PRIVACY NOTICE FOR IMPERIAL COLLEGE LONDON EVENTS

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Transcription:

PRIVACY NOTICE FOR IMPERIAL COLLEGE LONDON EVENTS This Privacy Ntice (Ntice) explains hw Imperial Cllege Lndn (the Cllege, we, ur, us) prcesses yur persnal data when yu attend its events (including public lectures, demnstratins, cmpetitins, turs f the Cllege's campus and facilities, and nline events such as webinars (Event)) and yur rights in relatin t the persnal data we hld. Fr the purpses f any applicable data prtectin laws in England and Wales, including frm 25 May 2018 the EU General Data Prtectin Regulatin 2016/679 (GDPR), the Cllege is the data cntrller f yur persnal data. The Cllege has appinted a Data Prtectin Officer, wh can be cntacted via email at dp@imperial.ac.uk, via telephne n 20 7594 3502 and via pst at Imperial Cllege Lndn, Data Prtectin Officer, Faculty Building Level 4, Lndn SW7 2AZ. Fr mre infrmatin abut the Cllege's data prtectin plicies please refer t ur data prtectin webpage http://www.imperial.ac.uk/admin-services/legal-services-ffice/dataprtectin/. Hw yur persnal data is cllected The Cllege cllects yur persnal data frm the fllwing surces: frm yu, typically when yu: cmplete frms in relatin t attending r participating in an Event, including buying r registering fr tickets nline; attend and participate in an Event; interact with ne f ur representatives r emplyees during an Event (fr example when yu sign up t a mailing list r enter a cmpetitin); cmplete ur surveys and feedback frms; cmmunicate with us by pst, email, nline chat, scial media, telephne r anther frmat; visit the Cllege's website, including when yu search, register r use ur nline payment/ticketing prtals r sign-up fr an event. frm third parties such as: ticketing agencies wh sell tickets r prcess ticket rders n ur behalf; a third party wh may purchase tickets n yur behalf r register yur details with us; ur website, webinar, ticketing and sign-up platfrm prviders; ur payment prvider wh will cnfirm details f yur payment; publicly available surces when researching and creating bigraphies f speakers and key attendees. What categries f persnal data are cllected? 1 4137-9973-2755.1

We cllect the fllwing categries f persnal data: Identificatin, backgrund and cntact details bigraphical infrmatin such as yur name, title, gender and date f birth; yur image, audi and likeness (as captured n a webinar, in phtgraphs r n recrdings we make f the Event, and n CCTV where the Event is hsted at ur premises); yur cntact details including address, email address, nline chat r scial media accunt details and phne number; yur qualificatins, prfessinal experience and institutin r emplyer (where this is relevant t an Event); yur student clubs r scieties, affiliatins and ther cnnectins with the Cllege (fr example, where this is relevant t Alumni Events); infrmatin abut yur schl, educatinal backgrund, and family financial infrmatin (such as family incme) where this is relevant t selecting participants fr an Event and deciding whether yu are eligible t participate in a particular Event; Online and transactinal details f yur IP address, brwser type and perating system when yu visit ur website; events that yu have attended in the past r fr which yu are registered t attend in the future; payment details and yur financial transactins in relatin t Events; recrds f cmmunicatins sent t yu by the Cllege r received frm yu; We may als cllect the fllwing special categries f persnal data where it is necessary fr the purpses set ut in this Ntice (please als see the sectin n Special categries f persnal data fr details abut hw we prcess this data): infrmatin cncerning yur health and medical cnditins (e.g. disability and dietary needs); trade unin membership number (fr example, where membership prvides yu with access t (r a discunt n) an Event; criminal acts caught n ur CCTV cameras; and diversity infrmatin abut yur racial r ethnic rigin; religin r similar beliefs; and sexual rientatin. The basis fr prcessing yur data, hw we use that data and with whm we share it We will prcess yur persnal data either in ways yu have cnsented t, r because it is therwise necessary fr a lawful purpse. We set these ut as fllws: 2 4137-9973-2755.1

As part f the cntractual relatinship between yu and the Cllege (fr example in relatin t a ticket yu have purchased) In this respect we use yur persnal data fr the fllwing purpses: t deliver the Event yu have registered fr; t crrespnd with yu abut the Event, including sending yu pre and pst-event infrmatin. As part f this prcess, we will expect t share yur persnal data with: ur agents, cntractrs and service prviders (including prviders f accmmdatin, catering, IT, webinar and ther supprt services) where applicable and where it is necessary fr them t receive the infrmatin; ur bank t whm payment details are prvided in rder t prcess a payment; c-rganisers r partners wh are invlved in the delivery f an Event; relevant prfessinal bdies r institutins where membership r affiliatin affects yur entitlement t attend (r results in a discunt n) an Event. Other legitimate interests Yur persnal data will als be prcessed because it is necessary fr the Cllege's legitimate interests r the legitimate interests f a third party. This will always be weighed against yur rights, interests and expectatins. Examples f where we prcess data fr purpses that fall under legitimate interests include: creating bigraphies f attendees r a delegate r speaker list and distributing the bigraphy/list t speakers and attendees (except in circumstances where it is apprpriate t gain yur cnsent); sharing yur infrmatin with spnsrs f an event (except in circumstances where it is apprpriate t gain yur cnsent); filming, phtgraphing r therwise recrding Events and publishing such cntent n ur website, scial media accunts and ther frmats where it wuld nt be necessary, apprpriate r practicable t btain yur specific cnsent (fr example, we may seek specific cnsent fr prminent r impactful uses, but typically nt fr grup shts, backgrund inclusin r internal use); analysing and imprving the use f ur website; using digital tls t mnitr the impact f ur marketing cmmunicatins (such as using email tracking t recrd when an email we send yu has been pened); analysing wh is attending ur Events, including s that we can mnitr the success f ur utreach prgrams and understand trends in participatin (fr example, by mnitring participatin by sci-ecnmic grup); infrming ur Advancement activities (please find a link t the Advancement team s privacy ntice - http://www.imperial.ac.uk/advancement/abut-us/advancementplicies/privacy-plicy/ ); 3 4137-9973-2755.1

prcessing feedback t imprve the quality f ur Events and marketing activities; marketing the Cllege and its Events by pst, telephne, scial media and electrnic mail (but withut prejudice t yur rights under the legislatin that regulates the sending f marketing cmmunicatins by electrnic means); defining and targeting new audiences (fr example, we use the persnal data f Event attendees t create a surce audience fr nline tls such as Facebk Lkalike Audiences which identifies new target audiences fr receiving ur Event advertising); and cnsulting ur prfessinal advisers where it is necessary fr us t btain their advice r assistance; In additin t thse rganisatins named abve, we will als share yur persnal data with: ur agents and cntractrs where they require yur persnal data t perfrm the services utlined abve; and direct mail agencies wh assist the Cllege in the administratin f marketing cmmunicatins. Legal bligatins Yur persnal data will be prcessed fr cmpliance with the Cllege's legal bligatins. Fr example: fr the detectin and preventin f crime and t assist the plice and ther cmpetent authrities with investigatins; t cmply with tax legislatin, safeguarding duties and subject access requests f thers. In this respect, as well as the rganisatins mentined abve, we may in specific circumstances need t share yur persnal data with third parties wh have made legitimate requests under data prtectin r freedm f infrmatin law; the plice and ther law enfrcement agencies; HMRC and the Cllege s external auditrs. Where yu have cnsented Yur persnal data will als be prcessed by the Cllege where we have yur cnsent. Examples where cnsent wuld be sught include where the law r sme ther prtcl requires that the Cllege btains yur cnsent (fr certain marketing r fundraising cmmunicatins) r where, having balanced the Cllege s legitimate interests against yur rights, interests and expectatins, we feel it is apprpriate t btain yur cnsent fr ur prcessing, rather than rely n the legitimate interests basis. Where applicable, cnsent will always be specific and infrmed n yur part, and the cnsequences f cnsenting r nt, r f withdrawing cnsent, will be made clear. Special categries f persnal data 4 4137-9973-2755.1

In additin t the abve, Cllege may prcess types f persnal data that the law cnsiders t fall int a special categry (such as race, religin, health, sexual life r criminal recrd). This will be under the fllwing circumstances: where yu have prvided yur explicit cnsent. Examples might include where yu have prvided infrmatin n yur dietary requirements, allergies r where yu infrm us f the requirement fr wheelchair access; where such prcessing is necessary fr the establishment, exercise r defence f legal claims (including sharing with the Cllege's insurers and legal advisers) r the preventin r detectin f crime (fr example, detecting criminal actins thrugh the use f CCTV r reprting allegatins t the plice); where it is in yur vital interests t d s and yu are incapable f giving cnsent, fr example t infrm yur specified emergency cntact, the NHS r emergency services in the event f yur illness r ther emergency. Internatinal transfers f data The Cllege will in limited circumstances disclse persnal data t third parties, r allw persnal data t be stred r handled, in cuntries utside the Eurpean Ecnmic Area. Fr example, we will transfer data t IT and ticketing/sign-up platfrm prviders based verseas (such as MailChimp, Ggle and EventBrite) and share infrmatin with internatinal crganisers f an Event. In these circumstances, yur persnal data will nly be transferred where the transfer is subject t ne r mre f the "apprpriate safeguards" fr internatinal transfers prescribed by applicable law, such as: an apprved certificatin mechanism such as Privacy Shield; where the Cllege has entered int cntractual clauses apprved by the Eurpean Cmmissin that prvide apprpriate safeguards; r there exists anther situatin where the transfer is permitted under applicable law (fr example, where we have yur explicit cnsent). Prfiling We may use persnal characteristics such as age, rle, yur expressed interests, yur previus interactins with the Cllege r gegraphical lcatin t target ur cmmunicatins, and advertising and prmtins s that they are relevant t yu. We may als use yur persnal characteristics (such as thse cntained within yur Facebk prfile) t assist us in identifying and targeting new audiences fr ur Events, including thrugh nline behaviural advertising (fr example, thrugh tls such as Facebk Lkalike Audiences). Yur rights under the Data Prtectin Legislatin Prir t 25 May 2018, yu have the fllwing rights: t btain access t, and cpies f, the persnal data we hld abut yu. Further infrmatin f hw t make such an applicatin can be fund at http://www.imperial.ac.uk/admin-services/legal-services-ffice/dataprtectin/subject-access-requests/ ; 5 4137-9973-2755.1

t require that we cease prcessing yur persnal data if the prcessing is causing yu damage r distress; t require us nt t send yu marketing cmmunicatins. Once GDPR cmes int frce, frm 25 May 2018 yu will als have the fllwing additinal rights: t request that we erase yur persnal data; t request that we restrict ur data prcessing activities in relatin t yur persnal data; t receive frm us the persnal data we hld abut yu, which yu have prvided t us, in a reasnable frmat specified by yu, including fr the purpse f transmitting that persnal data t anther data cntrller; and t require us t crrect the persnal data we hld abut yu if it is incrrect. Please nte that the abve rights are nt abslute, and requests may be refused where exceptins apply. If yu have any questins abut these rights r hw yur persnal data is used by us, yu shuld cntact the Data Prtectin Officer using the details belw: Pst Data Prtectin Officer Address - Level 4 Faculty Building, Imperial Cllege Lndn, Suth Kensingtn, Lndn, SW7 2AZ Email dp@imperial.ac.uk Telephne 020 7594 3502 If yu are nt satisfied with hw yur persnal data is used by the Cllege yu can make a cmplaint t the Infrmatin Cmmissiner (www.ic.rg.uk). Hw lng is my persnal infrmatin retained fr? Yur data is held in accrdance with the Cllege s Retentin Schedule available at http://www.imperial.ac.uk/media/imperial-cllege/administratin-and-supprtservices/recrds-and-archives/public/retentinschedule.pdf. In additin, we hld infrmatin n participants fr up t three mnths after an Event unless we have a legitimate reasn fr retaining yur infrmatin fr lnger; fr example, where yu have requested t receive further infrmatin frm us and t keep yu infrmed abut future Events. Dcument last updated n 12 June 2018 6 4137-9973-2755.1