N-TUTORR at Dundalk Institute of Technology (DkIT)

1. Introduction
   
   LinkedIn Learning is an online learning service that provides access to a large range of courses and tutorials taught by industry experts in categories including information technology, creative and business skills. Through the N-TUTORR project, DkIT is providing access to the LinkedIn Learning platform for all staff and students as a pilot project until June 2025. This innovative training option will enhance employee and student learning and development and contribute to organisational learning. This Privacy Notice refers to the personal data which DkIT, as the data controller, will share with LinkedIn Learning, the data processor, in order to provide employees and students with this new service. Dundalk Institute of Technology (DkIT) has allowed access to Linkedin Learning via Single Sign-on (SSO), an identity management service enabling staff and students to access services provided by third parties for DkIT staff and students using their DkIT IT account log in credentials.

2. Lawful Basis for Processing
   
   Where you are invited by DkIT to use LinkedIn Learning to carry out training/learning, the lawful basis upon which the Institute relies to process your personal data is that the processing has the potential to support the staff member/student’s performance of a contract or role, and “legitimate interests”. Where you yourself decide to use LinkedIn Learning, the lawful basis is consent.

3. Data Controller and Processor
   
   DkIT is the data controller of your personal data, which is shared with and processed by third-party online learning platforms, acting as data processors. These platforms use your data solely to provide their services. Here, Linkedin (data processor) processes your personal data on behalf of DkIT (data controller) for staff and students. Where access to Linkedin Learning meets a business or an academic need, then DkIT will share this limited personal data:  name, email Address @dkit.ie, affiliation with DkIT – Staff or Student. Linkedin Learning only processes the data for the provision of Linkedin Learning Services.

4. Personal LinkedIn Profile account
   
   Your DkIT LinkedIn Learning Account is separate to any other LinkedIn account you may hold as a personal user. You will be given the option to connect your personal LinkedIn profile during activation of DkIT LinkedIn Learning. If you choose to connect your LinkedIn profile with your LinkedIn Learning account, then you will receive personalised content recommendations based on your LinkedIn profile information. Connecting accounts is completely optional and those wishing to use DkIT LinkedIn Learning without owning or connecting a LinkedIn profile can do so without issue. Accounts can also be disconnected at any time. This DkIT Privacy Policy only applies to the specific personal data which you share as a DkIT employee on your LinkedIn Learning account.

1. 1. Additional personal data shared with DkIT, if you decide to link your DkIT LinkedIn Learning account with a personal LinkedIn Profile account
      If you decide to link the two accounts, DkIT will receive the following additional information related to your personal Profile account from LinkedIn corporation: LinkedIn Profile information, such as work title, and profile photo which are already available through LinkedIn.com; any courses that the learner has transferred to their DkIT LinkedIn Learning account.

5. User Agreement and Data Privacy
   
   Before you use the DkIT LinkedIn Learning service, you must accept the User Agreement through which you are agreeing to enter into a legally binding contract with LinkedIn. Your use of the service is also subject to LinkedIn's Cookie Policy and Privacy Policy which covers how they collect, use, share and store your personal information. Please review the User Agreements and Privacy Policies of the respective online learning platforms. LinkedIn will collect and use the following details for the LinkedIn Learning service: Email Address @dkit.ie; Affiliation with DkIT – Staff or Student; First Name; Surname; IP Address; Saved Courses; Skills Followed; Playlists; Learning History; Notes and Assessments. For N-TUTORR DkIT staff with Administration permissions, it also includes Recommendation History and Usage Reporting.
   
   
   If you have any concern about providing information to LinkedIn or having such information used in any manner permitted in this Privacy Policy, you should not visit DkIT’s SSO link for Linkedin Learning, or LinkedIn Learning (https://www.linkedin.com/learning/) websites, apps or otherwise use their services.

6. How will your information be used
   
   By engaging with the LinkedIn Learning platform being provided to DkIT staff and students via the N-TUTORR project and the activation link, you consent to your personal data (first name, surname, e mail) being anonymised by the DkIT N-TUTORR team for the sole purpose of generating anonymised, high-level engagement metrics. These engagement metrics are a requirement of the NextGenerationEU Fund. No personal data will be shared internally or externally by the DkIT N-TUTORR team. Specifically, the limited amount of personal data on your DkIT Linkedin Learning account will be shared with the DkIT N-TUTORR team members with administration permissions, and also with the Linkedin corporation. Information may be used for analytics and reporting relating to usage of the DkIT LinkedIn Learning service. No personal data will be shared internally or externally by the DkIT N-TUTORR team.

7. Data Security and International Transfers
   
   LinkedIn Learning services require data to flow outside the EU. To help ensure an adequate level of protection for EU personal data when it is transferred outside the EU, as of July 18, 2017, LinkedIn certified to the US Department of Commerce its adherence to the EU-US Privacy Shield framework for the protection of LinkedIn’s customers' personal data. On July 10, 2023, the European Commission adopted its adequacy decision for the EU-US Data Privacy Framework thereby designating the United States as a country that ensures an adequate level of protection for personal data transferred from the EU/EEA. Further details are available at: https://www.linkedin.com/help/linkedin/answer/62533/eu-data-transfers. Additional security practices that LinkedIn follow for all their products is available at the following: https://security.linkedin.com/our-security-practices &  https://security.linkedin.com/trust-and-compliance

8. Retention periods for personal data.
   
   LinkedIn Learning information will be held by the DkIT N-TUTORR project team in line with the DkIT Record Retention Schedule.If you decide to add your learnings/courses/certifications to the DkIT HR Core system, then they will form part of your record. Linkedin Learning is not integrated with this internal system, however, users can update their profile should they wish to maintain a comprehensive record in one place. Any such manual updates will be retained in line with the associated retention period. LinkedIn will retain your DkIT employee personal data for as long as the DkIT LinkedIn Learning account is active.

9. Your rights in respect of your DKIT Linkedin Learning account
   
   If you would like to exercise your rights to access, rectify and close/or erase your information held on LinkedIn Learning please contact ntutorr@dkit.ie and/or dataprotection@dkit.ie. If you decide that you no longer wish to access DkIT Linked Learning as a DkIT employee or student, you have the right to close and terminate your account.

10. Object to processing based on legitimate interests; Contact and Complaints
    
    If you have any concerns in relation to how your personal data is being processed as part of your DkIT LinkedIn Learning account, the DkIT N-TUTORR project team would appreciate if you could contact ntutorr@dkit.ie as a first port of call to discuss any concerns to see if it is possible for us to help and reassure you about the protection of your privacy rights.

You also have a right to report any concerns you have in relation to the processing of your personal data under DkIT LinkedIn Learning to the DkIT DPO by emailing dataprotection@dkit.ie.

Finally, you have the right to lodge a complaint with the Supervisory Authority, in Ireland the DPC if you have serious concerns that your rights as a data subject under the GDPR have been breached through DkIT LinkedIn Learning. However, we really wish to help, and would encourage you to contact DkIT N-TUTORR team or DPO with any initial concerns. Details of how to lodge a complaint can be found on the Data Protection Commission’s website.

Version 1 was updated on 21 Nov 2023.

FAQs will appear here during the roll out of Linkedin Learning across DkIT. If you have specific questions in relation to LinkedIn Learning, please contact ntutorr@dkit.ie