Always ask before you pass on someone’s name and number, tell them who will contact them and why, share only what is needed, and delete details once you no longer need them. These are good data protection habits for anyone making referrals. This article is general information, not legal advice.
Why does consent matter when you refer someone?
A name and a phone number are personal data, and under UK data protection law people have a say over who receives their information and what is done with it. When you pass someone’s details to Omega Partners, you are sharing another person’s information, so the safe starting point is that they have clearly agreed.
It also makes practical sense. An introduction only works when the person wants it. A call they are expecting is welcome; a call out of the blue from a company they’ve never heard of usually isn’t.
What should you do before passing on someone’s details?
Ask them, and wait for a clear yes. A message such as “Is it okay if someone from Omega Partners calls you about the course we talked about?” works well. A written reply like “Yes, go ahead” also gives you a record.
If the person hesitates, leave it. A shrug or a “maybe” is not a yes, and you shouldn’t make the decision for them.
How do you tell them who will contact them and why?
Name the organisation and say what the contact is about. For example: someone from Omega Partners, which helps adults apply to university and to Student Finance England at no cost to the student, will call or message to talk about study options. Say how they are likely to be contacted, such as by phone, text or email.
Be specific. The ICO’s direct marketing checklist says that where details are passed to third parties for marketing, people must be given the name of those third parties, with enough detail to make an informed choice. A referral isn’t always marketing, but the principle is a good guide: name the company, rather than saying something vague like “a partner” or “an education company”.
How much should you share?
Only what is needed for the introduction. That usually means a name and the best way to reach the person, plus the fact that they have agreed to be contacted. Don’t pass on sensitive details such as health, money worries, immigration status or family circumstances, even if they told you, unless they have asked you to.
You don’t need to check anyone’s eligibility yourself. The admissions team will ask what it needs to know, the university makes every admissions decision, and Student Finance England makes every funding decision.
Can you add people to lists or group chats?
Not without asking. Adding someone to a WhatsApp group shares their number with every member, and a mailing list can lead to messages they never asked for. Keep introductions private and one to one. If you would like to send someone updates, ask them separately and make it easy to say no.
How long should you keep someone’s details?
No longer than you need to. Once you have made the introduction, you rarely need their number any more. Delete it, and keep a reference such as a first name and a date for your own records. Our guide to keeping simple records of your referral income suggests what to keep.
Store any notes securely, such as on a phone with a passcode or in a password-protected file, and never in a shared notebook or shared device.
What if someone says no or changes their mind?
Respect it straight away. If they say no before you have passed on their details, don’t pass them on and don’t raise it again unless they do. If they change their mind afterwards, tell Omega Partners promptly so the team knows not to contact them, and don’t try to persuade them back.
Consultants must never offer money, gifts or any other incentive to a student to apply or enrol, and must never refer someone who doesn’t genuinely intend to study and attend. Pressure of any kind goes against the role.
What about sending messages to lots of people?
Be careful with texts or emails sent to people who haven’t asked to hear from you. UK rules on electronic marketing (the Privacy and Electronic Communications Regulations, or PECR) generally require consent before marketing messages are sent to individuals. The simplest approach is to stick to personal conversations with people you know, and to check the ICO’s guidance before sending anything that looks like a marketing message. Our guide to using WhatsApp and social media to find referrals covers posting in groups.
Where can you read more?
Omega Partners’ privacy policy explains how Omega handles personal data. The ICO has practical guidance for small organisations, including a direct marketing checklist. For the role itself, see our checklist on who makes a good referral and the vacancy page.
Frequently asked questions
Is a WhatsApp message enough to show consent?
A clear written yes in a message is better than a spoken one, because you have a record. Keep it only as long as you need it.
What if a friend gives me someone else’s number and says they’d be interested?
Don’t pass it on. Ask your friend to put you in touch, or to pass on your details so the person can contact you if they want to.
Can I refer someone who hasn’t asked me about university?
Only if you have talked about it and they have then agreed to be contacted. A conversation first, then a clear yes, is the right order.
Do I need to register with the ICO?
That depends on your circumstances. The ICO has an online self-assessment to check whether you need to pay the data protection fee, so use that if you are unsure.
