Residential Community Student Privacy Notice
Source: https://warwick.ac.uk/services/rescommunity/privacy/ Parent: https://warwick.ac.uk/services/legalandcomplianceservices/dataprotection/otherprivacynotices/
- About this notice
- The personal data we collect and use
- How the University of Warwick obtains your personal data
- Purpose and associated lawful basis
- Lawful bases for processing your personal data under the UK GDPR and DPA 2018
- Confidentiality and data sharing
- Retention of your personal data
- Transfers outside the European Economic Area (UK)
- Data subject rights
- Keeping your personal data secure
- How to contact us
- Changes to this privacy notice
1. About this notice
We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event that you have a query or complaint.
The University of Warwick (“UoW”) is committed to protecting the privacy and security of your personal data. The purpose of this notice is to promote transparency in the use of personal data, and to outline how UoW collects and uses your personal data during and after your educational relationship with us, in accordance with the UK General Data Protection Regulation 2016 (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”).
The UoW collects, uses and is responsible for certain personal data about you. This is known as “processing”. When we do so we are regulated under the UK GDPR and DPA 2018 which applies across the UK and we are responsible as ‘data controller’ of that personal data for the purposes of those laws.
The purpose of this notice is to explain how the University of Warwick (“UoW”) - and more specifically the University’s Residential Community Team (“RCT”) - will collect and use (process) your personal data, what rights you have in relation to that data and to provide transparency about the data collected about you.
The UoW is the data controller under the UK GDPR and the DPA 2018 and we will process your personal data in accordance with the UK GDPR and DPA 2018 at all times. You, as a ‘data subject’, therefore have specific rights to the data that we hold, collect and process.
Throughout this notice, “University”, “we”, “our”, and “us” refer to the UoW (including the RCT); “you” and “your” refer to those expressing an interest in becoming a student at the University (both prior to and during the application process), and those who later become enrolled students at the University.
If you would like this notice in another format (for example: audio, large print, braille), please contact us (see 'How to contact us' below).
2. The personal data we collect and use
Personal data
The following are examples of personal data which may be collected, stored and used by RCT:
- Personal identifiers and biographical information: Full name, date of birth, student ID number, nationality
- Contact details: Home and term time address, telephone number, email address, emergency contact details or next of kin
- Course/academic details: Course, department, start and expected end date, year of study, mode of attendance, course status, timetable, personal tutor
- Accommodation details: Term time address, application choices, application type, hobbies/interests, health/medical information, any additional information provided by the student applicant
- Ethnicity and diversity data: gender, visa status
- Student ID photo
- Health and wellbeing: Health information relevant for room allocations (disclosed disability information), incident and support reports for wellbeing support
- Medical information: For use in emergencies or compliance with public health
- Student discipline and complaints: Records of investigations and outcomes - including appeals (if relevant)
- Campus incident and third party incident reports - including hall lock access data, CCTV and body worn camera recordings (if relevant)
Special category data
We may also collect, store and use what is known as ‘Special Category’ personal data such as that revealing your ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
3. How the University of Warwick obtains your personal data
The Residential Community Team may hold and collect your personal data in a number of ways, for example:
- Information you provide to us when joining the University or during enrolment;
- Information you provide to us by applying to live on or off campus;
- Through communication to or from you by telephone, email, or via the website. For example, when you raise concerns or make enquiries.
- Other areas of the UoW such as Warwick Accommodation, Community Safety, Wellbeing and Student Support, Student Information Centre Reception, Campus Cleaning Services, your academic department, the Chaplaincy and other professional services such as those dealing with disciplinary matters or complaints.
- We may also gain your personal data from third parties, for example, statutory services such as health care professionals, the police, the local authorities, your GP, the Students’ Union or concerned third parties.
Some of your information you are legally or contractually obliged to provide. If you decline to provide the information to us we may not be able to provide services to you or to meet our legal obligations.
4. Purpose and associated lawful basis
The Residential Community Team processes your personal data for the below reasons in order to provide you with the best possible support during your time at the UoW:
| Purpose | Lawful basis |
|---|---|
| Undertaking room allocations for accommodation applications | Performance of a contract |
| Supporting any special requests regarding accommodation allocations/transfers and obtaining any additional further information in relation to the requests | Performance of a contract |
| Liaising with Warwick Accommodation, Wellbeing and Student Support, Campus Cleaning Services, Student Information Centre Reception and Estates to facilitate any special requests for the provisions of accommodation in line with requirements | Performance of a contract |
| Liaising with you regarding student matters on campus | Legitimate interests of the University; vital interests; performance of a contract |
| To provide suitable support to you whilst you are living in campus accommodation which may include liaison with other parts of the UoW including Wellbeing and Student Support or medical services (in the event of a medical emergency) or following a request from public health authorities | Vital interest; performance of a contract |
| Ensuring the safety and security of UoW students, staff, volunteers and third parties instructed on their behalf which may include liaising with Community Safety, Student Information Centre Reception, Estates and the Health and Safety Office | Compliance with a legal obligation |
| Ensuring the safety and security of UoW property which may include liaising with Community Safety, Student Information Centre Reception, Estates and the Health and Safety Office | Compliance with legal obligation; performance of a contract |
| Opportunities for student engagement | Legitimate interests |
| Undertake fact finding action following a student complaint with regards to Life in Halls | Performance of a contract |
| Undertake disciplinary action under Regulation 27 On Campus Residential Accommodation Regulation if required, or referral under Regulation 23 Student Disciplinary Offences | Compliance with legal obligation, performance of a contract |
| Business management and planning, including accounting and auditing | Compliance with a legal obligation and/or legitimate interest of sound management of the business of the University |
| Research and statistical analysis | Legitimate interest of the University; public information |
Use of Special Category Data
Where any of the above activities involve any special category data the Residential Community Team will only process it if your explicit consent has been obtained, it is necessary to protect vital interests or it is necessary for reasons of substantial public interest.
Please note: there may be certain circumstances where the processing of medical/health data is required for social security/protection requirements, protecting your vital interest and/or for reasons of substantial public interest or where the information has been made public to you. UoW will not require consent in these circumstances.
Where we believe it is necessary to protect your vital interests, we may share your personal data with Wellbeing and Student Support, Community Safety or the University's safeguarding team.
5. Lawful bases for processing your personal data under the UK GDPR and DPA 2018
Personal data
Personal data will only be processed when the law permits this to happen. Most commonly personal data will be processed in the following circumstances:
- Where you have given us your consent. Please note that you have the right to withdraw consent at any time.
- In order to fulfil UoW’s obligations to you as part of any contract we have with you.
- Where UoW needs to comply with a legal obligation (for example, the detection or prevention of crime and financial regulations).
- Where it is necessary for UoW’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our interests are the effective and efficient operation of the University.
- To protect the vital interests of you or of another person (for example, in the case of a medical emergency).
- In order to perform a task carried out in the public interest.
Special category data
We may only process special category personal data in the following circumstances where, in addition to a lawful basis for processing, there exists one of the following grounds:
- Explicit consent - where you have given us explicit consent.
- Legal obligation - where the processing is necessary for us/you to carry out/exercise obligations and rights of a legal nature.
- Vital interests - where the processing is necessary in order to protect the vital interests of you or another individual where you are physically or legally incapable of giving consent. This is typically limited to processing needed for medical emergencies.
- Not for profit bodies - where the processing is carried out in the course of the legitimate activities of a not-for-profit body and only relates to members or related persons and the personal data is not disclosed outside that body without consent.
- Public information - where the processing relates to personal data which is manifestly made public by you.
- Legal claims - where the processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
- Substantial public interest - where the processing is necessary for reasons of substantial public interest, on the basis of the law.
- Healthcare - where the processing is necessary for healthcare purposes and is subject to suitable safeguards.
- Public health - where the processing is necessary for public health purposes and is based on the law.
- Archive - where the processing is necessary for archiving, scientific or historical research purposes, or statistical purposes and is based on the law. The law can introduce additional conditions in relation to health, genetic, or biometric data.
UoW will only use personal data for the purposes for which it was collected unless it is considered reasonably that it is needed for another purpose and the reason is compatible with the original purpose. If the University needs to use your personal data for an unrelated purpose, it will notify you and will explain the legal basis that permits it to do so. The University may process your personal data without your knowledge or consent where this is permitted by law.
6. Confidentiality and data sharing
The Residential Community Team is committed to providing a confidential service for both the team and the students that they support in residential halls. The Residential Community Team may share your personal data with different areas of Wellbeing and Student Support, Warwick Accommodation and Community Safety in order to provide you with the best quality of service and support, with third parties where required by law, where it is necessary to administer the working relationship with you or where there is another legitimate interest in doing so. Third parties with whom Residential Community Team may share your data include:
| Third parties within the UK | Lawful basis |
|---|---|
| Wellbeing and Student Support | Necessary for the performance of a contract and/or explicit consent |
| Academic or professional services departments | Necessary for the performance of a contract and/or explicit consent |
| Other UoW professional services - e.g. those that handle complaints or disciplinary matters | Necessary for the performance of a contract and/or explicit consent and/or legitimate interests |
| Warwick Accommodation | Necessary for the performance of a contract and/or explicit consent |
| Community Safety | Necessary for the performance of a contract and/or explicit consent |
| Estates including Campus Cleaning Services | Necessary for the performance of a contract and/or explicit consent |
| Students’ Union | Explicit consent and/or vital interests and/or legitimate interest |
| External organisations to which a referral has been made - e.g. CRASAC | Explicit consent |
| HESA, HEFCE, Office for Students, Office of the Independent Adjudicator | Legitimate interest |
| Police or other emergency services | Compliance with a legal obligation and/or vital interests |
| Health services including Public Health England | Compliance with a legal obligation and/or vital interests |
| Local authorities | Compliance with a legal obligation and/or vital interests |
| Our professional advisors e.g. insurers, auditors, lawyers, etc. | Legitimate interest |
7. Retention of your personal data
The UK GDPR and DPA 2018 requires that personal data should be kept for no longer than is necessary for the purposes for which the personal data are processed (except in certain specific and limited instances).
The University's Record Retention Schedule (RRS) is a tool that enables the University to transparently demonstrate how the organisation complies with its data protection obligations by making provision for the time periods for which common classes of record are retained by UOW.
Full details of the retention periods of records can be found by viewing the records management page and selecting the University’s Record Retention Schedule (RRS), which is kept up to date separately.
8. Transfers outside the UK
If we have to transfer any of your personal data outside the UK we will let you know if the receiving country or organisation is deemed to have adequate data protection provision. Where a country or organisation does not have adequate protections we will put safeguards in place. Details of these safeguards can be provided to you upon request to Legal and Compliance Services.
9. Data subject rights
Under the UK GDPR and DPA 2018 you have a number of important rights free of charge.
You have the right to:
- Be informed of how we collect and use your personal data;
- Access your personal data;
- Require us to correct any mistakes in the data we hold on you;
- Require the erasure of personal data concerning you in certain situations;
- Restrict our processing of your personal data in certain circumstances;
- Receive your personal data, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- Object in certain situations to our continued processing of your personal data or at any time to processing of your personal data for direct marketing; and
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
To exercise any of these rights please refer to the Data Subject Rights page. If a subject access request is made and the request for access is clearly unfounded or excessive, the University reserves the right to refuse to comply with the request in these circumstances.
10. Keeping your personal data secure
The UoW keeps your personal data secure at all times using organisational, physical and technical measures.
Where appropriate, we also take measures such as anonymisation to ensure data cannot be used to identify you and/or encryption to ensure that the data cannot be accessed without the right security accesses and codes.
Where UoW engages a third party to process personal data it will do so on the basis of a written contract which conforms to the security requirement of the UK GDPR.
UoW takes measures to enable data to be restored and accessed in a timely manner in the event of a physical or technical incident.
UoW also ensures that we have appropriate processes in place to test the effectiveness of our security measures.
11. How to contact us
We hope that our Data Protection Officer (DPO) can resolve any query, concern or complaint you raise about our use of your personal data on the contact details below:
The DPO can be contacted via email at infocompliance at warwick dot ac dot uk
Or write to:
The Data Protection Officer
Legal and Compliance Services\ University of Warwick\ University House\ Kirby Corner Road\ CV4 8UW
The UK GDPR and DPA 2018 also gives you the right to lodge a complaint with the Information Commissioner who may be contacted at ico.org.uk/make-a-complaint or telephone: [0303 123 1113].
12. Changes to this privacy notice
This privacy notice was published and revised on 20 July 2023.