Report and Support - PRIVACY NOTICE
What is the purpose of this document?
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 2018 and the General Data Protection Regulations (the “GDPR”) 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 current and former students and staff, members of the public. This notice does not form part of any contract of employment or other contract to provide services. 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.
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:
· Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
· Date of birth or Age Category
· Gender you identify with
· Marital status and dependants.
· Location of employment, workplace and incident
· Those who you have given us permission to communicate with
· Details regarding incidents you have disclosed to us.
· Documents, files, images, photographs, electronic/social media messages that you have shared with us.
· Information pertaining to Imperial College including your department, level of study, CID
· Information about your use of our information and communications systems.
We may also collect, store and use the following "special categories" of more sensitive personal information:
· Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
· Information about your health, including any medical condition, health and sickness records
· Offences and alleged offences raised by you or against you.
How is your personal information collected?
We collect personal information about you by the report details you disclose in the Report and Support tool or when details are provided by a data subject about you. The reporting party will be able to disclose anonymously or as a named contact by providing contact details as part of the report. The level of detail provided will be down to the person reporting the incident. The report format has a series of standard questions to gather the required information about the incident including relevant personal information and all questions deemed optional will be defined as such.
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: Where we need to comply with a legal obligation* Necessary for the performance of a contract** 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.*** Where you have consented to the processing****
Situations in which 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 provide you with support and take appropriate action where a named report has been submitted. For anonymous reports, the College will use the information provided to develop trends and management insight to drive recommendations for broader action. [describe e.g. 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. [We have indicated by [asterisks] the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.]
· To provide you with the information and services that you request from us.*
· To contact you in relation to your contact with the service*/**/****
· To ensure we meet any and all legal obligations with regards to the service we provide to you*
· Administering the contract we have entered into with you with regards to the adherence to the conditions agreed**
· To help us address incidents of harassment and bullying*
· To help us plan support and develop preventative measures in relation to harassment and bullying across the College***
· Gathering evidence for possible grievance or disciplinary hearings*/**
· Making decisions about continued employment or engagement. */**
· Making arrangements for the termination of a working relationship. */**
· Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work. */**
· Complying with health and safety obligations. */**
· To conduct data analytics studies to review and better understand harassment and bullying of all types***
· To ensure the information we hold about you is up to date and accurate. **/***
· To ensure that content from our site is presented in the most effective manner for you and your computer or mobile device***
· Diversity monitoring in relation to harassment and bullying**/***
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 provide the necessary support or take required actions to address an incident.
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 it is necessary in the context of employment law, or laws relating to social security and social protection. 3. Where the processing is necessary to protect your vital interests (or those of another person) where you are incapable of giving consent. 4. Where the processing is carried out in the course of our legitimate activities as a charity, with respect to our own members, former members, or persons with whom we have regular contact in connection with our purposes. 5. Where the processing relates to personal data which have been manifestly made public by you. 6. Where the processing is necessary for the establishment, exercise or defence of legal claims, or for courts acting in their judicial capacity.
Our obligations
We will use your particularly sensitive personal information in the following ways:
· To provide you with services that you request from us including investigating to any allegations
· To adhere to legal obligations regarding the welfare of its students / staff / others
· To inform relevant authorities regarding the incident where required to do so
· To monitor student need and trends of those using Sexual Violence Liaison Officers in order to improve what we offer
· To improve measures taken to reduce the likelihood of incidents reoccurring
· To use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful monitoring and reporting
Do we need your consent?
We do not need your consent to process sensitive personal information if we use special categories of your personal information to provide support and address incidents that are reported to us either by your or against you outside of the initial notification whereby following this point other legal basis will be in place. 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 and it is your choice whether to report anonymously or not.
Data sharing
| Under usual circumstances we do not share your personal data with a third party except where you have consented for us to do so or when your identity has been removed (anonymised data) and we need to share anonymised data with third-party service providers and/or with other entities in College. Where we require third parties involvement we will ensure the security of the data and to treat it in accordance with the law. We may have to share your data with third parties, including third-party service providers and other entities in the College group. We may have to share your data with third party data controllers dependent on the allegations and findings. Third parties may include the Police, the NHS, external Support Services. 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, but only where necessary as part of any investigation whereby such transfer is required. 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. This will be:
· Where we have the express consent of the student, member of staff or member of the public to disclose the information.
· Where we believe the student, employee or third party is in significant and serious danger.
· Where we would be liable to a civil or criminal court procedure if the information was not disclosed or as part of a legal proceedings.
· To provide an appropriate service to you.
Which third-party service providers process my personal information?
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within the College group. [The following activities are carried out by third-party service providers:
· ICT – in order to maintain technology and communications
· Culture Shift – in order to provide and maintain the Report and Support platform.
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 College 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 outside the European Economic Area in order to perform our contract with you. Examples of such scenarios will include where you or the involved party are based outside of the UK or when there is a separate legal requirement for us to do so.
However, to ensure that your personal information does receive an adequate level of protection we have put in place appropriate measure[s] dependent on the situation to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.. These measures may include use of encryption, pseudonomisation, contractual clauses, court orders or other legally defined mechanism.
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 whilst utilising Report and Support. 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 and have been trained to utilise the data and the system. They will only process your personal information on our instructions, in accordance with College procedures surrounding investigations of this type 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 for different records the College holds are available in our retention policy which is available on this website: http://www.imperial.ac.uk/media/imperial-college/administration-and-support-services/records-and-archives/public/RetentionSchedule.pdf. 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 relationship with us where appropriate.
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
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.