Student Accommodation privacy notice

NTU is a “data controller” which means we are responsible for deciding how we hold and use personal information about you.

This Privacy Notice applies to all students deciding to book student accommodation services (“you” or “your”) or services that link to it (collectively, our “NTU Accommodation Services”).

Please read this Privacy Notice carefully and contact our Data Protection Officer if you have any questions about our privacy practices or your personal information choices.

Attn: Data Protection Officer.

Nottingham Trent University Address: 50 Shakespeare Street, Nottingham, NG1 4FQ

Email: DPO@ntu.ac.uk

We may need to update this Privacy Notice from time to time. If changes made to this Privacy Notice are considered to be material, we will notify you of the changes.

NTU is committed to the responsible handling and protection of personal information.

Personal Data, or personal information, means any information about an individual from which that person (a “Data Subject”) can be identified. It does not include data where the identity has been removed (anonymous data).The information will be Personal Data if a person can be identified either directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. For example personal data may include names, addresses, email addresses and telephone numbers; it may also include images in photographs or films and recorded telephone conversations.

We collect, use, disclose, transfer, and store personal information to deliver our accommodation services to you and for our operational and business purposes as described in this Privacy Notice. We want to be clear about our privacy practices so that you are fully informed and can make choices about the use of your information, and we encourage you to contact us at any time with questions or concerns: DPO@ntu.ac.uk

We collect personal information from you when you access our student accommodation booking services. There are two separate processes that you might go through, depending on the category of accommodation you are seeking. These processes are:

• NTU-managed bookings (for bookings at Brackenhurst or those delivered by our bookings partner University Partnerships Programme (“UPP”)); or
• Private bookings where we work with external accommodation providers.

For both processes, the categories of personal information that we may collect, store and use about you include (but are not limited to):

• Your NTU ID number (which, when going through our NTU-managed process, will automatically provide our Student Accommodation Services Team with the necessary student data linked with the NTU ID number, including the data listed below)
• Your name and contact details (email address and phone number)
• Date of Birth
• The course you have applied for
• Your accommodation preference(s)
• Financial details (for NTU-managed bookings this will be for payment of the deposit and accommodation charges, for private bookings this will be managed by the private accommodation provider).

We process this data in order to enter into and administer the contract for accommodation with you (if you do not provide this information this could limit the services we are able to provide you).

In addition we will also retain a record of any general enquiries, complaints, reports about accommodation usage, as well as any feedback you submit to us via our online form or survey results (anonymised where appropriate). We process this data typically because we have a legitimate interest in upholding our accommodation regulations, responding to complaints, and monitoring, evaluating, auditing and developing our accommodation services (we will ensure that any processing undertaken in this area is not overridden by your individual rights and freedoms).

Sensitive types of personal data

We may also need to process some sensitive personal information about you in order to properly provide the accommodation services. This is sometimes referred to as ‘Special Category’ personal data which includes racial or ethnic origin, physical or mental health conditions, sexual orientation and biometric or genetic data.

We will not need to process all these types of information for the purposes of providing accommodation, but we do need to ensure that in certain circumstances the accommodation that you are offered is suitable in the event you have any particular requirements (e.g. a disability).

In particular, we might ask you for:

• Your gender.
• Any disabilities or relevant health conditions you would like us to take into account when providing you with accommodation services.

In most cases the above data will be provided directly by you. However in some cases we may:

• collect personal information from NTU to help us maintain data accuracy and provide and enhance NTU Accommodation Services
• receive personal data about you from your Accommodation Advisor, NTU Reps or from UPP (our partner accommodation provider), for example data regarding any issues we can assist you in resolving, or any incidents within the Halls which require our attention.

We have covered above why we require certain specific types of personal data from you for the provision of student accommodation services. In the course of providing those services we may also use your personal information for the following purposes:

• To provide you with information on products or services that you may request from us, or which we feel may be of interest to you, and where you have given consent for us to contact you for such purposes.
• To carry out our contractual obligations between you and us.
• Where it is necessary to comply with a legal obligation.
• To provide management statistics through reporting using NTU Accommodation Services data which may be used by us to enhance the student experience.
• For security, safety and disciplinary purposes (through the use of CCTV and information to support our Student Code of Behaviour)
• To ensure that content from our website or Services is presented in the most effective manner for you and for your computer or device by gathering aggregate information about our users, using it to analyse the effectiveness and efficiency of communications.
• To ensure we meet our statutory obligations, including those related to diversity and equal opportunity.
• Photographs demonstrating our accommodation opportunities as part of general marketing materials, for example in our annual report, accommodation guides or materials. Personal data alongside photographs will only be used with explicit consent.
• To ensure compliance with the Prevent Duty under the Counter Terrorism & Security Act 2015
• To notify you about changes to our Services.

NTU shares or discloses personal information when necessary to provide Services or conduct our business operations. When we share personal information, we do so in accordance with data privacy and security requirements. We may occasionally share non-personal, anonymised or pseudonymised, and statistical data with third parties.

We may share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legal requirement or legitimate interest in doing so. Third parties will only process your personal data on our instructions and where they have agreed to treat that information confidentially and to keep it secure.

Below are the parties with whom we may share personal information and why:

• Within NTU: Associated entities or services around the world are provided data by a variety of NTU teams and functions, and personal information will be made available to them if necessary for the provision of Services, account administration, marketing, student support and technical support, for instance.
• University Partnerships Programme (UPP): UPP are our partner for the operation and management of student accommodation. Where you choose to reside in UPP-managed accommodation, we share information (as set out in this notice) with UPP to support those students. Find out more regarding the privacy responsibilities of UPP.
• Other private accommodation providers: if a student requests access to alternative private services, we can support them by putting them in touch with other private accommodation providers and sharing data with those providers.
• Other third-party service providers: We partner with and are supported by service providers both in the UK around the world. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, such as direct marketing services, advertising and data analytics. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
• Payment service providers.
• We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; fraud or safeguarding.
• External scholarship/funding providers;
• We may also use personal information to meet our internal and external audit or governmental requirements, information security purposes, and as we otherwise believe to be necessary or appropriate.
  • (a) Under applicable law, which may include laws outside your country of residence;
  • (b) To respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence;
  • (c) To enforce our terms and conditions; and
  • (d) To protect our rights, privacy, safety, or property, or those of other persons.

All such third parties are prohibited from using your personal information except to provide these services to NTU, and they are required to maintain the confidentiality of your information. NTU ensures such third parties handle your information in accordance with the GDPR (as applied, enacted and amended in UK law).

We will not store your personal information for longer than is necessary. NTU will ensure that our trusted partners and selected third parties with whom we share your personal information in accordance with this Privacy Notice will delete your personal information when they no longer require it.

In determining data retention periods, NTU takes into consideration local laws, contractual obligations, and the expectations and requirements of our data subjects. When we no longer need personal information, we securely delete or destroy it.

We have appropriate security measures in place to prevent your personal data 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 requirement to know.

• Policies and procedures – measures are in place to protect against accidental loss and unauthorised access, use, destruction, or disclosure of data.
• Business Continuity and Disaster Recovery strategies that are designed to safeguard the continuity of our service to our clients and to protect our people and assets.
• Appropriate restrictions on access to personal information.
• Monitoring and physical measures, to store and transfer data securely.
• Data Privacy Impact Assessments (DPIA) in accordance with legal requirements and our business policies.
• Periodic training on privacy, information security, and other related subjects for employees and contractors.
• Vendor risk management.
• Contracts and security reviews on third-party vendors and providers of services.

Your personal information may be transferred by us or our trusted partners outside of the European Economic Area (the “EEA”). The trusted partners that may do this are organisations who process data for analysis or marketing purposes, including a marketing automation hub where the email address of recipients will be logged and a record of email delivery, opening, click-through and bounce-backs will be kept. Our partner uses Microsoft’s Windows Azure data centres located in East US (Virginia), West Europe (Netherlands), and Australia East (New South Wales).

NTU has networks, databases, servers, systems, and support located throughout the world. NTU collaborates with third parties such as cloud hosting services, suppliers, and technology support located around the world to serve the needs of the NTU, workforce, and students. Your personal information may be shared with record matching and customer targeting partners, including Google, Facebook, Snapchat and LinkedIn.  Some of these partners process personal data in Canada and the United States of America.

Our accommodation booking system is provided by StarRez. This partner processes data to enable accommodation marketing and lettings management and contains personal data (including, but not limited to; age, course details, gender, disability information, booking status) in order to offer you suitable accommodation and contact details (email address, home address, and phone number) to communicate with you about your booking. Our partner offers system support from offices in East US (North Carolina), West US (Colorado) and Australia (Victoria).

We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within NTU or to third parties in areas outside of your home country.

NTU shall ensure that your personal information transferred to countries outside of the EEA is adequately protected by transferring the personal information in compliance with International Data Transfer Agreement requirements and relevant addendums to the European Commission’s standard contractual clauses.

This means, your rights and protection remain with your data, i.e.: we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your personal information protect it. If you would like to know more about our data transfer practices, please contact our Data Protection Officer.

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your 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 personal information that we hold about you. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.

• Request erasure of your personal information in limited circumstances. 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 processing your personal information on the basis of our legitimate interest (or that 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 or suspension 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.

• Object to any direct marketing (for example, email marketing or phone calls) by us, and to require us to stop such marketing.

• Object to any automated decision-making about you which produces legal effects or otherwise significantly affects you.

• Request the transfer of your personal information to another party.

If you are concerned about an aspect of your interaction with NTU Accommodation Services please bring your concerns to the attention of relevant NTU Accommodation Services staff. You can contact us on accommodation@ntu.ac.uk.

Please contact us with any requests related to your personal information, or with any questions or queries you may have about this statement. Our DPO contact is: DPO@ntu.ac.uk

If you are not satisfied with how NTU manages your personal data, you have the right to make a complaint to a data protection regulator.