Hello All,
I wondered if anyone has started reviewing their international transfer arrangements? In particular, we've been reviewing the exchange of student data with our international partner universities for example where our student attends a placement or whether we validate an award delivered by another university.
We have a number of non-EU partner university and are considering negotiating the MCCs (where we don't already have them).
I did consider whether we could rely on the derogations that the transfer is necessary for the performance of a contract or with the consent of the student. However, I note the GDPR provides that these derogations aren't available to a public authority in the performance of its public task. I've taken the view that this would cover the provision of higher education in the context of placements and validation awards.
Are others taking the same approach and implementing the MCCs in these contexts?
Best wishes,
Laura
Laura Jones| Solicitor | Information Law
Legal Services|The Manchester Metropolitan University | Room 215 | All Saints| Oxford Road |
Manchester | M15 6BH
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