Enterprise Division Privacy Notice

November 2018

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 and the College’s Data Protection Policy.

This notice applies to current and former corporate partner staff, College staff and students, affiliated start-up companies, venture capital companies, volunteer mentors, investors, college alumni, individuals or staff members of businesses who access the College’s business support services, and staff of companies who lease office space, laboratory space or co-location facilities managed by the College. 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.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.

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 
  • Gender 
  • Location of employment or workplace 
  • Information about your use of our information and communications systems 
  • Your image and likeness (as captured in photographs or filming)
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).

How is your personal information collected? 

We collect personal information about you through events, meetings and business exchanges by entering the details onto a database. We may sometimes collect additional information from third parties including e.g. (among others) former employers, credit reference agencies or other background check agencies.

How we will use information about you

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 it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us. 

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

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 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 below 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 event registration and/or 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 contract 
  • To administer and fulfil requirements as agreed in the contract and any related terms and conditions 
  • To notify you [or your guarantor] about changes to our service 
  • Making a decision about e.g. your recruitment or appointment 
  • Determining the terms on which you work for us 
  • Checking you are legally entitled to work in the UK 
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions 
  • Administering the contract, we have entered into with you 
  • Business management and planning, including accounting and auditing 
  • Conducting performance reviews, managing performance and determining performance requirements 
  • Assessing qualifications for a particular job or task 
  • Making arrangements for the termination of our 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 prevent fraud 
  • To monitor your use of our information and communication systems to analyse our online systems and services 
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution 
  • To conduct data analytics studies to review and better understand corporate engagement levels 
  • 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 
  • To provide you with relevant news and special offers by email, phone or post where you have consented to receive this information 
  • Equal opportunities monitoring 
  • To use audio, photography and video footage featuring your likeness, captured on College grounds, in official College publicity materials, to promote the College and its work to support businesses and entrepreneurship, thereby furthering the College and the Enterprise Division’s missions and strategic goals.

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, or we may be prevented from complying with our legal obligations.

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 we need to carry out our legal obligations and in line with the College’s Data Protection Policy. 
  3. Where it is needed in the public interest, such as for equal opportunities monitoring and in line with the College’s Data Protection Policy.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations

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

  • We will 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 equal opportunity monitoring and reporting. 

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. 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.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

  1. Where we have notified you of the decision and given you 21 days to request a reconsideration. 
  2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. 
  3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. 

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

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 working relationship with you or where we have another legitimate interest in doing so.

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 our group. The following activities are carried out by thirdparty service providers: The following third-party service providers process personal information about you for the following purposes:

  • Salesforce: Data reporting and marketing activities 
  • Razor Edge: Data reporting activities 
  • Wellspring: Data reporting activities 
  • MailChimp: Mailing/Marketing activities 
  • Eventbrite: Event management activities 
  • FormAssembly: Web form data collection activities 
  • Qualtrics: Web form data collection activities 
  • Wrike: Project Management activities 
  • Mavenlink: Project Management activities 
  • Mentimeter: Presentation tool 
  • Trello: Project Management activities 
  • Office 365: Cloud storage, communications and reporting activities 
  • Google docs: Cloud storage, communications and reporting activities 
  • Slack: Cloud based communication and collaboration activities.
  • Social media services including YouTube, Instagram, Facebook, Twitter and LinkedIn

All third parties comply with GDPR.

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 [United States of America] in order to perform our contract with you. There is an adequacy decision by the European Commission in respect of that country. This means that the country to which we transfer your data are deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure 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: We will ensure personal information treated by these third parties are complaint with the EU-US Privacy Shield.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.
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 for different records the College holds are available in our Retention Schedule

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. 

VersionDateSection, ParagraphSummary of changeAuthorised by
1.1 05.11.18
  • 2nd paragraph from top (beginning: 'This notice applies')
  • 'The kind of information we hold about you'
  • 'Situations in which we will use your personal information'

Updated individuals covered by the notice to include those accessing business support services offered by the College and staff of companies leasing space on College grounds.

Updated list of kinds of information held and situations in which we will use personal information to include video footage used for publicity purposes.

Simon Herriot
1.0 11.04.18      
Summary of the table's contents