1. Introduction
This Privacy Statement applies exclusively to Participants undertaking Executive Development programmes delivered by Irish Management Institute (“IMI”) that lead to awards of University College Cork (“UCC”).
For such programmes:
- IMI and UCC act as Joint Controllers of personal data strictly for the purposes of academic administration, assessment, certification and regulatory compliance relating to UCC-accredited programmes.
- IMI acts as an independent Data Controller for all other processing activities, including non-UCC accredited programmes, marketing, alumni engagement, consultancy services, events and corporate services.
- This Privacy Statement applies only to UCC-accredited programmes and does not apply to other IMI services.
2. Who We Are
Irish Management Institute Leadership Limited is a company incorporated in Ireland with its registered office at Sandyford Road, Dundrum, Dublin 14.
University College Cork – National University of Ireland, Cork has its seat at Western Road, Cork, Ireland.
For UCC-accredited programmes, IMI and UCC jointly determine the purposes and means of certain academic-related processing.
3. What is Personal Data?
Under the General Data Protection Regulation (EU) 2016/679 (“GDPR”), personal data means any information relating to an identified or identifiable natural person.
Special Categories of Data
Certain data are classified as “special categories”, including:
- Health data
- Disability information
- Biometric data
- Other sensitive categories as defined under GDPR
Where such data is required (for example to provide reasonable accommodations), it will be processed in accordance with GDPR and only where a valid legal basis applies.
4. What Personal Data We Collect (UCC Programmes Only)
For UCC-accredited programmes, IMI may collect and process:
- Name and contact details
- Date of birth
- Nationality and country of domicile
- Education and qualification history
- English language proficiency
- Employer details (where relevant to sponsorship)
- Enrolment and registration information
- Assessment submissions, examination results and grades
- Academic transcripts
- Information necessary to provide reasonable accommodations
- Recordings where sessions are recorded (see Section 8)
Financial information (such as payment details) may be processed where necessary for programme administration but remains under IMI’s independent controller responsibility unless transferred into UCC systems for academic purposes.
5. Purpose of Processing
- Joint processing by IMI and UCC is limited strictly to:
- Application and admissions
- Registration as UCC students
- Delivery of accredited programmes
- Assessment and examination administration
- Academic governance and quality assurance
- Certification and conferring
- Compliance with regulatory or accreditation requirements
This joint processing does not extend to marketing, alumni engagement, consultancy services, events, room hire or other non-academic services.
6. Legal Basis for Processing
Processing is carried out on the basis of:
- Performance of a contract (delivery of the programme)
- Compliance with legal obligations
- Legitimate interests in academic governance and quality assurance
- Explicit consent where required for special category data
7. Sharing of Data with UCC
Where you apply for or enrol on a UCC-accredited programme: you will submit your application details via UCC Apply. This will include your:
- First Name
- Middle Name (if applicable)
- Last Name
- PPS Number
- Date of birth (dd-mm-yyyy format)
- Gender
- Email address (personal email)
- Contact phone number
- Home Address
- Nation of Birth
- Nation of Citizenship
- Domiciliary (i.e. country in which the student lived for the last 12 months prior to registering on the programme – this may differ from citizenship)
- Relevant Programme Code(s)
This personal data is available to IMI and UCC for the purposes of reviewing and considering your application. Should your application be successful, the above data will be retained on UCC’s student record system, which IMI has access to for the purposes of education and training services. As you progress through your course, this record will be supplemented by your academic results. Any personal data (i.e. information that can be used to identify you as an individual) which you provide to the University will be treated with the highest standards of security and confidentiality, and will be held within UCC systems in accordance with Irish and European Data Protection legislation and the UCC’s Data Protection Policy
Relevant personal data will be shared with UCC for academic administration.
Data held within UCC systems will be processed in accordance with UCC’s Data Protection Policies.
IMI retains independent control of its own operational systems outside the academic scope defined above.
8. Specific Privacy Matters Relating to Programme Participation
8.1 Virtual Learning Environment (VLE)
Participants do not retain perpetual access to the VLE.
Access will expire following completion of the programme. Participants are encouraged to retain copies of their own work where required.
8.2 Assignments, Assessments and Examination Scripts
Submitted assessments are stored on secure systems.
Programme Directors, grading faculty and external examiners may access submissions for grading purposes.
Examination scripts and assessments may be retained for up to 7 years where required for accreditation or regulatory compliance.
Psychometric reports, where used, will be retained only for the duration of the programme and deleted thereafter.
Participants are encouraged to anonymise third parties referenced in assignments.
8.3 Recording of Sessions
Presentations, workshops and assessments may be recorded for purposes including:
- Academic review
- Distribution to programme participants
- Reflective learning
- Assessment and moderation
- Where sessions are recorded:
- Participants will be notified in advance.
- Access will be restricted to relevant programme staff and participants.
- Recordings will be stored securely and deleted in accordance with retention policies.
- Online recordings may be temporarily hosted on secure platforms (e.g., Zoom or similar platforms) before being transferred to secure storage.
8.4 Group Work
Where group assignments are required, participant contact details may be shared within the assigned group solely for academic collaboration.
8.5 Employer Sponsorship
Where an employer sponsors participation and you have consented to share information, relevant personal data may be shared with the sponsoring organisation in accordance with your instructions.
8.6 Ethics
Where programme assignments require collection of personal data from third parties, participants must comply with applicable ethics and data protection requirements.
9. Third Parties and Service Providers
IMI may engage service providers necessary for programme delivery, including:
- Learning management platforms
- IT hosting providers
- Assessment systems
- Secure storage providers
- Professional advisers
Such providers act under contractual obligations and process data only in accordance with IMI’s instructions.
10. Retention
Academic records relating to UCC awards will be retained in accordance with UCC academic retention policies and applicable regulatory or accreditation requirements.
IMI will retain its operational records in accordance with its own independent retention policies.
11. Your Rights
Under GDPR, you have rights including:
- Access to your personal data
- Rectification of inaccurate data
- Erasure (where applicable)
- Restriction of processing
- Data portability
- Objection to processing
You may exercise your rights by contacting:
IMI: [email protected]
UCC: [email protected]
12. Complaints
If you are not satisfied with how your data has been handled, you may lodge a complaint with the Data Protection Commission in Ireland.
13. Governing Law
This Privacy Statement is governed by Irish law.