Privacy Notice

The FutureLets Limited Privacy Notice

 

Who are we?

In this Privacy Notice, the terms “we“, “our“, and “us” refer to The FutureLets Limited (Company Number 09136328), Alan Berry Building, Coventry University, Priory Street
Coventry, United Kingdom CV1 5FB (ICO registration number ZA118788) (“FutureLets“). The FutureLets is a wholly-owned subsidiary of Coventry University Higher Education Corporation. You can find the full details of the Group structure here.

As a controller of your personal data we are responsible for looking after it, and we will use it fairly, lawfully, and in a transparent manner.

Purpose

We are committed to protecting your privacy. This notice will help you understand how we look after, use, store and share your personal data, and how we meet our obligations under the General Data Protection Regulation 2016 and the Data Protection Act 2018 (Data Protection Laws). It supplements any other notices or statements we may provide to you.

What personal data do we collect?

“Personal data” is any information from which you can be identified, e.g. name, date of birth, contact details, identification numbers, photographs, and expressions of opinion about you.

The type of personal data we collect, and how we process it, can vary depending on your interactions with us.

Where applicable, we will collect:

 

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, university ID number.
• Contact Data includes address (home, postal or other physical address), email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Health and Wellbeing Data includes details of any disability or medical information disclosed by you in relation to your accommodation needs.
• Preference Data includes information you provide in relation to your accommodation preferences and interests.

Personal data does not include data where your identity has been removed or which is not associated with or linked to your personal data (anonymous data). 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but as this data does not directly or indirectly reveal your identity, it is not considered personal data in law. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Special Category Data

We may process your ‘special category data’ such as:

• racial or ethnic origin;
• religion;
• political views;
• trade union membership;
• genetics and biometrics (where used for ID purposes);
• health and disabilities; and
• sex life and sexual orientation.

 

We will only process this special category data where you have given your explicit consent for us to do so or when that processing is legally required.

Where do we get your personal data from?

We collect your personal data directly from you; during your visits to our website; if you attend our events; or through any other communication you have with us.

Except for your IP address data, when visiting our website we will only collect personal data when it is voluntarily submitted.

We also may obtain some personal data from other third parties.

Information that you give us

You may share personal data about yourself and your circumstances by:

• providing information as part of your online application process to us;
• completing hard copy application forms;
• verbally providing information to us, either by telephone or face to face;
• giving us information about yourself in any other communications with us either by e-mail, post or otherwise.

We need you to provide the personal data listed above so that we can consider your application, and so that we can comply with our legal and contractual obligations to you.

If you are unable to provide this personal data, it may mean that we will be unable to process your application for accommodation or provide other services which you have requested.  If this is the case we will notify you at the time.

Information that we collect about you

• details of your visits to our website including, but not limited to, Internet Protocol (IP) address used to connect your computer to the internet, MAC addresses, traffic data, location data, your login information, time-zone setting browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access. For more information please see our Cookie Notice;
• data including your name and images captured on body-worn cameras or CCTV, when you are on our premises or at a Coventry University campus;
• as part of the events organised at Coventry University and the associated buildings as necessary for our legitimate interests, third party photographers may be on site. If you do not wish to be included in any photographs or live streamed events (such as graduation ceremonies which are recorded and available online), please ensure that you clearly express your wishes to a member of our staff or directly to the third parties.

Information that we receive from other sources

We may receive personal data about you from other third parties, including:

• letting agents or referees, where we require a reference;
• your parents, guardians or any other third parties who send us personal data on your behalf;
• other members of the  Coventry University Group.

Please note that we may combine all personal data that we collect about you, i.e. data we receive from other sources, data you give to us and data we collect.

Why do we need personal data and how do we use it?

• Applications for accommodation – we will process personal data including Identity and Contact Data provided in an application for accommodation so that we can process that application, as necessary for the purposes of our legitimate interests and in order to take steps prior to entering into a tenancy agreement.
• Administration of accommodation – we will process personal data including Identity, Contact, Health and Wellbeing Data, Preference Data and Financial Data for the purpose of providing you with accommodation in accordance with our tenancy agreement, including processing of your payments for rent and providing suitable and appropriate accommodation in line with individual needs.
• References – we may also receive personal data about you from letting agents where we require a reference, or from your referees where you have provided us with their contact details for the purpose of obtaining a reference.
• Via Contact Us – we will use your Identity and Contact Data to respond to you regarding the reason you contacted us, i.e. in respect of Coventry University accommodation.
• For advertising, marketing and public relations – we may use your Identity, Contact, Technical, Usage and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you and, in doing so, we will only send you information that is deemed relevant to your use of our services.
• For website administration – as you navigate our website, Technical and Usage Data may be collected automatically. We do this to find out information such as the number of visitors to the various parts of the website, and to help us to improve the content of the website and to customise its content or layout for you, as necessary for the purposes of our legitimate interests. We collect this information in a way which does not identify you and we do not make any attempt to find out the identities of those visiting our website.
• For fault reporting – if you contact us to report a fault with our website, we will use the Identity and Contact Data provided for the purposes of rectifying that fault as necessary for the purposes of our legitimate interests.
• For recruitment – personal data including Identity and Contact Data provided for an employment opportunity with The FutureLets will be processed so as to allow us to process and evaluate the merits of that application as necessary for the purposes of our legitimate interests.
• For the purpose of providing you with a unique key code, which allows you access to the property you are renting. We keep a key log system, which we use:

 

• for maintenance (such as changing batteries),
• to provide you with your code if you fail to remember it,
• to monitor our locks and ensure that incorrect codes are not being entered repeatedly,
• to monitor use of key codes in the event of vandalism or other incidents.

 

This system is not used to monitor tenants and we do not check anyone in particular, however, if any incidents occur, we may check which codes have been used and who they belong to, and this data will be processed in line with our legitimate interests to provide a safe and secure environment to our tenants.

 

• If you submit a Freedom of Information Request or a Data Subject Access Request we will keep a record of that correspondence so as to deal with and/or respond to your request. We need information from you to respond to you and to locate the information you are looking for. This enables us to comply with our legal obligations under the legislation we are subject to. When we receive a request from you, we’ll set up an electronic case file containing the details of your request. This normally includes your contact details and any other information you have given us. We’ll also store, on this case file, a copy of the information that falls within the scope of your request in order to maintain adequate records of information we have made public and/or released to you.
• If you report a data breach we will set up an electronic case file containing the details of the breach and we will keep a record of our correspondence with you. We need information from you to contain and mitigate the risk. This enables us to comply with our legal obligations under the legislation we are subject to.

Legal Claims

Personal data, including special category data, may be processed for the purpose of establishing, exercising or defending a legal claim.

Basis for using your personal data

We need a legal basis for any processing of personal data. This means that our processing must be for one of a limited number of reasons set out in the data protection laws. The legal bases that we rely on are:

The processing is necessary for the entry into or performance of a contract

When we provide our services to you, we enter into a contract with you. For us to deal with any enquiry or request made by you prior to entering into a contract, and to fulfil our obligations under it, we will need to collect, process and share (as further detailed below) your personal data. Please note that we may not be able to enter into a contract with you or provide the services under it if you: do not provide us with the personal data required; object to the type of processing we need to do; or exercise your right to have your personal data deleted.

Compliance with a legal obligation

Sometimes we process your personal data because we are legally obliged to do so, for example in some of the circumstances listed above, to demonstrate compliance with Home Office regulations, or because we may be required to share your personal data with certain statutory bodies.

Legitimate interests

We may use your personal data (excluding special category data) as set out in this Privacy Notice for the legitimate interests of our business including:

• ensuring the quality of the services we provide;
• ascertaining your (or your guarantor’s) financial status;
• enabling us to engage utility companies and contractors associated with the application, management and performance of your tenancy agreement;
• ensuring student engagement and a safe and supportive learning environment.

We will always balance our legitimate interests in processing your personal data against your privacy rights.

Legitimate interest

We have a legitimate interest in processing your personal data as:

• you benefit from the provision of the services we provide;
• we both benefit from the ability to enforce or apply rights under any contract between us;
• we need to assess your ability to pay, and your reliability as a tenant; and
• we need to ensure our properties are appropriately maintained, and that services are connected and appropriately charged.

Necessity

the processing is necessary for the purposes outlined in this Privacy Notice.

Impact of processing

such processing does not unreasonably intrude on your privacy.

Vital interest

We consider it reasonable to process personal data for the protection of any interests that are essential for someone’s life

Consent

Generally, we do not rely on consent as a legal basis for processing your personal data other than for sending third party direct digital marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

Where we wish to use your image in promotional videos and photographs, we will first obtain your consent.

If we require your consent to process your personal data in any other circumstances, we will contact you separately to request this.

Processing of your personal data

“Processing” means doing anything with the personal data, such as collecting, recording, organising, structuring, storing, adapting or altering, retrieving, accessing, consulting, disclosing, disseminating, aligning or combining, restricting, erasing or destroying or using the data in any way.

We will process your personal data for the purposes set out above, or as we otherwise notify you.

The personal data you provide will be subject to security measures and procedures to minimise the risk of unauthorised access, loss, theft or disclosure.

Your personal data will not be used for the purposes of automated decision making.

How long do we keep your personal data for?

We will only keep your personal data for as long as we need to in order to fulfil the purposes for collecting it, including satisfying any legal, accounting, or reporting requirements.

We consider a number of factors in deciding how long to keep your data: the amount, its nature and sensitivity, the potential risk of harm from unauthorised use or disclosure; the purposes for processing it, and whether we can achieve those purposes through other means; and the applicable legal requirements.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.

Who do we share your personal data with?

Your personal data will be disclosed to relevant FutureLets employees that have a need for such access for the purpose for which it was collected and will not be disclosed to any other individuals or other entities, except that, if consistent with the purposes for which it is collected, your personal data may also be shared with other organisations within the Coventry University Group. We may also need to share your personal data with third parties in the following circumstances:

• as we are required by law to place your deposit in a tenancy deposit protection scheme and, in doing so, we will need to share relevant personal data with our scheme provider, The Deposit Protection Service (see depositprotection.com);
• on occasions, we need to hire other companies to help us to serve you better and, in some of these cases, we may need to share personal data that is necessary to perform tasks for us, namely to utility companies (as necessary for our legitimate interest in ensuring that utility charges are directed to those responsible), and contractors associated with the application, management and performance of your tenancy agreement and as otherwise set out in your tenancy agreement. Guidance on how a tenant’s personal data may or may not be used is published on the ICO website at page: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/consent/when-is-consent-appropriate/;
• similarly, we may need to share landlord’s personal data with utility companies (as necessary for our legitimate interest in ensuring that post contract utility charges are directed to those responsible);
• where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any agreements that may be entered into between us;
• where it is necessary in our legitimate interests to share your personal data with credit agencies to ascertain the financial status of you and/or your guarantor;
• the police and other crime and fraud prevention and detection agencies for crime prevention or detection purposes;
• statutory bodies, including HMRC and local councils and electoral authorities, where we are under a legal obligation to do so;
• in order to protect the rights, property or safety of The FutureLets, our employees, tenants and others.

We may engage third parties to provide processing activities where it is necessary for our legitimate interests to do so (including processing for administrative and practical purposes).  We require that all third parties who process personal data on our behalf to treat it in accordance with the Data Protection Laws. We do not allow our third-party service providers to use your personal data for their own purposes, but only to process it for specified purposes, and in accordance with our instructions. Such processing is to be conducted under a formal agreement, which includes provisions around the processing of personal data and which provides appropriate safeguards.

We will seek your express opt-in consent before we share your personal data with any company outside of FutureLets for marketing purposes, or before we send you relevant third party information on behalf of any third party.

Keeping your personal data secure 

We are committed to the protection and security of your personal data. We will ensure that appropriate measures are taken against its unlawful or unauthorised processing, and against its accidental loss or damage.

Transfers of your personal data to third countries

Your personal data will be held and processed on computers and in hard copy within the UK and we will not transfer any of your personal data outside of the European Economic Area. As the UK has left the EEA, and where otherwise required, we ensure that appropriate transfer mechanisms to and from the UK are put in place.

Please contact us if you want further information on the specific mechanism we use when transferring your personal data out of UK and other countries outside of the EEA.

We keep our mechanisms for transferring personal data outside of the UK and/or the EEA under regular review to ensure that these are in line with UK data protection laws.

How we may contact you

Please note that we may contact you in connection with the purposes set out above, by post or by electronic means (including telephone, text messages, email, social media messaging, or any other suitable electronic method).

Your Data Protection Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data that we hold about you, and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new personal data.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data if:

• there is no good reason for us continue processing it;
• you have successfully exercised your right to object to processing (see below);
• you believe we may have processed your personal data unlawfully; or
• we are required to erase your personal data to comply with the law.

Please note that we may not be able to comply with your request for specific legal reasons which, if applicable, will be notified to you.

Object to processing of your personal data when we are relying on public task or a legitimate interest (or those of a third party), and you feel that this processing impacts on your fundamental rights and freedoms. However, these may be overridden by the public interest or our legitimate interest grounds.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the accuracy of the data;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it (for example if you need it to establish, exercise or defend legal claims); or
• If you have objected to our use of your data, but we need to verify whether we have overriding public interest or legitimate interest grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated data that you initially provided consent for us to use, or where we used the data to perform a contract with you.

Withdraw consent at any time when we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” (or similar) links on any marketing message sent to you, or by contacting us at any time.

When you opt out of receiving these marketing messages you will no longer hear from us in that regard.

Exercising your rights

If you wish to exercise any of your above rights, please send a written request to the Information Governance Unit, Coventry University, Portal House, 163 New Union Street, Coventry, CV1 2PL, or email dsar@coventry.ac.uk.

You will not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.

We may need to confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information, in order to speed up our response.

We try to respond to all legitimate requests within one month, although it may take us longer if your request is particularly complex, or if you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints and questions

We have appointed a Data Protection Officer to oversee compliance with this Privacy Notice. If you have any concerns of complaints about it, please contact the Data Protection Officer at Coventry University, Priory Street, Coventry CV1 5FB or email dpo@coventry.ac.uk.

If you are not satisfied with the proposed resolution of your complaint, you have the right to contact the Information Commissioner’s Office. Further information can be found on the Information Commissioner’s website at www.ico.org.uk or via their helpline on 0303 123 1113.

We reserve the right to update this Privacy Notice at any time.  Any updated versions will be made available on our website.

Feedback

If you have feedback for us about this privacy notice, please let us know by emailing enquiry.igu@coventry.ac.uk.