Personal data, purpose and legal basis
UAL's Accommodation Services team will process information UAL already holds about you (your name, email address, phone number, address, date of birth and gender) and the information you provide in your application, for the following purposes:
When your tenancy is with UAL - to enter into an agreement with you (GDPR Art.6(1)(b)'necessary for the performance of contract')
When your tenancy is with an external provider - to pass on your details to them to help secure a place for you with their accommodation (GDPR Art.6(1)(f)'legitimate interests')
UAL will use your contact and application data, and other information such as:
- Details of your enquiries, correspondence and other communication between you and UAL staff
- Your room number, room changes, maintenance carried out, rent due, and payments made
- Incidents, complaints or feedback
- Information about your conduct, behaviour, tenancy breaches and disciplinary action
to manage your accommodation in line with your tenancy agreement with UAL (GDPR Art.6(1)(b)'necessary for the performance of contract').
Under GDPR Art.6(1)(f) 'legitimate interests' or Art.6(1)(a)'consent' (where the contact is direct marketing), we will also inform you of events and services provided by our Social Programme aimed at supporting your health and wellbeing. You can unsubscribe from these communications by contacting accommodation@arts.ac.uk or in response to any email you receive.
CCTV, card access and other premises access data will be processed under UAL’s legitimate interests to protect its property, staff and students.
'Special Category' information such as your health, disability, sexuality, ethnicity and religion will be processed and shared only with your 'explicit consent' for the specific purpose as collected from you before the data is collected, under GDPR Art.6(1)(a) and Art.9(2)(a), except in rare circumstances where another Article 9 legal basis or GDPR exemption applies and collecting consent is not appropriate, for example where necessary to save the life of yourself and others.
UAL Accommodation Services will provide welfare support in accordance with UAL's student welfare policies and processes agreed with the Student Services team, either with your consent or another Art.9 legal basis determined under the relevant student safeguarding and counselling guidelines.
Data Controllers, Processors and Sharing
UAL is a 'Controller' of your data for the purpose of your application and where UAL manage your tenancy. For residents of the Costume Store, IQSA (Athena) Limited are also data controller alongside UAL in relation to the management and maintenance of the premises, and UAL will share your personal data with them for these purposes. If you enter into a tenancy agreement with an external provider, they will be 'Controller' of your personal data under data protection legislation when fulfilling that agreement. Please contact them directly for their privacy information, including the ICO registration and who to contact regarding your privacy rights.
UAL uses CBRE to support the maintenance and security of premises it manages, and Fresh Student Living to manage the Glassyard Building, Highline Building and Sketch House on UAL’s behalf. As necessary for these purposes, these organisations will act as 'Processor' of your personal data under UAL’s instruction.
Your name, student ID, email address, phone number and tenancy details will be passed to the Tenancy Deposit Scheme so they can contact you in relation to your deposit.
Your name, date of birth, nationality and halls address will be shared with the relevant local authority to register you to vote, if you are eligible to do so.
Retention
Your personal data related to the management and performance of your tenancy agreement and events during your stay will be kept for up to 6 years after the end of your tenancy.
CCTV data will be kept for 30 days unless needed by law enforcement.
Data given under 'Consent' will be deleted within one month if you withdraw consent, or otherwise as will be described at the point where consent is first recorded if you do not withdraw it.
For any other purposes, your personal data will be used and retained by UAL's Accommodation Services' other UAL departments and processors acting on UAL's behalf only as permitted by an appropriate GDPR legal basis or exemption. Wherever possible and as required, this will be described to you in a specific privacy notice at the point of collection or use (e.g. on a feedback form, application for an event etc.)
For more information about UAL and your privacy rights, go to www.arts.ac.uk/privacy-information.