Data privacy notice
Student Recruitment and Outreach – privacy notice
Imperial College London Student Recruitment and Outreach (SRO) 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 to or participate in one of our programmes, activities, events or webinars, sign up for our electronic communications, undertake voluntary work with us or request our other services:
Information you give to us
This may include personal details such as:
- your name
- address and contact details
- nationality and country of residence
- date of birth
- school/institution or organisation
- information relating to your past and future academic progress, educational or professional background,
- your communication preferences
- details of emergency contacts
For events, programmes and activities we may also collect special categories of data including:
- information about health conditions
- dietary requirements
- photocopies of your passport/visa
For events, programmes and activities funded by the College under its Access Agreement this may also include information about:
- your eligibility for Free School Meals
- your family household income
- whether you have been or are in care
- whether you are a young carer with caring responsibilities
For paid casual workers this may also include your bank details.
*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.
Information we collect about you
Individuals who apply to SRO programmes, events and activities may be asked to provide us with information about their parents/guardians, carers or teachers prior to participating on a programme or at an event.
Parents/guardians, carers and teachers may also be asked to confirm information about applicants to our programmes, events and activities, including information about special categories of data outlined above. For details of what information we may collect or confirm please see Information we collect–parents/guardians/careers/teachers/referees [PDF].
If you are applying to one of our programmes, we may also collect information regarding your school or institution including its academic and socio-economic profile.
If you go on to apply to undergraduate or postgraduate programmes at the College, we may collect information relating to your higher education applications from third parties such as:
- the College’s Registry Department
- the College’s Student Finance Department
If you attend an event organised by a third party, and indicate to the organiser that you wish to be contacted by Imperial, the personal details you provide to the event organiser may be shared with us where the organiser has notified you they will do this.
If you use a third party service that has a relationship with Imperial (for instance Capex, EdX) and you 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 they will do this.
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 an SRO 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 we use the information you provide to us
Most commonly, we will use your personal information in the following circumstances:
- 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
- Where we need to perform services relating to a contract we have entered into with you
- 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 SRO’s activities
- 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.
- 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 or programme application 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 undergraduate or postgraduate programmes at Imperial and have not objected to us doing so
- you register for one of our Open Days or Campus tours and have not objected to us doing so
If you do not want us to use you 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.
For applicants to our undergraduate or postgraduate courses this may also include fee status and citizenship.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to comply with a legal obligation.
- Where we need to protect your interests (or someone else's interests).
- Where it is needed in the public interest or for official purposes.
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 which is compatible with the original purpose. If however 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.
If you are under 13 years of age we will only process your personal information if we have parent/guardian consent to do so.
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
Who we share your information with
We will only share your information where we have a legal basis to do so. Any data shared with third parties as described below will be used by the third party organisation for the purpose of monitoring and evaluation in line with this notice, or to help evaluate the effectiveness of our outreach activities, events and programmes as part of government policy to widen participation in higher education, and to develop future policy:
- The University and Colleges Admissions Service (UCAS)
- The Higher Education Access Tracker (HEAT) service and its member institutions
- The Centre for Evaluation and Monitoring (CEM)
- External funders of specific programmes such as JP Morgan, The Sutton Trust or the Elsevier Foundation and Berkeley Foundation
- Evaluation partners of external funders of specific programmes such as NFER and the Bridge Group. Other partners may be engaged in the future
Additionally, we may share your personal information with staff from Imperial’s academic and support services departments, as well as external contractors that are providing parts of the specific service you have requested. This is for reporting and evaluation purposes in line with this notice.
We may also share your personal data with our contractors and service providers who process personal data on behalf of SRO to perform certain business-related functions. These include:
- Data Harvesting Student CRM — event management and CRM database services
- GoToWebinar (Log me in inc) — online webinar services
- Mailbird — delivery of printed prospectuses and materials
- Qualtrics — applications, surveys and email suppression services
- Eventbrite — event management services
- Mailchimp (The Rocket Science Group LLC) — email services
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.
For programmes funded, or part-funded, by The Sutton Trust, all information you provide on your application form will be stored by Imperial College London and shared with the Sutton Trust.
To read about how The Sutton Trust will use your information please see their privacy notice.
How long we keep your information for
We are required to only keep your information for as long as is necessary.
When you apply to or participate in one of our programmes, activities, events or webinars, complete one of our web forms to register your interest in these, or complete one of our web forms to request other services we provide (delivery of our prospectus, access to the alternative guide to funding, subscription to our e-newsletters, access to webinar recordings) 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.
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 Higher Education professional 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.
Your rights as a data subject
You have the right to:
- Withdraw consent where that is the legal basis of our processing
- Access your personal data that we process, see Access to the information we hold about you
- Rectify inaccuracies in personal data that we hold about you
- Be forgotten i.e. for your details to be removed from systems that we use to process your personal data
- Restrict the processing of your data in certain ways
- Obtain a copy of your data in a commonly used electronic form
- Object to certain processing of your personal data by us
For further information see the Information Commissioner’s Office or contact Imperial’s Data Protection Officer.
You have a right to complain to the Information Commissioner’s Office about the way in which we process your personal data.
Access to the information we hold about you
You have a right to request a copy of the data that we hold about you, to ask us to amend your details or ask us to stop processing or delete your personal data in certain circumstances.
If you would like a copy of the data supplied to us, or have any questions or concerns about the use of data for the purposes described, or would like your data to be deleted from our system, please contact us by writing to:
Student Recruitment and Outreach — Data Enquiry
Imperial College London
Level 3 Sherfield Building
Alternatively, please email us at: firstname.lastname@example.org with the subject title: Data Enquiry.
The College is currently required to register its notice of being a data controller with the UK’s regulatory body – the Information Commissioner’s Officer. The College’s registration number is Z5940050.
You can contact the College’s Data Protection Officer at:
Level 4 Faculty Building
Imperial College London
If we are unable to help resolve your concerns, you have the right to raise your concern with the Information Commissioner’s Officer: www.ico.org.uk
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.
Last updated: 10 December 2019