At Britannia Student Services, we collect different types of information about our customers, whether corporate partners or direct students, for five main reasons:
- To provide accommodation and related services to students.
- To help us to monitor and improve the accommodation and services we offer.
- To keep customers up-to-date about accommodation and services they have purchased.
- To fulfil contracted accommodation and service agreements.
- If we have permission from the user, to market products and services to them.
- The protection of your privacy and personal information is important to us. We make sure that not only do we have appropriate security measures in place, but that any other organisation we work with to provide a service also meets the same standard as us.
- We will respect your privacy. You should receive marketing emails only from us. We will make sure the boxes you need to tick if you are happy to receive promotional communications are presented clearly and at an appropriate time.
- We will make it clear at the point when we request your information, what we are collecting it for and how we are going to use it.
- We will collect and use your personal information only if we have your permission or we have sensible business reasons for doing so, such as collecting enough information to provide accommodation within government regulations, e.g. HMO, Right To Rent.
- We will minimise the amount of information we collect from you to what we need to deliver the accommodation and services you have requested.
- We will use personal information only for the purposes for which it was originally collected and we will make sure we delete it securely.
- Our websites are accessible via the internet. Please remember, if you post any comments or links on any of our sites, they can be read and accessed by anyone and everyone.
- If we, our service providers or our commercial partners transfer any information out of the European Economic Area (EEA), it will only be done with the relevant legal permissions being in place.
What information do we collect about you and how do we use it?
You may provide personal information when communicating with us, e.g. accommodation enquiry or if you contact us with a query or complaint. You may purchase accommodation and provide your name, e-mail address, home/business address, telephone number, bank account details, etc, so the order can be processed and your accommodation/services can be delivered to you.
If you enter a competition or promotion we will ask for your name, address and e-mail address and any other relevant information.
We will collect information about your tastes and preferences when you tell us what these are. It may be that some of the personal information you give us, e.g. about your health, is sensitive personal data within the meaning of GDPR. Any such information (“sensitive information”) will only be collected by us with your express consent. It may be that you provide to us details of bank accounts in order to make payments to us or receive refunds. Any such information (“confidential financial information”) will be used only for the specific purpose for which it is provided.
Essentially, we collect information on you:
- when you contact us for information;
- when you work with us in a commercial capacity;
- when you sign-up for a sales promotion, event or competition;
- when you sign up for a newsletter;
- when you use the website;
- through cookies;
- if you choose to reveal information in postings; and
- if you complete your details on research questionnaires.
Certain services we provide may involve us collecting extra information (your location or preferred language, for example), so we can tailor our accommodation provision and services better. This may also apply to apps we provide.
What legal bases do we use for processing your data?
We use different legal bases depending upon the purpose for collecting your data in the first instance.
- For all data collected to sign up for further information on accommodation and services, we process the data using Legitimate Interest, i.e. you are able to access a range of information in exchange for supplying your information, and we have a relationship where the balance of benefit is in your favour. You always have a choice in the management of your data in this manner and can opt out of processing under this basis at any time.
- Where you provide data in the course of the purchase of accommodation, we process your data under Contract, i.e. your data is necessary for the fulfilment of the service. Any additional contact, i.e. telling you about other accommodation options or related services to that previously purchased is managed under legitimate interest.
- Any secondary processing of your data, i.e. sharing with third parties, sending you messages on behalf of third parties, transfer to third countries, is managed under Consent.
Under the terms of current data protection legislation, we will always make it as easy as possible for you to opt out of unwanted processing, provided it does not restrict our ability to provide you with the accommodation or service you have requested.
From time to time, we may use some elements of the data you supply to target the messages we send you. For example, we may use your location to send you information about an event which is happening in the same country, or we may use your company type to send you relevant accommodation information.
None of this information is collated by wholly automated means and the rights and freedoms of the data subject are safeguarded by suitable measures.
How long do we retain your data?
Because we collect data for a wide range of purposes, we do not have a singularly defined retention period. For each individual product and service, we define a carefully assessed timeframe within which we retain your data.
After this, data is managed to ensure it is either erased from our system, minimised and retained for legal reasons or pseudonymised and retained on a global suppression list to ensure you do not receive unwanted messaging from us.
Other uses of your data
We do not sell your data at any time. We may share your personal information with third parties in the following ways:
- where we have a legal or regulatory obligation to do so – this will include sharing your personal information with local councils for the provision of electoral roll services;
- where we use third party suppliers to provide services to us, e.g. airport transfers, and they need access to your personal information in order to deliver that service;
- where it is necessary to do so to protect or defend our legal rights or the legal rights of others;
- if you are accommodated and you fail to pay your rent, we may contact your school, agent or guarantor and inform them of this failure when exercising our rights under the guarantee;
- if we sell a property we will transfer information relating to tenants and guarantors to the new owner.
We may provide aggregated statistics about our sales, customers, traffic patterns and other site information to third parties, but these will not include any information that could personally identify you.
Any organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to ensure they protect your information and keep to the data protection and privacy laws which apply. We may also independently audit these service providers to ensure they meet our standards. We may use service providers to help us run these sites (or services on the sites), some of whom may be based outside the EEA or countries deemed adequate by the EDPB.
Use of children’s data
We only collect or store any personal information about children under the age of 18 in the context of provision of accommodation and safeguarding. This is applicable to young people aged less than 13 years where permission is obtained directly from a legal adult guardian by the third party school or agent placing them in our accommodation.
Updating your personal information
Under current data privacy legislation, you have the right to rectify, erase or restrict the processing of your data without undue delay. You may also request access to the data we hold on you. To do this or to update your personal information at any time please contact our Database Manager, Rob Grant, by email on email@example.com or telephone on +44 (0)20 7436 7738.
A cookie is a piece of information stored on your computer’s hard drive by your web browser or stored as a temporary object in your web browser for the time of that connection.
During the online enquiry process, we allocate cookies for our services. These cookies will hold information collected during the enquiry process which allow us to recognise you as a web visitor and provide you with the services you require. The type of cookie we use is known as a ‘session-based’ cookie and is allocated to your computer only for the duration of your visit to our web site.
The second type of cookie is known as a ‘persistent’ cookie. These cookies will remain on your computer for a period of time set for each cookie. They are used for statistical purposes, to track how many users we have and how often they visit our websites. We collect information listing which of our pages are most frequently visited, and by which types of users and from which countries.
How you can refuse or opt out of cookies: Most browsers are set by default to automatically accept cookies, but you can usually alter the settings of your browser to prevent this and prompt you every time a cookie is sent to you or allow you to choose not to receive cookies at all. For further information on cookies and how to manage them, go to www.allaboutcookies.org
We use Google Analytics on our sites for anonymous reporting of site usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link: https://tools.google.com/dlpage/gaoptout
Sometimes we also use Google AdWords Remarketing and Similar Audiences to advertise on third party
websites (including Google, LinkedIn and Facebook advertising networks) to previous visitors to our site or users with similar interests. It could mean we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry, or users with interests like our previous visitors.
If you want to opt out of receiving online behavioural advertising (OBA), this does not mean you will no longer receive advertising when you are using our sites. It just means the advertising you see will not be customised for you. If you would like more information about OBA and how to opt out of it, please visit youronlinechoices.com
Advertising on mobile devices may require the collection and sharing of the unique device ID with companies who purchase advertising space on the mobile application.
Legal information and how to contact us
Under the currently Applicable Laws we have to say who our ‘data controller’ is for accommodation and services provided via our websites, events and other products and services. The data controller is the organisation responsible for protecting information and, in our case, is Britannia Student Services.
If you would like access to or a copy of the personal information we hold about you, request a correction, or have any questions about how we may use it or to make a complaint, please contact the Database Manager, Rob Grant, by email on firstname.lastname@example.org or telephone on 020 7436 7738. Requests will be dealt with by the Database Manager, and will be responded to within a reasonable period, not longer than 30 days.
If you are not satisfied with the way your request was handled, you have the right to lodge a complaint with the supervisory authority – details of which are:
Information Commissioner’s Office
Tel: +44 (0)303 123 1113