Who are we?
The FutureLets Limited is committed to protecting your privacy. This notice will help you understand how we look after your personal data and how we make sure that we meet our obligations to you under the UK data protection laws (referred to in this notice as the “Data Protection Laws”). This notice outlines how we will use, store and share your personal data, and supplements any other notices or statements we may provide to you.
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.
We are a controller of your information which means that we are responsible for looking after it. We will use your personal data fairly, lawfully and in a transparent manner, and in accordance with the Data Protection Laws.
Personal data we collect about you
The type of personal data we collect about you and how we collect it can vary depending on your interactions with us
“Personal data” means any information we hold about you, from which you can be identified. It may include contact details, identification numbers, other personal information, photographs, expressions of opinion about you or indications as to our intentions about you.
What information do we collect?
We may collect, use, store and transfer different kinds of personal data about you as follows:
- 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 information about you which is classified as ‘special category data’ in the Data Protection Laws, such as details you have supplied to us about your health and any disabilities you may have.
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. For example, when you provide Health and Wellbeing Data, unless we are under a legal obligation to process this information, such information will be only processed with your explicit consent.
Where do we get your personal data from?
We collect some of your information directly from you, either through information that you give to us or information that we collect during your visits to our website or through any other communications you might have with us. We also obtain some information from third parties (please see below for further details). Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.
|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 may need you to provide the personal data listed above so that we can provide the services and support your needs, and so that we can comply with our contractual obligations to you, and our legal obligations.
If you don’t 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||We collect personal data about you:
· when you visit our website as well as 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.
· when you are on our premises or at a Coventry University campus, data including your name and CCTV images.
|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;
· Other members of the Coventry University Group;
· Your parents, guardians or any other third parties who send us personal data on your behalf.
Why do we need your personal data?
There are various reasons that we may need to collect and process your personal data. We may collect and process the personal data about you for the following purposes:
- 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.
- 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.
- 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.
- 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 the content or layout of the website 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.
- 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.
- 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.
Basis for using your personal data
Data Protection Laws state that we need to have a legal basis for all of the processing of your personal data that we carry out. This means that our processing of your information must be for one of a limited number of legal bases set out in the legislation. 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 a contract is entered into between us. For us to deal with and/or respond to any enquiry or request made by you prior to entering into this contract, and fulfil our obligations under this contract, we will need to collect, process and share (as further detailed below) your personal data. If you don’t give us the personal data we need when we ask for it, or if you object to the type of processing we need to do, or if you exercise your right to have your personal data deleted, it is likely to mean that we cannot enter the contract with you or provide the services under it.
Compliance with a legal obligation
Sometimes we process your information because we are legally obliged to do so, for example in some of the circumstances listed above, or in relation to the prevention of crime, or because we may be required to share your information with certain statutory bodies (see below for further information about whom we may share your information with).
We may use your personal data (excluding special categories of personal data) as set out in this privacy notice where this is necessary for the purposes of 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.
As explained further below, we may share your personal data with other members of the Coventry University Group, as well as other third parties where this is necessary for the purposes of our legitimate interests.
We are required to carry out a balancing test of our legitimate interests in using your personal data outlined above against your interests and rights under the Data Protection Laws. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that this is necessary for our legitimate interests.
|Legitimate interest||We have a legitimate interest in processing your information 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;
· we need to ensure our properties are appropriately maintained, and that services are connected and appropriately charged.
|Necessity||We consider that it is reasonable for us to process your personal data as it is necessary for the purposes of our legitimate interests outlined above as we process your personal data only so far as is necessary to achieve the purposes outlined in this Privacy Notice.|
|Impact of processing||We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above, as the processing of your personal data does not unreasonably intrude on your privacy.|
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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 only process your personal data for the purposes set out above or as we otherwise notify you.
The information 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 we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We consider a number of factors in deciding how long to keep your information: the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements (i.e. whether particular laws mean we have to keep certain types of document for a certain length of time).
Details of retention periods for different aspects of your personal data are available by contacting firstname.lastname@example.org.
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 information indefinitely without further notice to you.
Who do we share your personal data with?
Your personal data will only 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, information about you 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:
- 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 information 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/.
- 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 which may be entered into between us.
- Where it is necessary in our legitimate interests to share your personal information with credit agencies to ascertain the financial status of you and/or your guarantor.
- Where we are under a legal duty to do so in order to comply with any legal obligation.
- In order to protect the rights, property or safety of The FutureLets, our employees, tenants and others.
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.
We require all third parties that process personal data on our behalf to respect the security of your personal data and 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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Keeping your personal data secure
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect. In addition, the access to and use of the personal data that we collect is restricted to our employees who need the personal data to perform a specific job role or activity. Where personal data is shared with third parties (e.g. The Deposit Protection Service) in line with this notice, responsible measures are used to protect your personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. We urge you to take every precaution to protect your personal data when you are on the internet.
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. In the event that the UK leaves the EEA, or if otherwise required, we will ensure that appropriate transfer mechanisms to and from the UK are put in place.
Other Websites and Links
The FutureLets’ website may contain links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third party websites and are not responsible for their privacy notices or for the content, accuracy or opinions expressed in such websites.
The FutureLets does not investigate, monitor or check third party websites for accuracy or completeness and the inclusion of any linked website on or through our website does not imply approval or endorsement by The FutureLets of the linked website.
If you decide to leave The FutureLets’ website and access these third party websites, plug-ins and/or applications you do so at your own risk. We encourage you to read the privacy notice of every website you visit.
How we may contact you
Please note that we may contact you by post or by electronic means including telephone, text messages, email, social media messaging, or any other suitable electronic method in connection with the purposes set out above.
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 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 we hold about you corrected, although we may need to verify the accuracy of the new personal data that you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
- 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you and in particular we may not be able to process your application for accommodation. We will advise you if this is the case at the time you withdraw your consent. You can ask us or third parties to stop sending you marketing messages at any time by logging into your website account and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the “unsubscribe” (or similar) links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, product/service experience or other transactions.
Exercising your rights
If you wish to exercise any of your above rights, please send a written request to us at the address listed at the end of this privacy notice.
You will not have to pay a fee to access your personal data (or to exercise any of your other 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 request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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 relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
About this Notice
This privacy notice was last updated on 19 August 2019. Historic versions can be obtained by contacting us.
Complaints and Questions
Coventry University has appointed a Data Protection Officer to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal information, please contact the Data Protection Officer at the Information Governance Unit, Coventry University, Priory Street, Coventry, CV1 5FB or email email@example.com . You can also contact us at firstname.lastname@example.org.
If you are not satisfied with Coventry University’s 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, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.