Bivibag Education’s OpenLearn Site Policy: General Data Protection Regulations 2018

This site policy includes all of the following information in simple language:

    1. What information is collected.
    2. The purpose of all processing to be performed on the user’s data.
    3. The identity of the data controller and contact information
    4. List of rights
    5. The period the data is stored
    6. The mechanism for withdrawing consent
    7. The mechanism for requesting corrections, or erasures of personal data
    8. The mechanism for requesting a record of all personal data
    9. List of third parties that data will be shared with (This includes integrations such as LTI, portfolios, plagiarism, repositories, authentication etc.) including:
    1. The contact details of the data protection officer for each
    2. The privacy policy for each.
  1. Whether the personal data will be used for any automated decision-making process, including the significance and details of the process (e.g. analytics).


Bivibag Education’s OpenLearn is the Virtual Learning Environment (VLE) used at It is based on the Moodle ‘Course Management System’ (, a free open source software package designed using sound pedagogical principles, to help educators create effective online learning communities.  Moodle is distributed under the GNU General Public License.

Bivibag Education’s OpenLearn provides a range of features for the delivery, support, administration and participation in teaching and learning activities.  The features include content delivery and collaboration between tutors and learners, such as:

  • Content creation or upload;
  • Discussion forums and chat rooms;
  • Messaging tools;
  • Assignments;
  • Quizzes; and
  • Monitoring of users’ online activity.

Privacy and personal data

At Bivibag Education we take your privacy very seriously. In order to provide access to the service we must collect and store some personal information about you.


Children under 16 years of age are not permitted to access the services provided by By agreeing to this privacy policy, you are also agreeing that you are 16 years of age or older.

What is collected?

When you register to use this Site, we will grant access to this Site. As part of the registration process you will be required to provide us with personal information, comprising:

  • your name and contact information, including email address.
  • information regarding your personal or professional interests, demographics, experiences with our products and services and contact preferences.

The reason for collecting location details is to set the server time to your locality so that information is posted out to you at 18:00 in your location, rather than at 18:00 London time.

Additional profile information – optional

You can choose to add a description and a photo of yourself, more contact details and a telephone number. You can also add an additional name in a phonetic form.

If you are only a company contract, we add details of your Institution/Company and Department.

As you use the site, information about the users, courses, activities and resources you interact with will also be stored and linked to your profile information.

Users (students, staff and managers) are reminded that their use of the OpenLearn learning environment will be logged and that this information, along with other personal data about them contained within the system, will be used by their tutors to monitor their academic progress.

How is this information used?

This information is used as follows:

Who can I contact?

The data protection officer for Bivibag Education is Robin Trangmar and he may be contacted at

Who is my data shared with?

In order to provide access to learning content provided by, we may share your basic profile information with the following services or providers.

  • Data storage is through ICDSoft who host the servers where the databases are located. Your data is hosted in the European Union. ICDSoft’s Privacy statement can be found here:
  • Your personal details will be created into a spreadsheet which is turned into a ‘CSV’ file for uploading into Moodle. This file is stored in a Dropbox directory. Dropbox’s Privacy statement is here:
  • Portfolio services are provided through a linked portfolio platform using iPortfolio (a Mahara application). This is accessed through a ‘Single Sign On’ (SSO) protocol used to link OpenLearn and iPortfolio together. Mahara has a detailed set of privacy statements here:

Bivibag Education will not transfer, disclose, sell, distribute or lease your personal information to third parties unless we have your permission or are required to do so by law. This process may involve sending personal information to other countries, whose data protection laws may not be as extensive as in the EU. However, we have carried out appropriate steps to ensure the same level of protection for the processing carried out in these countries as within the EU.

How long is my data stored?

Your personal data is stored as long as you are enrolled in one or more online courses at  A snapshot of Moodle to include individual course archives and a copy of the master MySQL database will be taken on or around 1st September annually and retained for 6 academic years. These snapshots will be stored offline.

How do I withdraw my consent for Bivibag Education to store and process my personal data?

If you have previously consented to allow Bivibag Education to store and process your personal data in accordance with this privacy policy, and you wish to withdraw your consent, please send an email to the data protection officer at

You will no longer be able to access the services provided by if your consent is withdrawn.

How do I request that my personal data is corrected or erased?

You may make corrections to your basic profile information by logging into  and editing your own profile.

If you have questions, or would like any other data to be corrected or erased, please send an email to the data protection officer at

How do I request a record of all my personal data that has been collected?

You may request a record of all of the personal data relating to you that has been collected in accordance with this privacy policy. To do so, please send an email to the data protection officer at