The Imperial College London, Global Summer School (GSS), is committed to protecting the privacy and security of your personal information.

This privacy notice sets out how we collect and use your personal information when you apply to or participate in one of our programmes, activities, events or webinars, undertake voluntary or paid casual work with us or request any of our other services.

This information is intended for school pupils, prospective students and applicants to the College, current students, teachers, parents, staff, higher education professionals and other interested parties who would like further information on how we process, store and use personal data.

Information we hold about you

We may collect and process the following data about you when you apply or participate in one of our programmes, activities, events or webinars, sign up for our electronic communications, undertake voluntary work with us or request other services.

Information you give to us

We may collect, store and use the following categories of personal information about you: 

• Full name
• Title
• Gender
• Date of birth
• Nationality and country of residence
• School
• Year group/institution or organisation and year group
• Addresses
• Telephone number
• Personal email address
• Level and grade of previous qualifications attained by the applicant
• Level and grade of qualifications currently being studied by the applicant
• Level and grade of English language qualification
• Details of future qualifications
• Applicant English language ability
• Applicant visa requirements
• Photographs
• Your communication preferences
• Records of communications and interactions we have had with you
• Records of payments made to us in relation to your programme place

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

• Applicant ethnicity
• Applicant disabilities
• Applicant special educational needs or learning disabilities
• Applicant dietary requirements
• Applicant medical conditions
• Medication taken by applicant
• Medical attention required by the applicant
• Bank details (for paid casual workers only)

If you receive our email communications, we may collect information regarding which of our emails you have opened, and links that you have clicked within these.

If you attend a GSS event, activity or programme we may take photographs, audio recordings, and video recordings of you if you have not objected to us doing so.

Information we collect about you

Individuals who apply to the Global Summer School programme will be asked to provide us with information about their parents/guardians or carers, and teachers or referees as part of the application process.

Parents/guardians, carers and teachers will also be asked to confirm information about applicants to our programme, including information about special categories of data outlined above.

For parents and guardians, this may include:

• Name and title
• Email address
• Nationality/country of residence
• Telephone number
• Relationship to applicant
• Occupation
• Educational background and level of education achieved

For teachers and referees, this may include:

• Name and title
• Work email address
• Work telephone number
• School/organisation
• Position/job role
• Relationship to applicant

Parents/guardians, carers and teachers may also be asked to confirm information about applicants to our programmes, including about special categories of data outlined above.

If you apply to one of our programmes, we may also collect information relating to your school or institution. 

How is your personal information collected?

We collect personal information about you in the following ways:

• Information you give to us: We collect most of the personal information about you through our online application system Aspire. You may also give us personal information when you complete our online or printed forms or by corresponding with us by phone, email, or otherwise.
• Information from others: We may receive some personal information from your teacher/referee or parent/guardian as part of the application process.
• Information from third parties: If you use a third party service to find out more information about the Global Summer School programme, and have indicated to the service provider that you wish to be contacted by Imperial, the personal details you provide to them may be shared with us where they have notified you that they will do this.

How we use the information you provide to us

Most commonly, we will use your personal information in the following circumstances:

1. Where you have consented to us processing your data in order to provide you with specific information, print or digital materials, or other services you have requested
2. 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.

• For application, admission and registration purposes prior to participating on a programme, event or activity
• To deliver and administer our programmes, events and activities and inform you about them
• To ensure your safety and wellbeing during our programmes events and activities
• To contact you for a reference for an applicant to one of our programmes
• For the administration of volunteering or paid work opportunities
• For the administration of Global Summer School’s activities

3. Where we need to comply with a legal obligation.
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.
5. 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. Usually this will include:

• For internal record keeping
• To monitor and evaluate the effectiveness of our programmes, activities, events and marketing materials through research, statistical analysis and surveys
• To monitor and evaluate trends in applications to the College through statistical analysis
• To monitor and evaluate the effectiveness of our electronic communications through statistical analysis
• To contact you with information about the College, or our events and activities that may be relevant to you where you have not objected to us doing so (please see section 4 below for more details.
• To take photographs, audio and video footage at our events, activities, and programmes for use in the College’s digital and printed promotional materials, communications, publications and social media sites.

6. Where it is necessary in order to protect your vital interests or someone else’s vital interests.
7. Where you have consented to the processing.
8. To provide you with information about the College and our activities and events that we feel may be relevant to you. We will only send you electronic marketing messages in the following situations:

• You consent to this by completing the relevant field on our web forms, event registration forms
• You are a higher education professional with whom we have an existing relationship and have not objected to us doing so
• You apply for Global Summer School, and have not objected to us doing so

If you do not want us to use your data in this way you can opt out of these at the point which we collect your data or use the unsubscribe link in our email communications at any time after our initial contact.

Please note that in order to ensure that the content of our electronic communications is relevant to you, we may send some of these based on specific information you have provided. This includes information such as your country or region of domicile, gender, age, subject area(s) of interest, and level of studies.

Situations in which we will use your personal information

The situations in which we will use your personal information are listed below.

Enable us to perform our contract with you:

• To provide you with the information and services that you request from us.
• To contact you in relation to your application and/or offer, including for the purposes of feedback.
• To notify you or your parent/guardian about changes to our service.
• Administering the contract we have entered into with you.
• Gathering evidence for possible grievance or disciplinary hearings.
• To monitor your use of our information and communication systems to ensure compliance with our IT policies
•  To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

 To comply with legal obligations:

• To ensure we meet any and all legal obligations with regards to the service we provide to you for the duration of your application and/or attendance on the Global Summer School.
• Complying with health and safety obligations.

For legitimate interest purposes, provided your fundamental rights do not override these:

• 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, where you have agreed to receive such communications.
• Equal opportunities monitoring.

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 information and services that you request from us though you will be informed if this is the case. Where providing information is optional, this will also be made clear to you.

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

In some cases we may need to process sensitive personal information that you have provided or we have collected about you. We will only collect sensitive personal information outlined earlier in this Privacy Notice and for the reasons below:

• Where the processing is necessary to protect your vital interests (or those of another person) where you are incapable of giving consent. 
• Where the processing relates to personal data which have been manifestly made public by you.
• Where the processing is necessary for the establishment, exercise or defence of legal claims, or for courts acting in their judicial capacity.
• 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. 

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 during the programme and to provide appropriate adjustments. 
• We will use information about your 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 to process sensitive personal information if we use special categories of your personal information to ensure your health and safety, and to ensure meaningful equal opportunity monitoring and reporting. 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. Whilst 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.

Who we share your information with

We may have to share your data with third parties, including third-party service providers and other entities in the College group. Additionally, we may share your personal information with staff from Imperial’s academic and support service departments, as well as external contractors that are providing parts of the specific service you have requested.

We share this 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?

The following activities are carried out by third-party service providers:.

• Data Harvesting Student CRM: Our CRM database service, when you register your interest for the Global Summer School.
• Qualtrics: Our online form provider – your data is shared when you complete one of the online forms. For example, the arrival and departures form.
• Mailchimp (The Rocket Science Group LLC): Third party email marketing provider, Mailchimp, to be able to send you important service emails.
• DocuSign: To provide a secure contract with application offer holders.
• Guidebook: The Global Summer School welcome app, to store and share important information with you for the duration of the programme.
• Microsoft Teams: To provide a secure platform for the sharing of academic work within mentor groups and to enable communication between students and pastoral mentors.
• GoToWebinar (Log me in inc): When you join a Global Summer School webinar.

Data will only be shared using secure data transfer methods and stored by us and our partners on secure systems. We and our partners will not use your personal data in any way that would affect you individually.

Transferring information outside the EU

We may transfer the personal information we collect about you in the following country outside the UK;

• USA in order to perform our contract with you.

The process of sharing your information with USA is in accordance with the implementation of Standard Contract Clauses otherwise known as the International Data Transfer Agreement.

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.

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. We have also agreed and defined security standards in place to ensure all third parties treat your data in the same way we do.

Data retention

How long will you use my data for?

We are required to only keep your information for as long as is necessary.

When you apply to or participate in our programme, complete one of our web forms to register your interest, or complete one of our web forms to request other services we provide (subscription to our e-newsletters) we will retain your personal data based on the criteria below.

Where more than one applies, we may retain your data based on whichever of these occurs at the latest date:

• The April after you have reached the age of 25 years old
• If you have indicated a preferred year of entry for undergraduate or postgraduate study on our enquiry/event forms, your data will kept until the April +2 years following the preferred year of entry you most recently provided
• If you have not indicated a preferred year of entry, your data will be kept until the April +3 years after the date you last requested our services, registered for/attended an event
• If you apply to undergraduate or postgraduate courses at Imperial Marketing, Recruitment and Admissions will keep your personal data until the April +5 years following the year of entry for the course to which you apply 

For security purposes, data may exist on backup servers with our database and CRM suppliers for an additional 3 months after deletion. Data will exist for backup purposes only and will not be accessed or processed during this time.

Any personal data processed for medical purposes or as emergency contact details will be retained until the conclusion of the programme unless we are required to keep the data for longer to comply with any necessary referral or follow up queries.

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.

Personal data relating to casual workers or volunteers will be retained for the duration of their work with us, however non-personal data may be held for monitoring purposes.

If you are a teacher or counsellor with whom we have an ongoing relationship, your professional contact details will be held on our database until we are notified of any changes to these or you request for these to be removed.

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.

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.