1. Introduction

The Ray Education & Recruitment Ltd is a student recruitment and admissions support organisation that assists prospective students with applications to partner universities and colleges. Our registered office is located at Unit 6, Longsight Business Park, Hamilton Road, M13 0PD. We can be contacted via email at admin@raay.co.uk, by telephone on 4401779400757, or through our website at http://www.raay.co.uk/. The company is registered with the Information Commissioner's Office (ICO). "Zeadni Chowdhury" is our DPO, can be contacted via our official email and phone number mentioned.

This Privacy Policy outlines the position of The Ray Education & Recruitment Ltd regarding recruitment, selection, admissions support, and the handling of applicant information in collaboration with partner universities and colleges.

The company is committed to operating in accordance with applicable UK legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and relevant admissions and education sector guidance.

This policy also reflects the principles and admissions standards of partner universities and colleges where applicable.

2. Purpose

The purpose of this policy is to provide clear and transparent information to applicants, prospective students, parents, guardians, advisors, sub-agents, and partner institutions regarding the recruitment, admissions support, and data handling practices of The Ray Education & Recruitment Ltd.

This policy establishes the framework and standards that govern all recruitment, screening, admissions support, compliance, and applicant management activities carried out by the company.

The policy is intended to ensure that:

• Recruitment and admissions support activities are conducted professionally, fairly, and consistently.
• Applicants receive accurate, timely, and transparent guidance throughout the application process.
• Personal data is processed securely and lawfully in accordance with UK data protection legislation and ICO guidelines.
• Staff, representatives, and sub-agents understand their responsibilities regarding confidentiality, compliance, safeguarding, and ethical conduct.
• All admissions support activities are aligned with the requirements of partner universities and colleges.

The Ray Education & Recruitment Ltd is committed to maintaining high professional standards, protecting applicant interests, and always promoting ethical and compliant recruitment practices.

3. Scope

This policy applies to all recruitment, admissions support, applicant screening, compliance, and data handling activities carried out by The Ray Education & Recruitment Ltd in relation to applications submitted to partner universities and colleges.

The policy covers applications for:

• Undergraduate courses
• Postgraduate taught courses
• Postgraduate research courses
• Foundation and pathway programmes
• Continuing Professional Development (CPD) courses
• Other academic or vocational programmes offered by partner institutions

Courses may be delivered through one or more of the following study modes:

• Full-time
• Part-time
• Distance learning
• Online learning
• Blended learning

The study mode available for each course will be determined by the relevant partner university or college and outlined within the official course information provided by that institution.

This policy applies to:

• Applicants and prospective students
• Parents, guardians, and advisors
• Employees and representatives of The Ray Education & Recruitment Ltd
• Recruitment staff and screening staff
• Marketing and admissions teams
• Approved sub-agents and recruitment partners
• Third parties acting on behalf of the company in recruitment-related activities

The policy applies throughout the entire applicant journey, including enquiry handling, document collection, eligibility screening, admissions support, communication with partner institutions, and post-application follow-up.

4. Equality and Diversity

The Ray Education & Recruitment Ltd is committed to promoting equality, diversity, inclusion, and fairness in all recruitment, admissions support, and applicant engagement activities.

We aim to provide an environment that is free from discrimination, bullying, harassment, victimisation, or unfair treatment, where all individuals are treated with dignity, professionalism, and respect.

The company values diversity and is committed to creating an inclusive culture where applicants, staff, representatives, and partners are respected for their individual backgrounds, experiences, and contributions.

We are committed to providing equality of opportunity regardless of:

• Disability
• Gender identity
• Marriage or civil partnership
• Pregnancy or maternity
• Race, colour, nationality, ethnic or national origin
• Religion, belief, or philosophical belief
• Sex
• Sexual orientation

Recruitment and admissions support decisions are based solely on applicant eligibility, merit, suitability, partner institution requirements, and lawful admissions criteria.

The Ray Education & Recruitment Ltd expects all employees, representatives, and sub-agents to uphold these principles and to act in accordance with relevant equality legislation and professional standards.

5. Responsibility for Recruitment, Admissions and Widening Participation Activities

The Ray Education & Recruitment Ltd is committed to providing professional, transparent, ethical, and compliant recruitment and admissions support services to all applicants and partner institutions.

Recruitment, admissions support, and applicant management activities are carried out through several operational departments within the organisation.

Marketing Department Responsibilities

The Marketing Department is responsible for:

• Promoting partner university and college courses through approved marketing channels, including social media platforms, digital advertising, and the company website.
• Providing general information regarding courses, entry requirements, study options, and admissions processes.
• Collecting initial applicant enquiries and consent documentation, including agency authorisation and consent forms.
• Ensuring that applicant consent is obtained before processing personal information or submitting applications to partner institutions.
• Maintaining accurate and lawful advertising practices in accordance with partner institution guidelines.

Applicant Screening and Admissions Support Responsibilities

The Screening and Admissions Support Team is responsible for:

• Assessing applicant eligibility against partner institution requirements.
• Reviewing the authenticity, completeness, and consistency of applicant documentation and qualifications where applicable.
• Providing guidance regarding UCAS procedures and application requirements.
• Advising applicants on international qualification equivalencies and entry criteria.
• Supporting applicants from diverse educational, professional, and personal backgrounds.
• Verifying that applicants meet age and eligibility requirements established by partner institutions.
• Communicating with partner universities and colleges regarding admissions processes and applicant documentation.
• Requesting additional evidence or clarification where necessary.
• Ensuring fair and consistent interpretation of admissions requirements.

Applicants must meet the eligibility criteria established by the relevant partner institution. Local applicants aged 18 years or above may be processed subject to the requirements of the chosen course and institution.

Staff Training and Professional Standards

All staff involved in recruitment, screening, admissions support, and applicant engagement activities must be familiar with this policy and all associated procedures relevant to their responsibilities.

The Ray Education & Recruitment Ltd provides regular training, guidance, and compliance support to employees and representatives, including intake-based and refresher training sessions conducted periodically throughout the year.

The company is committed to maintaining professional standards in student recruitment and counselling practices.

Sub-Agent Management and Oversight

The Ray Education & Recruitment Ltd may work with approved sub-agents and recruitment partners under formal written agreements.

All sub-agents must:

• Comply with applicable laws, regulations, and partner institution requirements.
• Obtain valid applicant consent before sharing applicant information.
• Submit authentic and accurate documentation.
• Follow the company's recruitment, safeguarding, and compliance procedures.
• Participate in periodic training and compliance reviews where required.

The company reserves the right to investigate any concerns relating to fraud, misrepresentation, unethical conduct, or false documentation. Where misconduct is identified, the company may immediately terminate the agreement with the relevant sub-agent and discontinue all future collaboration.

6. Student Recruitment Framework

Provision of Information

The Ray Education & Recruitment Ltd is committed to providing timely, accurate, transparent, and appropriate information and support to prospective students throughout the recruitment and admissions process.

Our recruitment activities are guided by a commitment to fairness, impartiality, professionalism, and informed decision-making. Applicants are encouraged to review official information published by partner universities and colleges before proceeding with an application.

Accuracy and Transparency

The Ray Education & Recruitment Ltd aims to provide accurate information regarding:

• Course structure and content
• Entry requirements
• Tuition fees and associated costs
• Attendance requirements
• Modes of study
• Assessment methods
• Professional accreditation
• Employability outcomes
• Funding and finance information where available

Applicants are also directed to the official websites and published materials of partner universities and colleges for complete and updated information.

Commitment to Professional Standards in Recruitment

The company is committed to maintaining high professional standards in all recruitment and admissions support activities. This includes:

• Providing impartial advice and fair admissions guidance.
• Maintaining integrity and professionalism in all interactions with applicants.
• Avoiding misleading information or inappropriate comparisons with other institutions.
• Keeping up to date with developments in UK and international higher education.
• Supporting recruitment events and activities that provide free and impartial guidance to prospective students.

Staff and Sub-Agent Data Conduct

The Ray Education & Recruitment Ltd is committed to processing applicant information in accordance with UK GDPR, the Data Protection Act 2018, and ICO guidance.

All recruitment staff and approved sub-agents are expected to maintain strict confidentiality, data security, and professional compliance standards at all times when handling applicant information.

Recruiting Agent Performance Analysis

The performance of recruitment agents and screening staff is regularly monitored and evaluated by Ray Education & Recruitment Ltd to ensure compliance, professionalism, and service quality standards are consistently maintained. Performance assessments may include the number of applicants successfully enrolled with partner institutions, applicant progression and retention, the accuracy and completeness of submitted applicant documentation, communication standards maintained with applicants, responsiveness and effectiveness in handling applicant concerns or complaints, and adherence to internal procedures and partner institution requirements. Key Performance Indicators (KPIs) are reviewed periodically to assess operational performance, ethical conduct, compliance standards, and the overall quality of applicant support services provided by recruitment agents.

7. Assessment of Applications

Fair Admissions

The Ray Education & Recruitment Ltd is committed to supporting fair and transparent admissions practices that enable partner institutions to identify applicants with the appropriate qualifications, potential, and suitability for their chosen course of study.

Selection Criteria

Applications are assessed against the academic and non-academic requirements established by the relevant partner university or college.

Assessment methods may include:

• Academic qualifications
• Predicted or achieved grades
• English language proficiency
• References
• Personal statements or supporting statements
• Employment or professional experience
• Interviews or additional assessments where required

Applicants may come from a wide range of educational, professional, and personal backgrounds. Where standard admissions procedures may not fully demonstrate an applicant's suitability, additional or alternative evidence may be requested to support the application.

The Screening Team may contact applicants directly where further clarification or supporting documentation is required.

8. Entry Qualifications

Entry Qualifications for Admission

The Ray Education & Recruitment Ltd welcomes applications from students holding a wide range of UK and international qualifications.

The Screening Team is responsible for guiding applicants regarding qualification suitability, entry requirements, and UK qualification equivalencies in accordance with partner institution requirements.

Age Criteria

Applicants aged 18 years or above may be considered for processing subject to the requirements of the relevant partner university or college and the applicant's chosen course.

Applicants with International Qualifications

Applications from students whose previous education was completed outside the UK will be assessed against the standard entry requirements of the relevant institution and course.

Applicants Returning to Education

Applications from individuals returning to education following employment, career breaks, or other professional or personal experiences are welcomed.

Where appropriate, additional evidence may be considered to support an application and ensure fair consideration by the relevant partner institution. However, applicants must still satisfy the minimum academic and admissions requirements established by the partner university or college.

9. Applicants with a Disability and/or Additional Support Needs

The Ray Education & Recruitment Ltd works with partner institutions that welcome applications from individuals with disabilities, medical conditions, or additional support needs.

Applicants are encouraged to disclose relevant information during the application process where appropriate so that suitable guidance, support, and transparency can be maintained throughout the admissions process with the relevant partner institution.

Any disclosed information will be handled confidentially and in accordance with applicable data protection legislation.

10. Reapplication Framework

Applicants who are unsuccessful may submit a new application in a future intake or academic year, subject to the requirements and admissions policies of the relevant partner institution.

Any subsequent application should demonstrate improvement, updated qualifications, additional experience, or other relevant developments since the previous application.

11. Interaction and Operational Conduct with Applicants

Communication with Applicants

The Ray Education & Recruitment Ltd will communicate with applicants throughout the admissions process regarding their chosen course, application status, documentation requirements, interview arrangements, and updates received from partner universities or colleges.

Communication may take place through email, telephone, messaging platforms, online systems, or other appropriate communication methods.

Fraud, Omission and Plagiarism

Applicants must provide complete, accurate, and authentic information throughout the application process.

Any omission of relevant information, submission of false or misleading documentation, plagiarism, impersonation, or fraudulent activity may result in:

• Rejection of the application
• Withdrawal of support services
• Notification to the relevant partner institution
• Withdrawal of any offer issued by a partner institution
• Termination of agreements with associated sub-agents or representatives

The company reserves the right to investigate suspected fraudulent or unethical conduct and to take appropriate action where necessary.

12. Applicant Privacy Notice

Categories of Data Collected

The Ray Education & Recruitment Ltd collects personal data that is strictly necessary to facilitate the application process and ensure compliance with institutional and regulatory standards. The categories of data collected include:

• Personal Identification Data: Full name, date of birth, and contact details including email address, telephone number, and residential address.
• Verification Documents: Official proof of identification and proof of address.
• Academic and Professional Records: Academic qualifications, official transcripts, and relevant employment history.
• Immigration Status: Immigration or visa-related documents.
• Emergency Information: Designated emergency contact details.
• Supplementary Data: Any other relevant information provided by the applicant during the application process.

Purpose of Processing and Lawful Basis Mappings

Automated Decision-Making: The Ray Education & Recruitment Ltd does not utilize automated decision-making, profiling, or algorithmic scoring systems to process or evaluate applicant documentation or eligibility. All admissions screening is subject to human verification.

The company processes applicant data under specific lawful bases defined by the UK GDPR. The processing purposes and their corresponding lawful bases are mapped below:

Purpose of Processing

• Evaluating academic suitability and processing applications with partner colleges.
• Verifying the applicant's eligibility to study in the United Kingdom with the UK Visas and Immigration (UKVI).
• Conducting legal reviews, compliance checks, or handling contractual disputes.
• Managing emergency contact details.

Lawful Basis (UK GDPR)

• Consent / Performance of a Contract: The applicant has given explicit consent or requested these steps to enter into an educational program.
• Legal Obligation / Public Task: Necessary to comply with UK immigration laws and immigration sponsorship frameworks.
• Legitimate Interests / Legal Obligation: Necessary for the company's legal defense and to fulfill statutory duties.

Before the company processes any personal information for admission purposes, applicants must sign an electronic consent form. We send each student a unique digital link containing this form. Once the student digitally signs and submits it, explicitly allowing us to process their data for their desired educational goals, the signed consent record is automatically saved and securely stored in our central database for compliance tracking.

Data Sharing and Third-Party Disclosure

Applicant data is shared only when necessary and with appropriate safeguards in place. It is disclosed to the following specific categories of recipients:

• Partner Universities and Colleges: Shared to evaluate entry criteria, review academic eligibility, and secure official course offers.
• UK Visas and Immigration (UKVI): Shared to verify immigration history, check visa eligibility, and ensure statutory compliance with UK study route laws.
• Legal Representatives and Auditors: Shared with professional legal advisors or compliance auditors if a legal dispute arises or verification is formally required.
• Internal Screening and Admissions Teams: Shared internally among authorized recruitment, marketing, and compliance staff to manage the applicant journey.

Data Retention and Disposal Schedule

The company maintains a strict data retention schedule to ensure personal information is not kept longer than necessary.

• Retention Period: All applicant data, submitted documentation, and related application records are retained for a maximum period of up to 1 year following the conclusion of the relevant application cycle.
• Criteria for Retention: This 1-year window ensures the company can address any post-application inquiries, verify agent performance metrics, or manage admissions appeals.
• Secure Disposal: The standard retention threshold for applicant records is 1 year. However, for successful applicants, the company will retain basic contact information and admission history until their academic journey through us has officially ended. Upon reaching the end of this period, or the 1-year expiration threshold for other applicants, all personal data is permanently and securely deleted from all company databases and storage systems, unless a longer retention period is explicitly mandated by applicable UK legislation.

International Data Transfers

The company does not normally transfer applicant personal data to a third country or an international organisation. All standard applicant data is securely processed and stored within the United Kingdom.

However, given our role in international recruitment, if a specific university application or qualification check makes it necessary to transfer data outside the UK, the company will ensure the transfer is protected using the following strict legal frameworks required by the UK GDPR:

• Adequacy Decisions: The company will only transfer data to countries or international organisations that the UK government has officially declared as having an adequate level of data protection laws.
• Appropriate Safeguards (Article 46/47): In the absence of an adequacy decision, transfers will only occur if appropriate or suitable safeguards are in place such as UK-approved Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs) to protect the applicant's statutory rights.
• Access to Safeguards: Applicants have a legal right to obtain a copy of the specific safeguards and safety agreements used for their data transfer, or to see where they have been made available, by writing directly to our compliance team at admin@raay.co.uk.

Applicant (Data Subject) Rights

In accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, applicants possess specific statutory rights regarding their personal data held by The Ray Education & Recruitment Ltd. Applicants may exercise the following rights at any stage of the application process:

• Right of Access: Applicants have the right to request a copy of the personal data the company holds about them, along with information on how it is processed.
• Right to Rectification: Applicants have the right to request the immediate correction of inaccurate personal data or the completion of incomplete information.
• Right to Erasure (Right to be Forgotten): Applicants have the right to request the deletion of their personal data from company systems, provided there is no overriding legal or regulatory obligation to retain it.
• Right to Restrict Processing: Applicants have the right to restrict the processing of their data under certain conditions, such as when contesting the accuracy of the information.
• Right to Data Portability: Applicants have the right to receive their personal data in a structured, commonly used, and machine-readable format, or to request direct transfer.
• Right to Object: Applicants have the right to object to the processing of their data where the company relies on legitimate interests as its lawful basis.
• Right to Withdraw Consent: Where processing is based on explicit consent, applicants have the absolute right to withdraw their consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Lodge a Complaint: Applicants have the absolute right to complain if they are unhappy with how their data is being handled.

Talk to Us First: We encourage applicants to first contact our compliance team at https://raay.co.uk/public/#contact so we can investigate and resolve the issue quickly.

Escalating to the Regulator: If the issue remains unresolved, or if the applicant prefers to bypass the company entirely, they have a statutory right to lodge a formal complaint directly with the UK data regulator, the Information Commissioner's Office (ICO), via their official website at https://ico.org.uk.

How to Exercise Data Rights & Timeframes

Applicants can ask to use any of their data rights at any time, and it is completely free. Here is how the process works:

• How to Ask: To make a request, applicants must write to the Screening and Compliance Team through our contact link at https://raay.co.uk/public/#contact.
• Checking Identity: To keep data safe and prevent fraud, the company may ask the applicant for proof of identity before sharing any files.
• Our Response Time: The Ray Education & Recruitment Ltd will reply to all requests within one calendar month. If a request is very complex or if an applicant has made multiple requests, the company can extend the timeline by up to an extra two months.

The statutory response clock will be paused ("stopped") if the company needs to request proof of identity or further clarification from the applicant to find the data. The clock restarts only once the applicant provides the requested information.

• Applicant Withdrawal: If a student decides to withdraw their application or stop using our recruitment services at any point, the company will immediately stop processing their records. We will not continue to hold any of their personal information, and all of their data will be permanently and securely deleted from our databases and storage systems within 30 days of the withdrawal request.

Data Security Defenses

The company uses strong technical and human defenses to keep applicant data safe from leaks, losses, or unauthorized viewing. Our main defenses include:

• Limited Access: Only authorized admissions and compliance staff who need the files can see applicant data.
• Protected Storage: All digital forms, transcripts, and passports are saved in encrypted databases and secure cloud storage.
• Safe Sharing: When sending documents to partner colleges or UKVI, the company uses secure, encrypted networks.
• Regular Checks: The company regularly tests and audits its computer systems to find and fix any security gaps.

13. Academic Appeals and Service Complaints

This section applies strictly to academic feedback, admissions decisions, and operational service complaints.

The Ray Education & Recruitment Ltd aims to ensure that all applications are handled fairly, consistently, professionally, and in accordance with partner institution requirements.

Applicants may request feedback regarding unsuccessful applications where appropriate. Feedback may be provided in writing at the discretion of the relevant admissions or screening staff.

Applicants who are dissatisfied with the handling or outcome of their application should initially raise their concerns with the relevant Screening Team representative.

Where concerns remain unresolved, applicants may submit a formal appeal or complaint through the company's established Appeals and Complaints Procedure using the official company communication channels https://raay.co.uk/public/#contact.

All complaints and appeals will be handled fairly, confidentially, and within a reasonable timeframe.

14. Monitoring and Review

This policy and all related recruitment, admissions support, safeguarding, compliance, and data protection procedures are monitored and reviewed by the management team of The Ray Education & Recruitment Ltd.

The company regularly reviews its policies, operational procedures, training standards, and compliance practices to ensure alignment with:

• UK agent and counsellor training by British Council
• UK legislation and regulatory requirements
• ICO guidance and data protection obligations
• Partner University and college requirements
• Industry best practice standards

Feedback from applicants, staff, partner institutions, and sub-agents is taken seriously and may be used to improve operational procedures, service quality, compliance standards, and applicant experience.

Terms And Conditions

Responsible for data processing

The Ray Education & Recruitment Ltd. Registered office: Unit 6, Longsight Business Park, Hamilton Road, M13 0PD. Email: admin@raay.co.uk.

Purpose

Management of student recruitment and admissions support to help you apply to partner colleges and universities.

Legal basis for processing

The data subject gave his or her explicit consent to the processing of such personal data for one or more of the specified admission purposes.

Transfers and/or international transfers of data

No standard data transfers to third countries or international organizations will be made. Data is only shared with partner colleges and the UKVI to process your admission.

Exercise of rights

You can exercise your rights of access, rectification, deletion and portability of data, as well as the rights of limitation or opposition to processing, by writing to our compliance team, in which case we will respond within one month.

Right to complain

You have the right to file a complaint if you feel your data rights are not respected. We kindly ask that you contact our compliance team first at https://raay.co.uk/public/#contact so we can resolve your issue immediately. However, you always retain the statutory right to lodge a formal complaint straight with the Information Commissioner's Office (ICO) via their website at https://ico.org.uk.

For more information on the processing of your data, Click here.