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The Guidance makes a surprisingly broad distinction between public and private sector organisations, even when they process the same data for the same purposes. This would remove important protections when personal data are processed by the public sector, and does not appear to be required by the General Data Protection Regulation that the Guidance aims to implement.

Jisc is the UK's expert body for digital technology and digital resources in higher education, further education and research. Since its foundation in the early 1990s, Jisc has played a pivotal role in the adoption of information technology by UK universities and colleges, supporting them to improve learning, teaching, the student experience and institutional efficiency, as well as enabling more powerful research.