This policy (together with our accommodation licence and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
All personal data is held and processed in accordance with the Data Protection Act 1998, the College’s Data Protection Policy and other relevant legislation.
Information we may collect from you
Information you give us
You may give us information about you by filling in an accommodation application, or contact form on our site or by corresponding with us by phone, e-mail or otherwise. This information includes:
- Biographical information including your name, gender and date of birth
- Your contact details and communication preferences
- Details of your current study
- Details of your right to reside or study in the UK
- Biographical information relating to your guarantor
- Your family, friends or partner/spousal details if named as a next of kin
- Records of communications and interactions we have had with you
- Your accommodation details and records
- Records of payments made to us in relation to your accommodation
Information we collect about you
With regard to each of your visits to our site we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information you give to us will be used:
- To provide you with the information and services that you request from us
- To contact you in relation to your application and/or accommodation licence. Including for the purposes of feedback.
- To ensure we meet any and all legal obligations with regards to the service we provide to you for the duration of your accommodation licence
- To ensure the information we hold about you is up to date and accurate
- To administer and fulfil requirements as agreed in the accommodation licence and any related terms and conditions
- To notify you or your guarantor about changes to our service
- To ensure that content from our site is presented in the most effective manner for you and your computer or mobile device
- To provide you with relevant news and special offers by email, phone or post where you have consented to receive this information
Information we collect about you will be used:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer or mobile device
- To allow you to participate in interactive features of our service, when you choose to do so and if, and to the extent, applicable
- As part of our efforts to keep our site safe and secure
Information we receive from other sources:
We may combine such information with information you give to us and information we collect about you. We may use such information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your information with selected third parties including:
- Our sales and marketing provider (currently CRM Students Limited)
- Our facilities management providers (currently Apleona HSG Ltd and University Partnership Programmes)
- With the academic institution you are currently studying at
- Analytics and search engine providers that assist us in the improvement and optimisation of our site
- Our website agency (currently Mr B & Friends)
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If Imperial College of Science, Technology and Medicine or substantially all of its assets are acquired by, or merged with those of, a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of Imperial College of Science, Technology and Medicine, our students, alumni, staff or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We do not sell any of the data we hold about you to third party organisations.
Where we store your personal data
Any information you provide to us as part of your application and for the duration of your accommodation licence is stored by CRM Students on secured cloud servers (via TCAS). Access to the information is only permitted with an approved username and password. Information is encrypted and no information is held on local drives. We do not store any credit/debit card details.
It is your responsibility to keep safe the password you have chosen which allows you access to the secure portal. We ask you not to share this password with anyone.
We are committed to holding your information securely, and will ensure that all policies and permissions for access to your information are in line with the Data Protection Act 1998, or equivalent legislation that replaces or repeals the Act. Information will only be held for as a long as it is necessary for the above purposes.
This website is a secure website, denoted by the SSL certificate and padlock icon. Any information you share through this website is encrypted.
Access to information and your other rights
You have the right to:
- Access the personal data we hold about you;
- Object to us processing your personal data;
- Request amends to your personal data; and
- Withdraw consent for us to process your personal data,
in each case, as explained below.
Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998, or equivalent legislation that replaces or repeals the Act. If we do hold information about you we will:
- Give you a description of it;
- Tell you why we are holding it;
- Tell you who it could be disclosed to; and
- Let you have a copy of the information in an intelligible form.
To make a request to GradPad for any personal information we may hold, you need to complete the Subject Access Request Application Form located on the Imperial College website. Please return the form to the address below together with:
- If making a request prior to 25 May 2018, a payment of £10 (cheques should be made payable to Imperial College). If making a request on or after 25 May 2018, the law allows us to charge a fee if the request is ‘manifestly unfounded or excessive’; we may also charge a reasonable administrative-cost fee if further copies of information are requested.
- Evidence of your identity as the data subject or documentation that confirms your entitlement to act on the data subject’s behalf (for example, a signed form of authority or power of attorney):
The College Data Protection Officer
Imperial College London
Faculty Building, Level 4
South Kensington Campus
If we do hold information about you, you can ask us to correct any mistakes or delete your information by writing to the Data Protection Officer for Imperial College London at the address noted above.
You may revoke your consent to the processing of your data at any time by sending an email to firstname.lastname@example.org. Provided it is not necessary for the purpose you provided it to us, such as continuing to provide you with accommodation or for legal requirements, we will cease processing your data.
We keep our privacy notice under regular review. This privacy notice was last updated on 2 January 2018.
For the purposes of the Data Protection Act 1998, or equivalent legislation that replaces or repeals the Act, the data controller is Imperial College of Science, Technology and Medicine of Exhibition Road, London SW7 2AZ.
The legal basis for processing your personal data is for the performance of a contract and for compliance with any legal obligations related to that.
You have the right to lodge a complaint or report a concern about our handling of your personal data with the Information Commissioner’s Office at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF