This policy, together with the College’s Privacy Notice for Students and Prospective Students and the College’s accommodation licence, sets out how the Student Hub and Residential Services at Imperial College London collect, store and use your data.

All personal data is held in accordance with the Data Protection Act 2018, the General Data Protection Regulations (GDPR) and the College’s Data Protection Policy.

Further to the full Privacy Notice for Students and Prospective Students, the notice below will provide specific information about the data we process for College accommodation and related services.

The kind of information we hold about you

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Date of birth
• Gender
• Marital status and dependants, where applicable
• Next of kin and emergency contact information
• Accommodation details and records
• Records of communications and interactions we have had with you 
• Disciplinary and grievance information relating to a tenancy in halls of residence
• Financial information, such as payment and billing data, invoices, credit notes and debt balances
• CCTV footage and other information obtained through electronic means such as swipe-card records

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

• Information about your health, including any medical condition, disability or wellbeing

Please also note that:

• If you have applied to the College’s Rent Guarantor Scheme, we will also hold (i) copies of tenancy agreements (ii) references from previous landlords or private halls of reference, and (iii) evidence of financial means to pay the rent for the property.

How is your personal information collected? 

We collect most of the personal information about you through automatic data feeds from College systems, via our online forms, in person at Open Days and at the Student Accommodation Office. We collect this information in the course of your accommodation enquiry, application or tenancy and in the course of providing services to you such as private housing advice and guidance, in addition to when we ask for your feedback on services. 

We may sometimes collect additional information from third parties including, for example, information from wardens relating to your conduct in halls, or from landlords from whom you may be renting a private property. 

The basis for processing your data, how we use that data and with whom we share it

We will process your personal data as part of the contractual relationship between you and the College in applying for, allocating and managing tenancies in College accommodation; and in providing ongoing services such as advice on finding private accommodation.

We will do this either in ways which you have consented to, or because it is otherwise necessary for a lawful purpose. 

To this end, we will share your data with third parties such as:

• Kinetic Solutions (Kx) – provider of our accommodation management software (Kx Student) and our Accommodation Hub (ACCHUB) for applications, contracts and einductions
• Student Pad (PAD Group) – provider of ‘Imperial Home Solutions’, a private property search website for the sole use of Imperial students and staff
• Netsend Limited (or any other suitable provider that the College may engage) – provider of the online student fees and payment portal, in order to present all accommodation invoices, credit notes and debt balances via MyImperial
• Endsleigh, to confirm that you are resident in a College hall of residence, in order to provide basic insurance cover for the contents inside your room
• A2Dominion, who own and manage Parsons House, where College currently houses 47 students on floors 1-4
• Du Cane Housing Association, accommodation providers for postgraduate students around Hammersmith Hospital  
• Prince's Gardens Health Centre - as part of the decision-making process for allocations concerning students with medical, wellbeing or disability requirements 
• Local Authorities - we will disclose details of full-time registered students and wardening team members to the relevant local authority so that liability for Council Tax and rights to vote may be established 

In addition, we may also process and share your data for the following purposes: 

• With our Wardens, Wardening teams, Residential Services staff and our service providers (cleaning, maintenance and security/concierge contractors, for example) to enable the smooth operation of our halls of residence
• For the allocation of rooms, ensuring there is an appropriate student mix, measuring satisfaction, debt recovery, dealing with insurance claims, investigating complaints and enabling us to carry out our obligations.
• For crime prevention and detection.
• In emergency situations such as illness or serious injury we may pass your information to the emergency services, close family or next of kin.
• We will also use data in our legitimate interests or your vital interests where there is a serious risk of harm to you or to others or to our or other people’s property, to ensure the health and safety of students, staff and visitors and for all matters arising from your membership of the College.
• Information about you may be shared, only if necessary, with internal and external financial and legal teams in order to seek counsel on private housing matters, including the College’s Rent Guarantor Scheme.

Storing your data

• Your personal data will be stored safely and securely on Kinetics (Kx) using secure College servers for the purposes of administering your College accommodation applications and tenancies. Access to this information is only permitted with an approved username and password.
• After you leave the College, some student data (including some personal data) will be retained as a permanent archival record for research and legal purposes. Your data is otherwise retained in accordance with the College's Retention Schedule. 
• Some personal data, including archived applications to the College’s Rent Guarantor Scheme, are stored in secure areas as paper copies. Paper documents relating to the Rent Guarantor Scheme are retained for the duration of the applicable tenancy plus one additional year.

When we will contact you

We will contact you by email to:

• send information relating to your accommodation application, contract and e-induction prior to you moving into College accommodation
• provide you with information relating to halls during your tenancy
• provide you with relevant information about finding private accommodation in future years, only during your tenancy
• invite you to take part in surveys about your accommodation experiences from time to time 

Changes to our Privacy Policy

We will keep this privacy policy under review and will make changes to it from time to time. Any changes we make to our privacy policy will be posted on this page and where appropriate, notified to you by email.

Last updated 3 April 2023