It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Student Cribs Limited, a company registered in England and Wales under company registration number 07247566. Our registered office is at St Albans House, 57-59 Haymarket, Haymarket, London SW1Y 4QX|
|Personal data||Any information relating to an identified or identifiable individual|
|Special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; Data concerning health, sex life or sexual orientation|
|Data subject, you, your||The individual who the personal data relates to (i.e. you)|
Personal data we collect about you
We may collect and use the following personal data about you:
- your name and contact information, including email address and telephone number and company details;
- information to check and verify your identity, e.g. your date of birth;
- your gender;
- location data;
- your billing information, transaction and payment card information
- your personal interests;
- your contact history, including regarding property enquiries and/or lettings;
- information from accounts you link to us, e.g. Facebook;
- information to enable us to undertake credit or other financial checks on you;
- information about how you use our website, IT, communication and other systems; or
- your responses to surveys, competitions and promotions;
We collect and use this personal data to provide products and/or services to you.
If you do not provide personal data we ask for, it may delay or prevent us from providing products and/or services to you. For example we may not be able to let property to you, and indeed we would not be able to (among other things):
- liaise with you in order to arrange for maintenance at any property you let from us; or
- collect rent payment from you
which may ultimately result in you being in breach of your tenancy agreement and therefore potentially resulting in your lease ending prematurely. Indeed you will not be able to sign up to view a property or to a tenancy without agreeing to us processing your personal data in accordance with this policy.
How your personal data is collected
We collect most of this personal data directly from you in person, by telephone, text, email and/or via our website. This may include (among others) when you fill out a registration form to view a property or to become a tenant, or where you enter into a competition or promotion.
However, we may also collect information about you:
- directly from a third party, e.g.:
- credit reference agencies;
- customer due diligence providers;
- previous landlords; and/or
- guarantors for your and your co-tenants’ rent;
- from a third party with your consent, e.g. your bank or building society;
- via our IT systems, e.g.:
- from door entry systems and reception logs;
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
|What we use your personal data for||Our reasons|
|Providing products and/or services to you||To perform our contract with you or to take steps at your request before entering into a contract|
|Preventing and detecting fraud against you or us||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us|
|Preventing misuse of our property||For our legitimate interests or those of a third party, i.e. to stop the property being damaged or used to the detriment of other tenants and/or neighbours|
|Conducting checks to identify our customers and/or their guarantors and to verify their identity.|
Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law
|To comply with our legal and regulatory obligations, including to provide information to local councils for the provision of electoral roll services|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and fair usage of utilities/services provided to a tenant’s property||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price|
|Statistical analysis to help us manage our business, e.g. in relation to our customer base, product range/offering or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us To comply with our legal and regulatory obligations|
|Updating and enhancing customer records||To perform our contract with you or to take steps at your request before entering into a contract.|
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing lettings and new products and offerings
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations.|
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services and those of selected third parties to: |
– existing and former customers;
– third parties who have previously expressed an interest in our services;
– third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services|
|External audits and quality checks, e.g. for ISO, Investors in People, or National Residential Landlords Association (NRLA), Accreditation Network UK (ANUK) accreditation and the audit of our accounts||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards, |
To comply with our legal and regulatory obligations
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise, or defend legal claims.
We may use your personal data to send you updates (by email, text message, telephone or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at [email protected]; or
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you ask us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
- companies within our group;
- third parties we use to help deliver our products AND/OR services to you, e.g. (among others) payment service providers, maintenance workers/handymen, IT providers, and delivery companies;
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
- credit reference agencies;
- our insurers and brokers; or
- our banks.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
- share your personal data with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts;
- share your personal data with debt collection agencies where tenants and/or guarantors have failed to pay what is due under to us;
- share personal data with guarantors;
- disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations, including your personal data;
- share some of your personal data with other parties, such as potential buyers of some or all of our business or during a restructuring – usually, information will be anonymised but this may not always be possible; however the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK and all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’). For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will keep your personal data while you have an account with us or we are providing products AND/OR services to you. Thereafter, we will keep your personal data for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not keep your personal data for longer than necessary.
When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Transferring your personal data out of the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA, e.g.:
- with your and our service providers located outside the UK/EEA;
- if you are based outside the UK/EEA.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where;
- the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law.
These are explained below.
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:
- the EEA;
- Gibraltar; and
- Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained in the following section (‘Transfers with appropriate safeguards’).
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
- the transfer is necessary to establish, exercise or defend legal claims.
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|Erasure (also known as the right to be forgotten)||The right to require us to delete your personal data in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations|
|To object||The right to object: |
– at any time to your personal data being processed for direct marketing (including profiling);
– in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
- email, call or write to us – see below: ‘How to contact us’; and
- provide enough information to identify yourself (e.g. your full name, address and where appropriate the details of any property you have viewed and let) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
How to contact us
Individuals in the UK
Our contact details are shown below:
Email: [email protected]
Head Office telephone: 02037587000
Address: St Albans House, 57-59 Haymarket, Haymarket, London SW1Y 4QX