At IQ Student Accommodation (hereinafter referred to as IQSA Group), we are committed to protecting and respecting your privacy.
Please read this Privacy Notice, together with any other privacy notice that we may provide to you, as it contains important information about how we collect, manage, use and protect your personal data. This Privacy Notice may also be used in conjunction with other privacy notices that we may provide you with in certain situations.
We may change this Privacy Notice from time to time. Please check this policy frequently to ensure you are aware of the most recent version and the date that it was last updated.
This policy was last updated in November 2023.
If you have any questions regarding this policy or about our privacy practices, please contact us on the below details:
· Email: email@example.com
· Post: iQ Student Accommodation, 7th Floor, Cottons Centre, Cottons Lane, London, SE1 2QG (marking your query for the attention of The Data Protection Officer)
Who are we?
IQSA Group is made up different legal entities, details of which can be found here. This list may be updated from time to time.
When we say ‘IQSA’, ‘we’ or ‘us’ in this Privacy Notice, we are referring to the relevant company in the IQSA Group responsible for processing your personal data. This may be your landlord or the company you are visiting, contracting with or applying to or another member of the IQSA Group, including IQSA Services Limited, IQSA Group’s managing agents.
IQSA is a "data controller" of the personal data that you provide to us. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
IQSA Services Limited is the company that manages the properties owned by the IQSA Group. In this role, IQSA Services Limited will process your personal data on behalf of the relevant company within the IQSA Group and also as a data controller for the purposes of managing the IQSA Group’s properties. IQSA Services Limited processes your personal data in accordance with this Privacy Notice. Therefore, when we say ‘we’ or ‘us’ in this Privacy Notice, we are also referring to IQSA Services Limited.
IQSA Services Limited is a company registered in England (Company Number: 09857188) with its registered office at 7th Floor, Cottons Centre, Cottons Lane, London, SE1 2QG.
What information do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect information on residents, applicants, guarantors, employment candidates, visitors to our website or premises and suppliers.
We have grouped together the types of personal data that we may collect, use, store and transfer about you as follows:
· Identity Data including name, gender, date of birth, photographs, marital status, occupation, family members, emergency contact information, driving license, passport information, utility bill, mortgage statement, council tax bill, user name or similar identifier.
· Physical Location Data including CCTV footage and other information obtained through electronic means such as swipe card records or our telephone call recording systems or other information about your use of our premises, including meter readings;
· Contact Data including home address, billing address, business address, email address, phone numbers, geo-location, emergency contact details;
· Course Data including university that you are attending, name of course, length of course, matriculation details;
· Financial Data including bank account and payment card details;
· Transaction Data including details about payments to and from you and other details of products and services that you have purchased from us;
· Technical Data including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and device;
· Usage Data including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us;
· Communications Data including your preferences in receiving communications from us;
· Profile Data including your username and password, preferences, feedback and survey responses;
· Marketing and Communications Data including your preferences in receiving communications from us and third parties.
Special Categories of Personal Data
We may also collect, store and use information about:
· your health, including any medical conditions or disabilities to the extent required for us to make any reasonable adjustments to enable you to access and benefit from the facilities and services we provide and to ensure that you can evacuate the premises safely in the event of an emergency
· your health or wellbeing if disclosed to us during your tenancy either by you or by a others, including other residents, medical professionals or emergency services, or your university.
· medical conditions, injuries or and medical treatment administered to you in the event of an accident or incident involving your health or wellbeing at an iQ property
How do we collect your information?
· Information you give us.
o You may give us such information directly by applying for accommodation, completing forms and other forms of agreements, corresponding or speaking with us face to face at our premises, by phone, email, letter or otherwise, submitting a query, providing us with feedback, visiting our website, requesting that we provide you with services / communications, or when we appoint you as a service provider.
· Information we collect about you.
o Information obtained through CCTV footage and other information obtained through electronic means such as swipe card records when you access our premises, our telephone recording system, or other information about your use of our premises, including meter readings.
o When you visit our website and receive emails from us we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this by using cookies.
o Information provided by cookies.
§ Cookies are small files saved to the user's hard drive that track, save and store information about the user's interactions and usage of the website. This allows our website, through its server, to provide users with a tailored experience.
§ If you wish to prevent the use and saving of cookies from this website on to your computer's hard drive you should take necessary steps within web browser's security settings to block all cookies from our website.
§ Other cookies may be stored on your hard drive by external vendors when our website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer.
§ If you would like further information about cookies and how they are used, you can visit http://www.allaboutcookies.org/.
o When we e-mail you, such e-mails may contain tracking facilities. Activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but is not restricted to: the opening of emails, geo-location, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.
· Information we receive about you from other sources.
o We may receive information about you if you use any of the other websites we operate or the other services that we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
o We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and, if you are a supplier, credit reference agencies) and may receive information about you from them.
o We may receive information if you have provided permission to referees or other organisations to share it with us. Before providing permission to such third-party organisations to share your personal data, you should check their privacy notices carefully.
o We may take information from publicly available sources (where possible) to keep your information up to date, for example, from the Post Office’s National Change of Address Database.
o If you are a nominated guarantor, we will obtain contact details and some basic information about you from the prospective resident in order for us to process their application.
o We may occasionally purchase the contact details of people who might be interested in hearing from us. Before purchasing such information, we will check with the vendor that your information was originally collected in a compliant manner, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties.
o We may receive information about you if you apply for a vacancy with us.
How we might use your information?
We use information held about you in the following ways:
· To process your application for a tenancy including the use of sanctions screening (Please refer back to the Privacy Centre home page to find out more about sanctions screening)
· To manage and administer our relationship with you including by issuing communications and information to you
· To carry out our obligations arising from any contracts entered into between you and us
· To respond to your requests
· For marketing campaigns
· To confirm your identity when interacting with onsite staff, for e.g. for parcel collection, if you are locked out of your room, etc.
· To allow you to use and provide information to us and request services via the iQ mobile app
· To provide you with information about our activities
· To improve our level of service
· To notify you about changes to our service and notify you of new products and services
· To seek your views on our products and services
· To recover any unpaid sums due to us
· If you are a guarantor, to administer your guarantee
· To consider your application for employment
· For administrative and quality assurance purposes
· For the purposes of the establishment, exercise or defence of legal claims
· To prevent and detect criminal activity, fraud and misuse of or damage to our property
· To enable us to make any reasonable adjustments necessary to enable you to access and benefit from our facilities and services
· To ensure the safety of our premises, including that they can be safely evacuated in the event of an emergency
· To maintain a record of incidents at our premises for the purposes of monitoring and managing risk
· To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
· To provide and improve our site to ensure that content is presented in the most effective manner for you and for your computer
· To allow you to participate in interactive features of our service, when you choose to do so as part of our efforts to keep our site safe and secure
· Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive). For example, we may use your email address assigned to a Facebook account to profile you and target our Facebook advertising to similar audiences (look-alike audiences).
Communications with you
We may, with your consent, text or e-mail you to provide you with information about our activities and products and services supplied by us. You can unsubscribe at any time through an automated system. This process is detailed at the footer of each email. If an automated unsubscription system is unavailable, clear instructions on how to unsubscribe will be detailed instead.
We may occasionally, with your consent, call you to provide you with information about our activities or provide you with information about products and services supplied by us. You may unsubscribe to calls by instructing the person calling you or by contacting us at any time on the details set out in the ‘Contact Us’ section of this notice.
We may also communicate with your through postal marketing when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with information on our services, products, newsletter requests, feedback, competitions and other activities and those of other carefully selected organisations. You have the right to contact us at any time and opt-out of receiving postal communications.
What is our legal basis for using your information?
There are a number of lawful reasons for us to process your personal data.
Where we are providing you with accommodation services, we will primarily process your personal data in order to fulfil our contract with you.
Other legal bases that we will rely on include the following:
· Where we are required to comply with our legal obligations, or to establish and defend our legal rights, or to prevent and detect crimes such as fraud or misuse of or damage to our property.
· If we are providing you with email based promotional communications, we will only do so with your consent. If you have given us your consent, you can withdraw your consent at any time by clicking the ‘unsubscribe’ button at the bottom of the email. Please note that in order to fulfil your request we will have to retain your e-mail address to ensure that you do not receive any further promotional communications.
· Where it is in our legitimate interests to do so. This means that we can process your personal data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your rights and interests. Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.
o We will use your personal data in order to help us to provide you with the services that you have requested (for example by providing you with service communications), for our internal administration and to provide you with the best experience when dealing with us.
· Where we use special categories of personal data, for example, Health and Disability Data, we do so on the basis that such processing is necessary for us to comply with a legal obligation (our duty under the Equality Act 2010 to make reasonable adjustments to prevent discrimination arising from disability) and that our processing is therefore necessary for us to exercise a function conferred on us by an enactment or rule of law. We also use such information to make sure that we can safely evacuate our premises in the event of an emergency and manage your safety. We may further process special categories of personal data if it becomes necessary for reasons of public interest in the area of public health (e.g. to perform a public task to minimise the transmission of infectious diseases), or where necessary for the purposes of safeguarding. The law does not require us to ask for your consent to process Health and Disability Data for these purposes. We may also make use of this information without your consent where, for example, if it is in your vital interests or is necessary in the establishment, exercise or defence of any legal claims
Sometimes your personal data may be used for statistical research but only in a form that no longer identifies you.
How long will we hold your information for?
We will hold your personal data on our systems for as long as is necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any legal, accounting or other reporting requirements.
By law, we are required to retain certain information for a prescribed period of time. In circumstances where there are no such legal requirements, to determine the appropriate retention period, we will consider 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 are processing your personal data and whether we can achieve those purposes through other means.
Therefore, some information may be kept for more or less time depending on how long we reasonably feel it is required for.
Generally, at the end of your tenancy, we will hold your information for three years after the termination of your tenancy. However, in some cases we may retain information about you for up to 6 years where this is required for financial reasons. We may also hold this data for longer in the event that you have not fully paid any sums due.
We review our retention periods for personal data on a regular basis.
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.
If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
Who we might share your information with:
We will NOT sell your personal data to any third parties.
We may share your personal information with any member of our group.
We may share your information with selected third parties including:
· Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you e.g. our IT providers or our auditors or our Accounts Management provider or other professional advisors and for provision of the iQ app.
· If you are a tenant or applicant, we may share your basic information with others who seek to book a dual occupancy room or who may be booking with friends for the sole purpose of effecting that booking.
· If you are a tenant and fail to pay your rent, we may contact the guarantor and inform them of this failure when exercising our rights under the guarantee.
· With your University so that they can provide you with support or otherwise take any necessary steps in the event that we have concerns surrounding your health, safety or wellbeing, public health, or in the event of any serious disciplinary matters.
· With relevant utility suppliers and local authorities for the purposes of informing them who lives in the accommodation and in respect of any utility bills, council tax or other bills that you have failed to pay.
· With your emergency contact in the event of an emergency or where we have concerns as to your health, safety or wellbeing.
· With debt recovery agencies in the event that you fail to pay your rent or any other charges due and which you have not settled.
· Analytics and search engine providers that assist us in the improvement and optimisation of our site.
· Automated marketing providers.
· Live chat service provider including the use of Chat Bots.
· Our employee training & development service providers.
· If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear what will happen to your data when you register for that event.
· If we merge with another organisation or form a new entity, your personal data may be transferred to that new entity.
We may disclose your personal information to third parties to:
· Comply with any court order or other legal obligation or when data is requested by our regulators or by government agencies or law enforcement agencies;
· Protect the rights, property, or safety of us, our employees, our tenants, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
International transfers of personal data
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
You have a number of rights. If you would like to exercise any of these rights, please contact us using the details set out below in the ‘Contact Us’ section. If you exercise any of these rights we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge except in exceptional circumstances.
If you wish to raise a complaint in relation to our processing of your personal data, you can contact our DPO at firstname.lastname@example.org or in writing at iQ Student Accommodation, 7th Floor, Cottons Centre, Cottons Lane, London, SE1 2QG (marking your query for the attention of The Data Protection Officer). You also have the right to lodge a complaint with the data protection regulator, the Information Commissioner’s Office, if you have concerns about how we use your personal information. You can contact the Information Commissioner’s Office at.
Your rights include:
· transparency over how we use you data and to make a subject access request (right of access) – you can make a subject access request by clicking (here);
· a right to have your personal data updated and corrected (right of correction/rectification) ;
· a right to ask us to delete your information (right to be forgotten);
· a right to ask us to stop processing your information (right to restriction);
· a right to object to (i) processing based on our legitimate interests; (ii) processing of your information for direct marketing purposes; and (iii) automated decision making and profiling (right to object);
· a right to receive a copy of your information, or have this sent to a third party (right to data portability); and
· a right to claim compensation for material or non-material damage caused if we breach the data protection rules (right to compensation).
If you would like to find out more about your rights, you can visit the Information Commissioner’s Office website.
How you can access and update your information
We strive to maintain accurate, complete, and relevant personal information for the purposes identified in this privacy statement. If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it. It is important that the personal information we hold about you is accurate and current.
Security precautions in place to protect against the loss, misuse or alteration of your information
We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Details of these measures can be obtained on request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
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.
Our security measures are regularly reviewed.
If you have any questions regarding this policy or about our privacy practices, wish to exercise any of your rights or wish to make a complaint, please contact our Data Protection Officer at:
· Email: email@example.com
· Post: iQ Student Accommodation, 7th Floor, Cottons Centre, Cottons Lane, London, SE1 2QG (marking your query for the attention of The Data Protection Officer)