with Client Identity Services.
The HEA may share identifiable microdata, subject to a data sharing agreement in 2019/20, with SOLAS to allow for transitions rate analysis from further education to higher education.
The Department of Public Expenditure and Reform
The HEA may share disaggregated course level data with DPER to allow for detailed labour market analysis.
The HEA, on occasion, contract external bodies to process microdata in order to fulfil statutory functions, e.g. geocoding of student address data.
Data Collection Notice: Schedule 2
The data higher education institutions send to the HEA include, student records:
Anticipated length of programme in years
Faculty title & code
Outreach, off campus marker
Add-on indicator to mark add-on courses recognising previous credit for entry
Course completion credits
Full time credits per year
Course class indicator
Teacher training marker
Enrol status, student or graduate
Mode of study
ISCED code – field of study
Non-Standard award code
Grade for award
PhD structure indicator
Student code to indicate type of student, e.g. new entrant
Non-Standard attendance tag
Date of birth
Domiciliary of origin
Postal code for Dublin students
Non-EU fee indicator
Residence type during term-time
Fees – free fees indicator
DES grant indictor of grant status
SUSI grant code as per SUSI file
Post-Primary school number
Leaving Cert points
Leaving Cert year
Leaving Cert exam results
Last Institution attended
Year left last institution
Current year credits
Up-skilling initiative indicator, e.g. Springboard
Fund indicator for students funded through the Fund for Students with a Disability
Basis of entry to course
Data collected as part of the Equal Access Survey is also returned to the HEA. Data sent to the HEA as part of this process include:
Blind or deaf indicator
Physical disability indicator
Learning disability indicator
Psychological, emotional, or mental health indicator
Other condition indicator
One parent allowance status
The following Graduate Outcomes Survey data will be sent to the HEA:
Date of birth
Domiciliary of origin code
Mode of study
Grade of award
ISCED field of study information
Programme type code
Year of graduation
Response, yes or no
Principal economic status – main
Principal economic status – full
Need for qualification indicator
Find out about job indicator
Further institution indicator
Further course name
Further ISCED field of study
Award sought in further study
Further mode of study
Why do further study indicator
Other activity A – unemployment status
Other activity B – other activities
Barriers to employment
Same course again indicator
Follow up willingness indicator
HEA SRS data, Equal Access Survey data and Graduate Outcomes Survey data are linked in the HEA for analysis purposes via Student ID and/or PPSN.