Staff Accommodation, Imperial College London Privacy Policy

What is the purpose of this Privacy Policy?

Imperial College of Science, Technology and Medicine (the “College” or “Imperial”) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the applicable data protection legislation (the Data Protection Act 1998 until 24 May 2018 and the General Data Protection Regulations (the “GDPR”) from 25 May 2018 and the College’s Data Protection Policy.

The College is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to members of Imperial College staff or members of the public who enter a tenancy agreement for Imperial College London residential accommodation or have enquired about doing so. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

How is your personal information collected?

We collect personal information about you in the following ways:

  • Information you give to us. You may give us information about you when you sign a Tenancy Agreement, complete and submit a contact form on our website, or when you correspond with us by phone, email or otherwise
  • Information from third parties
  • Your details may be obtained through your employer
  • From previous landlords as part of the mandatory reference checks
  • Information we may automatically collect when you use the Resident portal

 The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are "special categories" of more sensitive personal data which require a higher level of protection. We may collect, store, and use the following categories of personal information about you.

Information you give to us:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Valid passport and visa documents
  • Employment details, including salary
  • Your communication preferences
  • Name and contact details of your next of kin
  • Information relating to your tenancy and previous tenancies including previous addresses and behaviour

  • Records of communications and interactions we have had with you
  • Records of payments made to us in relation to your tenancy

We may also collect, store and use the following "special categories" of more sensitive personal information:

  • Information about your health, including any medical condition, health and dietary information

Information we collect about you

How we will use information about you and the legal basis for processing your data under the GDPR

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you or in order to take steps at your request prior to the entry into a contract.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  4. Where you have consented to the processing.

We may also use your personal information where we need to protect your interests (or someone else's interests).

How we will use your personal information

We need all the categories of information in the list above (see the kind of information we hold about you) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

  • To provide you with the information and services that you request from us.
  • To contact you in relation to your tenancy, including for the purposes of feedback.
  • To inform our decision relating to your application. This is not an automated decision process.
  • To ensure we meet any and all legal obligations with regards to the service we provide to you for the duration of your tenancy agreement.
  • To administer and fulfil requirements as agreed in the contract and any related terms and conditions.
  • Administering the contract we have entered into with you.
  • Business management and planning, including accounting and auditing.
  • To prevent fraud.
  • To ensure the information we hold about you is up to date and accurate.
  • To inform you of any changes to our website, services or goods and products.

Eighty Eight Wood Lane residents

If you are a resident at Eighty Eight Wood Lane and are a registered user of the Resident Portal, we will also use your data to:

  • Provide you with direct access to your Resident Portal account and data that we hold about you and your tenancy
  • Provide you with the ability to make online payments (where this service is offered to you)
  • Enable you to communicate with your neighbours, landlord and service team (where this service is offered to you)
  • Enable you to communicate with your lettings team
  • Provide you with information about your household
  • To provide you with relevant news and special offers by email, text message, phone or post (where you have opted in).
  • Preferences used in the Resident Portal such as favourite bus station, tube lines, railway stations, offer types
  • Login history, account registration history, activity history
  • Unique identifiers to any integrated third-party systems
  • Information from your device or browser such as IP address, location, device type and browser version.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as your Tenancy Agreement) or respond to your enquiry.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit written consent.
  2. Where the processing is necessary to protect your vital interests (or those of another person) where you are incapable of giving consent.
  3. Where the processing relates to personal data which have been manifestly made public by you.
  4. Where the processing is necessary for the establishment, exercise or defence of legal claims, or for courts acting in their judicial capacity.
  5. Where the processing is necessary for reasons of substantial public interest, and occurs on the basis of a law that is, inter alia, proportionate to the aim pursued and protects your rights as a data subject.
  6. Where the processing is required for the purpose of medical treatment undertaken by health professionals, including assessing the working capacity of employees and the management of health or social care systems and services.
  7. Our obligations

We will use your particularly sensitive personal information in the following ways:

  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in carrying out our contract with you.

 Do we need your consent?

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We may share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

"Third parties" include third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes:

  • Local Council: We have a legal requirement to provide your personal information for the purposes of Council Tax and s106 compliance
  • Our facilities management provider, currently University Partnership Programmes: your data is shared for the purpose of fulfilling your Tenancy Agreement. You can view UPP's Privacy Policy online
  • Maintenance and housekeeping subcontractors in the event of maintenance to your property
  • Our online contact form provider, Qualtrics: Your data is shared when you submit an enquiry or application via the Imperial website form and input your personal data
  • Third party email provider, MailChimp: Your data is shared when you submit an application form, for the purposes of communicating with you about your application

If you are a resident at Eighty Eight Wood Lane and Clayworks the following third-party service providers process personal information about you for the following purposes:

  • Our sales and marketing agent, Knight Frank: Your personal data is shared when you enter into a Tenancy Agreement or use the Resident Portal. You can view Knight Frank’s Privacy Policy online
  • Our resident portal provider, Engage. Your personal data is shared when you create an account to the Eighty Eight Wood Lane Resident Portal
  • Third party energy suppliers

Some, non-identifiable, personal data may also be shared with our contractors and service providers who process data on behalf of Eighty Eight Wood Lane and Clayworks to perform certain business related functions. These include:

  • Analytics and search engine providers that assist us in the improvement and optimisation of our website

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business and operations of the College. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the EU

We may transfer the personal information we collect about you to the following country outside the EU; USA in order to perform our contract with you.

The process of sharing your information with USA is in accordance with “Privacy Shield”. This means that the country to which we transfer your data is deemed to provide an adequate level of protection for your personal information which is underpinned in the contractual provisions we have in place with the data processor.

Data security

We have put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods are as follows:

  • Contact details for marketing purposes will be kept indefinitely unless you withdraw your consent.
  • Contract, Assured Tenancy Agreements, details of financial transactions, statements and bills will be kept for at least 10 years from the date of expiry of the Tenancy Agreement.
  • Personal resident profiles on the Eighty Eight Wood Lane Resident Portal will be retained until the end of the Tenancy Agreement, at which point the profile will be deleted within 30 days.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.


Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your [working] relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the College’s Data Protection Officer in writing. 
No fee usually required.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the College’s Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer at:

Imperial College London
Data Protection Officer
Exhibition Road
Faculty Building Level 4
London
SW7 2AZ

e-mail: dpo@imperial.ac.uk    

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

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