Students' Union UCL is committed to protecting and respecting your privacy, whether you are a student, staff member, or other person engaging with Union services.
The Union adheres to UCL's policies on data protection. As part of this, the Union adopts the UCL Information Security Policy and supporting policies including the Data Protection Policy which can be found at https://www.ucl.ac.uk/informationsecurity/policy
This privacy notice sets out how any personal data we collect from you through your electronic and/or paper application to UCL will be processed by us. This notice also sets out the basis on which any personal data related to your application which is passed to us by individuals and by third parties is collected and processed. Please read the following carefully to understand how we collect, process and share your personal data.
- What are the Union's data protection obligations?
In accordance with the Data Protection Act (1998) and the GDPR, and any data protection legislation enacted in the UK (the "Data Protection Legislation") we are a data controller and this means that we are legally responsible for the personal data we collect and hold about you. One of our responsibilities is to tell you about the different ways in which we use your personal data – what information we collect, our legal basis for doing so, why we collect it, where we collect it from and whether and with whom we will share it with. We also need to tell you about your rights in relation to your personal data.
The Union will use the personal data you provide, as well as personal data for which you have given consent for the Union to receive in order to manage your Union membership, or to enable you to interact with Union services as a non-member. In addition to the information in this statement, you may be given further information about the uses of your personal data when you sign up to use specific services and facilities we offer, and in certain situations, you may be asked whether you give your consent to us processing information about you.
The Union agrees that Personal Data shall be:
- processed lawfully, fairly and in a transparent manner in relation to the data subject.
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- accurate and, where necessary, kept up to date.
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed, in accordance with UCL and Union data retention schedules designed for this purpose;
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
- be able to demonstrate compliance with the above principles
- On what basis does the Union collect and process personal data?
Data Protection Laws require that we meet certain conditions before we are allowed to use your data in the manner described in this notice, including having a "legal basis" for the processing. We take our responsibilities under Data Protection Laws extremely seriously, including meeting these conditions. The legal bases on which your personal data are collected are explained below.
Consent: We may ask you to provide us with a special category or sensitive personal data as detailed in this document, which we will agree only to process with your express consent.
Legitimate interests: The processing of your personal data may be necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or by fundamental rights and freedoms which require protection of personal data. It may be necessary for our legitimate interests to collect your personal data to enable us to manage certain operations and services of the Union effectively.
Performance of contract: The processing of your personal data may be necessary in relation to the contract we have entered into with you to provide the Unions services to you or because you have asked for something to be done so you can enter into such contract.
- What personal data does the Union hold?
'Personal data' means any information which identifies you as an individual. It may include your name but it may also be other information such as your date of birth, nationality and gender which when combined identify you.
After enrolment we receive the following data from UCL for current students who have not opted out of Union membership:
- Student code
- Student UPI
- UCL email address
- Date of birth
- Course code
- Student enrolment status
- Mode of attendance
- Fee status
- Course Block
- Student Course Start
- Student Course End
- Department code
- Faculty code
- Student contact address, including postcode
- Term time address code
- Course Name
- Hall of Residence
- Caring Responsibility
Depending on your relationship to the union, we will collect additional information in order for us to manage membership, involvement with the Union, or contract of employment which could include bank account details; next of kin details; visa status; and event attendance.
The data required will be covered during the on-boarding process and enrolment in a service.
Some of the personal data used for the above purposes are classed as being within 'special categories of personal data' under the Data Protection Legislation, for example, information relating to your ethnicity or any disability. This is collected to monitor our equalities responsibilities. Disability information will also be shared with relevant UCL staff in order to provide you with the best possible support for your studies. Access to, and the sharing of, this information is controlled very carefully. You will be given more details about our use of any sensitive personal data when we collect it from you.
Some of this information may also be collected to allow us to manage any ongoing case with the Union advice Service. Details of what is information is collected will be discussed with you during registration with the Advice Service. Further details about how the Advice Service may use your information can be viewed in the separate Advice Service data protection statement.
- How does the Union collect data?
The bulk of student data is received directly and securely from UCL, and is provided only where a student has opted-in and consented to this data being provided to the Union.
We work closely with other third parties including, for example volunteering partner's or event organisers, who may receive information about you from them if you have provided specific consent to this sharing of your personal data in your agreements with those third parties. If you have provided such consent, we may receive and process any of the information from third parties in relation to you.
Both your image and voice may be recorded during our attendance at Union events.
- How does the Union use and process personal data?
We process information we hold about you for the following purposes
to facilitate and manage your Union membership
to provide the services you request or initiate with the Union.
to manage your involvement in the democratic process such as standing for election and voting
to administer the financial aspects of your relationship with us – ie payroll, reimbursement of payment requests
to manage your membership and participation for Student activities and events
to manage your interest and involvement in volunteering opportunities facilitated by the Union
to manage access to Union systems such as the website
to enable effective communications with you in relation to Union activities and updates
to support your training, health, safety and welfare requirements including registering and using the Advice service
to produce statistics and research for internal and statutory reporting purposes
to monitor our responsibilities under equalities legislation.
Access to your personal information is limited to staff who have a legitimate need to see it for the purpose of carrying out their job at the Union in furtherance of the objectives outlined above.
- When and why is my personal information shared with others?
In all cases, the Union endeavours to share the least possible amount of personal data with other agencies. However, in some cases the services of the Union require data sharing, and/or you may otherwise consent to more data being shared for other purposes.
As part of a student's Union membership, your personal data may be disclosed to other organisations as required by law, for crime prevention, investigation or detection purposes. We may also share it in emergency situations where it is in your vital interests for us to do so.
We also use third party services ("processors") to facilitate our operations. Where we engage with such third parties, we insist upon strict contractual requirements to be adhered to by in order to protect the personal data. Current processors currently include:
- Leaseweb (for hosting)
- BUCS (for sports clubs)
- Mailchimp (for e-mail communications)
- Worldnet TPS (for online payments)
- SurveyMonkey (for surveys)
- The Mailing People (for mailouts)
- Zoom (for event signups)
Data may be shared or disclosed by the Union in other circumstances when needed. In these cases, we will share only the minimum required for the purpose. Such situations may include:
- HEAR: As a student, some of your personal data will be shared with UCL which will be to allow your achievements via the Union to be accredited, for example by inclusion in the Higher Education Achievement Report.
- Student Quality Reviewers scheme jointly run with the UCL Arena Centre
- Payroll: As a student staff member, UCL act as payroll service for the Union and process student staff wages on our behalf. Name, payroll number and bank details are shared with UCL to manage payment of wages.
- Volunteering: If you undertake a placement or undertake any voluntary activity facilitated by the Union, with a third party organisation or institution in the UK or in another country, personal data relating to you may be shared with the partner organisation/institution for the purposes of administering the placement.
- Disciplinaries: in accordance with our governing documents (Bye-law 15) we may share the results of student disciplinaries with UCL staff.
Sensitive personal data relating to your health or a disability will not be shared without your express consent unless required by law or in your vital interests in an emergency situation.
- How long does the Union keep personal data?
Your data will be retained in accordance with the Union's Data Retention Schedule.
After you leave UCL or cease to be a member of the Union, certain parts of your data may be retained as a permanent archival record for research purposes and to confirm your award and period of study. At this point, all identifiable fields will be 'pseudonymised' to ensure it cannot be identified as you.
- How do I access my data?
You have the right to access information held about you. For UCL, details are set out on the University's Data Protection policy https://www.ucl.ac.uk/informationsecurity/policy/public-policy/DataProtection.
As a student, data held on you can be found via the student 'My Profile' page on the Students' Union Website
Other website users can also view basic personal details via the My Profile page on the Union website.
Your right of access can also be exercised at any time by contacting us at SU.email@example.com
- How do I change the data the Union holds about me?
The Data Protection Laws require us to take reasonable steps to ensure that any personal data we process is accurate and up-to-date.
If the data is received from UCL then the student should contact UCL Portico services to update their data.
Students are able to make changes to some personal data that they have supplied during the course of their Union membership. Basic personal details can be updated via the My Profile page on the Union website
- Who regulates the use of my personal information?
The Union is registered on the Information Commissioners' Register of Data Controllers.
The Union's registration number is Z2701645 and sets out, in very general terms, the full range of purposes for which we use student, staff and all other personal information. See the Information Commissioners Office website for details http://www.ico.org.uk/what_we_cover/register_of_data_controllers.aspx.
- Who do I contact with questions?
If you need further assistance, please contact the Union via SU.firstname.lastname@example.org, or for general UCL data protection queries the University Data Protection Officer via email@example.com or by visiting the University's data protection web pages.
- How are staff members covered?
The Students Union UCL complies with the UCL Staff Policy Notice.