What is the purpose of this page?

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.

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 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.

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 

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.

Individuals who apply to the Global Summer School will be asked to provide us with information about their parents/guardians, carers or teachers prior to participating on the programme.

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.

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
• School
• 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
• Bank details (for paid casual workers)

Information we may collect about teachers/referees or parents/guardians/carers from applicants to the Summer School:

• Title
• First name
• Last name
• Email address
• Country
• Telephone number
• School/organisation
• Position/job role
• Relationship to applicant

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

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.

*Please note the lists above are not exhaustive. For details of the information, we collect for a specific activity, programme or event please refer to the signup form for that particular activity.

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.

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.

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 GSS’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.

• 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:

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

We need 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 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 application and/or offer, 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 application and/or attendance on the Global Summer School.** 
• 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.* 
• Complying with health and safety obligations.** 
• 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 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.*** 
• To provide you with access to the Global Summer School programme app. 

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

"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:

In limited circumstances, with your explicit written consent.

• 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.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the College 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.

Special categories of data

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:

• You consent to us processing this data to for application, admission and registration purposes prior to participating on a programme, event or activity
• You consent to us processing this data to ensure your safety and wellbeing during our programmes, events and activities
• For reporting and evaluation purposes where there is substantial public interest based on our agenda to widen participation in higher education
• To carry out employment rights and obligations if you undertake voluntary or paid work with the department

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.

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:

• Catering provision in on-campus food outlets.
• Our CRM database service, Student CRM, when you register your interest for the Global Summer School.
• Our online form provider, Qualtrics – your data is shared when you complete one of the online forms. For example, the arrival and departures form.
• 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 – 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.

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.

Any data released by the College or third parties into the public domain will only be released in aggregate form, and fully anonymised to prevent identification of individual students.

Transferring information outside the EU

We may transfer the personal information we collect about you in the following country outside the EU; USA in order to perform our contract with you.

The process of sharing your information with USA is in accordance with “Privacy Shield”

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.

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.

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. 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 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 SRO 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.

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.