This policy is applicable to past and present community of Gloucester Student Houses (GSH).
This policy is intended to provide information about how GSH will use (or “process”) personal data about individuals including: its current, past and prospective tenants; and their parents, carers or guardians (referred to in this policy as “parents”); any of those engaged in a management agreement (referred to in this policy as “landlords”).
This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Tenants, parents and landlords are all encouraged to read this policy and understand GSH’s obligations to its entire community.
This policy applies alongside any other information GSH may provide about a particular use of personal data, for example when collecting data via an online or paper form.
This policy also applies in addition to GSH’s other relevant terms and conditions and policies, including:
Anyone who works for, or acts on behalf of, GSH (including staff, volunteers and service providers) should also be aware of and comply with this policy.
Responsibility for data protection
Louise Coles as Compliance Officer will deal with all your requests and enquiries concerning GSH’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this policy and Data Protection Law.
Louise Coles is appointed to undertake Data Protection Officer (DPO) duties. Louise can be contacted by emailing email@example.com.
Why GSH needs to process personal data
In order to carry out its ordinary duties to tenants, parents and landlords, GSH needs to process a wide range of personal data about individuals (including current, past and prospective tenants, parents and landlords) as part of its daily operation.
Some of this activity GSH will need to carry out in order to fulfil its legal rights, duties or obligations.
Types of personal data processed by GSH
This will include by way of example:
How GSH collects data
Generally, GSH receives personal data from the individual directly (including, in the case of tenants, from their parents). This may be via a form, or simply in the ordinary course of interaction or communication (such as email or written assessments).
However, in some cases personal data will be supplied by third parties (for example other professionals or authorities working with that individual); or collected from publicly available resources.
Who has access to personal data and who GSH shares it with
Occasionally, GSH will need to share personal information relating to its community with third parties, such as:
For the most part, personal data collected by GSH will remain within GSH, and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis).
In accordance with Data Protection Law, some of GSH’s processing activity may be carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the School’s specific directions.
How long we keep personal data
GSH will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep ordinary personnel files is up to 7 years following departure from accommodation. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.
If you have any specific queries about how our retention policy is applied or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Louise Coles. However, please bear in mind that GSH will often have lawful and necessary reasons to hold on to some personal data even following such request.
A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes.
Keeping in touch and supporting GSH
GSH and/or any relevant other organisation may use the contact details of tenants, parents and landlords and other members of GSH community to keep them updated about the activities of GSH, including by sending updates and newsletters, by email and by post.
Rights of access, etc.
Individuals have various rights under Data Protection Law to access and understand personal data about them held by GSH, and in some cases ask for it to be erased or amended or have it transferred to others, or for GSH to stop processing it – but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to Louise Coles.
GSH will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information).
GSH will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, GSH may ask you to reconsider (but only where Data Protection Law allows it).
Requests that cannot be fulfilled
You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals, or information which is subject to legal privilege (for example legal advice given to or sought by GSH, or documents prepared in connection with a legal action).
You may have heard of the “right to be forgotten”. However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this policy. All such requests will be considered on their own merits.
Where GSH is relying on consent as a means to process personal data, any person may withdraw this consent at any time. Examples where we do rely on consent are certain types of uses of images, marketing material etc. Please be aware however that GSH may not be relying on consent but have another lawful reason to process the personal data in question even without your consent.
That reason will usually have been asserted under this policy or may otherwise exist under some form of contract or agreement with the individual.
The rights under Data Protection Law belong to the individual to whom the data relates. Where consent is required, it may in some cases be necessary or appropriate to seek the individual’s consent. Parents should be aware that in such situations they may not be consulted, depending on the interests of the tenant, the parents’ rights at law or under their contract, and all the circumstances.
Data accuracy and security
GSH will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify Louise Coles of any significant changes to important information, such as contact details, held about them.
An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under Data Protection Law): please see above for details of why GSH may need to process your data, of who you may contact if you disagree.
GSH will take appropriate technical and organisational steps to ensure the security of personal data about individuals. All staff will be made aware of these security measures and their duties under Data Protection Law and receive relevant training as necessary.
GSH will update this policy from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
Queries and complaints
Any comments or queries on this policy should be directed to Louise Coles.
If an individual believes that GSh has not complied with this policy or acted otherwise than in accordance with Data Protection Law, they should notify Louise Coles. You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with GSH before involving the regulator.