Last updated: 8th June 2022
ABOUT THIS NOTICE
This privacy notice explains how the Institute of Contemporary Performance (“ICMP”, "we", "our", "us") collects, uses, and shares your personal data, specifically your data regarding the use of the Student Wellbeing Team. This privacy notice concerns our processing of personal data of people who interact with ICMP ("you", "your").
This privacy notice should be read in conjunction with ICMP’s Student Information Privacy Notice.
ICMP is the data controller of your personal data and is subject to the UK’s General Data Protection Regulation 2021 (UK GDPR 2021).
HOW WE COLLECT YOUR INFORMATION
Personal data and special category data held by the Student Wellbeing Team relating to students is obtained directly from the student or applicant, or in some cases from a third party organisation involved in the services provided by ICMP (e.g. UCAS, bodies which award funding or loans such as the Student Loans Company (DSA Applications), the National Health Service, Needs Assessor Reports, Diagnostic Reports).
THE TYPES OF INFORMATION WE COLLECT
We will collect the following types of personal data about you:
- Personal details
- Family and social circumstances
- Education and training records
- Employment information, and
- Financial details
We will collect the following types of special category personal data about you:
- Disability data, whether regarding physical, mental or specific learning difficulty
We will ensure that all personal data you supply is held in accordance with the UK GDPR. We do not sell or otherwise transfer this personal data to any third parties unless this is permitted by law.
HOW WE USE YOUR INFORMATION
The Student Wellbeing Team will use personal data, including special category data, to administer your support, deliver services, and meet statutory obligations including:
- provision of support to assist your academic, physical, mental, emotional and/or financial wellbeing, this support may include:
- providing student support via Student Support;
- reasonable adjustments as required by the Equality Act 2010 in relation to your academic course, and its assessment (including examinations);
- maintenance of student records in relation to updating disability information;
- financial assessments (e.g. hardship funds):
- safeguarding and promoting student welfare;
- monitoring equality of opportunity and eliminating unlawful discrimination;
- ensuring safety and security;
- financial administration (e.g. student hardship, etc.).
We may also use your data for other administrative purposes, for example:
- to undertake statistical analysis
- carry out compliance audits
- promote services
- to detect or prevent crime and
- deal with grievances, disciplinary action, complaints or enquiries
ICMP has a statutory obligation to report data on its activities to the Higher Education Statistics Agency. Data about you will be supplied to HESA for the purposes set out in the HESA Collection Notices.
For this purpose, your student record is updated with information about disability, long term health conditions and specific learning difficulties if this information is disclosed.
THE LEGAL BASIS FOR PROCESSING YOUR DATA
The legal condition which enables ICMP to process personal information is found in Article 6 of the General Data Protection Regulation (GDPR). In particular we rely on:
- Article 6(1)(a) consent
- Article 6(1)(d) vital interests
Where special categories of data are processed we will have your explicit consent or another legal reason within Article 9(2) of GDPR will apply.
We will process your disability personal data for the performance of a legal obligation specified in the Equalities Act 2010, forming part of the social protection legislation with which ICMP is obliged to comply.
HOW WE STORE AND PROTECT YOUR INFORMATION
Your personal information is protected by us in a number of ways.
It is stored on computer systems that have been tested to make sure they are secure, and which are kept up-to-date to protect them from viruses and hacking. Where we share your personal information with other organisations, we only ever do so via secure computer systems or encrypted email.
We store your personal information in the UK only
For purposes referred to in this privacy notice we may share your personal data with certain third parties. Students are given the opportunity to opt-out of some data sharing arrangements, but we encourage students to think carefully about the impact of doing so. Where an opt-out is not in place, we will disclose relevant personal data to third parties as noted below.
ICMP may disclose a student’s personal data and special category data to external agencies to which it has a legal obligation; for example: the Student Loans Company, Office of the Independent Adjudicator for Higher Education, Research Councils and, potentially, other such organisations for defined purposes. It may also disclose information to legal representatives, Police or security agencies, suppliers or service providers engaged by ICMP, and regulatory authorities.
All Student Support Services will share data with:
- our employees, partners, agents and contractors, where there is a legitimate reason for receiving information (e.g. departmental staff, providers of student accommodation, software providers, auditors, etc.);
- government departments or agencies where ICMP has a statutory obligation to provide information (e.g. the Office for Students (OfS), the Higher Education Statistics Agency (HESA);
- agencies involved in the prevention and detection of crime (e.g. the Police);
- parents, guardians and next of kin (where there is a legitimate reason for disclosure).
Your information used by us can only be seen by staff who have been specifically trained to protect your privacy.
No information that could identify you will ever be published by us.
HOW LONG YOUR INFORMATION IS KEPT
Details of how long your data is held are available in ICMP’s Retention Schedule
Under the UK GDPR you have the following rights:
- to obtain access to, and copies of, the personal data that we hold about you;
- to require that we cease processing your personal data if the processing is causing you damage or distress;
- to require us not to send you marketing communications.
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us to erase your personal data;
- to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
- to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
If you have any queries about this privacy notice, how we process your personal data or to request access to the personal data that we hold about you, you can contact our Data Protection Officer by email: firstname.lastname@example.org; by telephone: +44 020 8328 0222 or by post: Data Protection Officer, ICMP, 1B Dyne Road, Kilburn, London NW6 7XG.
If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner.
You can find out more about your rights under data protection legislation from the Information Commissioner's Office website available at: www.ico.org.uk.
If you would like more details about how we use and store your personal data, you can view our Data Protection policies on our Policies Page.