London College of Contemporary Arts: Privacy Policy

Privacy Policy

Welcome to the London College of Contemporary Arts (LCCA) privacy notice. LCCA takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.

Terms and Conditions

Welcome to the London College of Contemporary Arts (LCCA) privacy policy. LCCA takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.

Introduction

Welcome to the London College of Contemporary Arts (LCCA) privacy policy. LCCA takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.

The UK General Data Protection regulation 2016/679 (‘’UK GDPR’’) and the Data Protection Act 2018, gives people the right to know what information is held about them, and requires LCCA to ensure that personal information relating to living individuals is handled properly, held in confidence and is protected from inappropriate disclosure to third parties.

As part of our legal obligations we have published Staff, Student and General Privacy polices. Where required local privacy policys will be issued to inform individuals about what personal data is gathered, how it is used, stored and retained.

Data Controller

London College of Contemporary Arts (“LCCA “also referred to in this policy as “we” or “us”) is registered as a data controller of your personal data with the Information Commissioner’s Office (our notification number is ZA184810), and is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at: www.globaluniversitysystems.com.

LCCA registered address in England and Wales is Belmont House, Station Way, Crawley, West Sussex, RH10 1JA, United Kingdom

Our Data Protection Officer

If you have any questions about LCCA’s privacy policies, please contact the Data Protection Officer at London College of Contemporary Arts, Sceptre Court, 40 Tower Hill, London EC3N 4DX. E-mail dpo@lcca.org.uk

How to Use This Privacy Policy

LCCA holds and processes information about many different types of people such as its current, past or prospective employees, visitors to is website, applicants, students and alumni & supporters. It also processes personal information for a variety of reasons. LCCA may also be required by law to collect and use certain types of personal information to comply with statutory requirements. For each category of personal data process you will find the following headings:

More information on how LCCA collects and uses personal information can be found in the relevant privacy policys below:

Website visitor - Privacy Policy

Types of personal information we collect

We collect, use and store different types of personal information about you, which we have grouped together as follows:

How we use your information

Cookies

Our website https://www.lcca.org.uk/ uses cookies. For more information on our cookies use, please read our cookies statement on our website.

Generally

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.

Where we collect your personal information from

We may collect personal information about you from the following sources:

Directly from you
Cookies – see our cookie statement which can be accessed from our website
Analytics providers, such as Google Analytics

Who we share your information with

We may share your personal information with the following third parties:

Our agents and service providers who we use to help us with marketing.
Event organisers (if we are organising an external event which you are attending)
The police and other law enforcement agencies
Relevant regulators, including the Information Commissioner's Office in the event of a personal data breach
Other companies owned or jointly owned by Global University Systems
Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business.

How long we keep your personal information

Where we use your personal information for marketing purposes we will retain your personal information for so long as we have your consent to do so (where we use your personal information with your consent in order to send you marketing messages) or, in other cases, for so long as we have a legitimate business or commercial reason to do so (unless you ask us to stop).

Where you withdraw your consent to receiving marketing materials or otherwise ask us to stop marketing we will add your details to a suppression list which ensures that we remember not to contact you again.

For further information as to how to withdraw your consent or to ask us to stop other marketing activities see Withdrawing consent using your information and Objecting to how we may use your information.

If you withdraw your consent to receiving marketing materials or ask us to stop our marketing activities, we will still communicate with you for other purposes in the normal course of any other relationship we may have with you.

International transfers

As a global company, we hold some personal information concerning our suppliers and their affairs within the United Kingdom. We do work with agents and service providers who may process your personal information on our behalf outside the UK. If your information is processed outside the UK, we will ensure that it is protected to the same standards as if it were being processed within the UK by putting in place a contract with our agents and service providers that provides adequate safeguards.

If you require more information or have any queries, please contact our Data Protection Officer at: dpo@lcca.org.uk

Applicants and Students Privacy Policy

London College of Contemporary Arts (LCCA) takes the protection of your personal data very seriously and are committed to protecting and respecting your privacy.

When processing your Personal Data, LCCA is obliged to fulfil individuals’ reasonable expectations of privacy by complying with the General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA), and other relevant legislation and regulations (collectively “Data Protection Law”).

Purpose of this Policy

This privacy policy sets out the basis on which any personal data we collect from you, or that you or any third parties provide, will be processed by us. We may withdraw or modify this policy at any time and we may supplement or amend this policy by additional policies and guidelines from time to time. We will notify you if this policy is amended.

LCCA also referred to in this policy as “we” or “us”) is a data controller (which means we are responsible for deciding how we hold and use your personal information) of your data and is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at https://www.globaluniversitysystems.com.

“Personal data” refers to information relating to a living, identifiable individual. It can also include "special categories of data", which is information about your racial or ethnic origin, religious or other beliefs, and physical or mental health, the processing of which is subject to strict requirements. Similarly, information about criminal convictions and offences is also subject to strict requirements.

“Processing” means any operation which we carry out on your personal data e.g. obtaining, storing, transferring and deleting.

Your personal information

We hold a range of personal data about you, some of which you provide to us direct and some of which we receive from third parties, such as UCAS, where relevant. See below for further details of personal data we receive from third parties. Examples of categories of personal data which we hold are: your contact details, prior educational experience/attainment, immigration information (e.g. passport details, language proficiency), where relevant, health information (including any disabilities) and other equality-monitoring data you provide to us. In addition, if you come to study with us, we process data about your academic performance, attendance and progression, and where relevant, breaches of our policies (e.g. academic or other misconduct concerning LCCA-related activities).We also process contact and educational details after you have completed your programme or your activities with us are otherwise terminated.

The purposes for which we process your personal data and the legal basis

When you are an applicant, we process your personal data for the purposes of assessing your eligibility to be offered a place on one of our academic or professional programmes.

If you take up a place at LCCA, we process your personal data for the purposes of providing our academic or professional programmes and related services.

If you are unsuccessful or do not take up a place at LCCA, we will retain your personal data in line with our retention schedules for statistical and audit purposes or in the event of a complaint or an appeal.

We only process data for specified purposes and if it is justified in accordance with data protection law. The table below lists the various purposes for which we process personal data and the corresponding justification for it. Some processing of your personal data is justified on the basis of contractual necessity. In general, this applies to personal data you provide to us to process your application and if enrolled, to monitor academic performance. Without that information, we would be unable to provide you with your chosen academic programme and related support services. Some personal data is also required to fulfil our legal obligations regarding immigration. A failure to provide that information would prejudice your application for a Tier 4 visa.

There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter.

Where the basis of processing your personal data is contractual necessity and you fail to provide the personal data in question, LCCA may not be able to process your application or provide you with the programme for which you have applied. A failure to provide immigration-related data may result in failure to obtain a Tier 4 visa for those who students who require it.

Personal data received from third parties

Recipients of personal data

On occasion we may need to share your data with third parties. The following table lists what information we may share with whom

* This will only be shared on request and where there is a legal basis for doing so.

Overseas transfers of personal data (i.e. outside the United Kingdom (UK)

Where possible, we aim to hold personal data relating to students within the UK. Where any of your personal data is transferred outside the UK it will be subject to a legally binding data sharing agreement and/or to an adequacy decision by the Information Commissioner’s Office (country, territory or specified sectors), or other appropriate safeguards as set out in Article 46 of the UK GDPR.

Retention of data

The length of time that we keep your personal data for is set out in the Student Records Retention Schedule, please contact dpo@lcca.org.uk for more information.

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data processed by us:

To gain access to your personal data;
To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month.

Exercising your rights, queries and complaints

For more information on your rights, if you wish to exercise any of the above rights or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at LCCA, Sceptre Court, 40 Tower Hill, London EC3N 4DX.

E-mail: dpo@lcca.org.uk

Complaints to the Information Commissioner

LCCA maintains a data protection registration with the Information Commissioner's Office, the independent authority which oversees compliance with the Data Protection Legislation. LCCA registration number is ZA184810 and sets out, in very general terms, the full range of purposes for which we use, students and all other personal information

You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/.

London College of Contemporary Arts (LCCA) Privacy Policy - Alumni and Supporters.

Purpose of this Privacy Policy:

Our alumni and supporters are extremely important to us. This Privacy Policy explains how we, London College of Contemporary Arts (LCCA), use the personal data our Alumni and Development Department collects from our alumni and supporters.

We are the data controller for personal data relating to you and this Privacy Policy explains how we will process your personal data. This Privacy Policy will be kept under review and any changes will be updated on our website and communicated to you as appropriate.

This Privacy Policy was last updated in on 5^th September 2024.

Due for Review by: 2^nd September 2025

Who does this privacy policy cover?
This privacy policy covers LCCA alumni who have completed a course of over 12 months’ duration. It also covers individuals who have chosen to support LCCA in some way that is under the remit of the Alumni and Development Department and have consented to be contacted for one of the purposes set out below. This policy only covers processing of personal data for Alumni and Development purposes as set out below. For other personal data processing related to former-students and alumni see the Student Privacy Policy.

What personal information do we collect?
We may hold a range of personal data about you from a number of sources.
The majority of the personal data that we hold is information provided to us by you. If you are an alumna/ alumnus of LCCA, personal data collected during your time as a student is transferred from your student record such as your name, date of birth and gender to LCCA’s alumni database when you complete a course of over 12 months’ duration. We may also add information provided by you during interactions with you. If you are a supporter of LCCA, the personal data we hold may be information provided by you during your interaction with us.

Examples of categories of personal data which we may hold are:

Personal identifiers – e.g. your name, gender, student/ alumni numbers and your date of birth;
Contact details – e.g. your postal/ email address, telephone number and contact preferences;
Information about your time at LCCA – e.g. the courses you completed and your membership of clubs and societies;
Career details – e.g. job role;
Records of donations – including financial details and Gift Aid status, where applicable (as required by HMRC);
Communications between the Alumni and Development Department and you;
Information about your interactions with LCCA – e.g. records relating to volunteering activities on behalf of the College, online interactions with us on social media, information about your use of College resources or facilities (e.g. the library), information on your engagement with College meetings, events, groups or networks;
Results of automated decision making and profiling processes to focus our interactions with you

We may also hold information collected from publically available sources, such as social network posts, internet searches and websites, and may augment this information with the personal data you provide to us.

Why are we collecting your personal data/what are we doing with it (purposes)?
We only process data for specified purposes and if it is justified in accordance with data-protection law. In general terms, we process your personal data for the purposes of increasing alumni involvement with the student experience at LCCA, fundraising, alumni/ supporter communications and related activities by the Alumni and Development Department. More specifically, these activities may include:

sending you publications (e.g. alumni magazines and email newsletters about LCCA and fundraising activities);
inviting you to alumni and supporter events, reunions and University events;
informing you of benefits available to alumni and supporters;
asking you to support LCCA (e.g. contributing to student mentoring schemes or donations);
fundraising programmes;
wealth analysis and research in order to improve our understanding of our alumni and supporters, inform our fundraising strategy and target our communications; and
internal record-keeping and administration (e.g. to process a donation or administer an event which you are attending).

Do we use any automated decision making or profiling?
Automated individual decision-making means making a decision solely by automated means without any human involvement and profiling means the automated processing of personal data to evaluate certain things about an individual. We may use automated or manual analyses including segmentation or profiling to link data together to send you communications which are relevant and timely, to identify opportunities which may be of interest to you, to help us identify your potential for supporting LCCA and to avoid approaching you with opportunities which are not of interest. We may carry out wealth screening to focus our conversations with you and ensure we provide you with an experience which is appropriate for you.

What legal bases do we rely on for processing your personal data?
Depending on the activity being carried out, we will rely on one of the following conditions for processing: a legitimate interest; a legal obligation; or your consent to process your data, as explained below.

UK GDPR Article 6(1) (a) – Consent of the data subject
Unless mentioned below, we will only process your personal data in relation to alumni and development purposes where we have your consent. This means we will only email you, or call TPS registered numbers, if we have your express consent to do so. We may contact you by post, unless you have asked us not to. We will also only contact you about College news, events or to ask for a donation if we have your express consent to do so.
UK GDPR Article 6 (1)(c) – Processing is necessary for compliance with a legal obligation
If you make or have made a charitable donation we will process your name, address, and donation information under Article 6(1)(c) of the UK GDPR for the purpose of administering your donation and claiming Gift Aid on your behalf. We may also use available sources to carry out due diligence checks to meet money laundering regulations. If you withdraw consent, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. The College has a legal obligation to supply some of the information we hold about you, as a graduate, to the Higher Education Statistics Agency (HESA) – the official agency for the collection, analysis and dissemination of quantitative information about higher education in the United Kingdom. HESA will treat your data in line with its collection policys. HESA produces official statistics and its outputs are regulated by the UK Statistics Authority, which has a direct line of accountability to Parliament.
UK GDPR Article 6.1(f) -Processing is necessary for the pursuit of our legitimate interests.
Processing of student record data for alumni under legitimate interests for the purpose of monitoring our academic services and providing you with information (e.g. copy of transcript, confirmation of degree etc.) is covered in the Student Privacy Policy.

Who do we share your personal data with? What data do we share?
On occasion we may need to share your data internally and with third parties. The following table lists what information we may share with whom.

How are we protecting your personal data?

Your personal data is held securely on LCCA’s alumni and supporter database, which is accessible by a limited number of staff and is secured.

We ensure we have appropriate data sharing agreements in place before sharing your personal data.We do not sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them. LCCA is committed to working in a transparent, ethical, responsible and honest way.

Your rights as a data subject
As a data subject, you have the following rights in relation to your personal data processed by us:

to gain access to your personal data;
to rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
to have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
to object to the processing of your personal data for marketing purposes;
to object to the processing of your personal data when such processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing;
to restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period; and
to ask for the transfer of your data electronically to a third party.

How long is your personal data kept?
Personal data in support of your alumni relationship with LCCA will be kept until there is no longer a legal basis for holding it, until you object to the processing of your data (e.g. for direct marketing purposes) or until you withdraw your consent.
If you ask us to delete your personal data, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. We may also need to retain some financial records for statutory purposes.

How can you maintain your personal data?
You can update, amend or correct the data we hold about you by contacting the Alumni and Development Department by email, phone or post. You can also change your communication preferences at any time to restrict how we process your data, or opt out of some or all communication. We will also review your consent and preferences at least every two years.

Exercising your rights, queries and complaints
For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Officer:

Data Protection Officer
Address: Sceptre Court, 40 Tower Hill, London EC3N 4DX
Email: dpo@lcca.org.uk

Complaints to the Information Commissioner
You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/.

London College of Contemporary Arts (LCCA) Privacy Policy - Graduation

London College of Contemporary Arts (LCCA), graduation ceremonies are significant events for our graduates, their guests and our staff. These ceremonies are public events and therefore there is no expectation of privacy under data protection legislation for any attendees. This statement explains how personal data will be processed for and during the event and provides guidance should you not wish your personal data to be processed in this way. This applies to all students who are intending to graduate or may be eligible for an award, whether they attend a ceremony or not. Please note the following important information and ensure your invited guests are also aware of the information relevant to them:

Your name will appear in the Graduation brochure. If you do not want your name included for these purposes you must tell us be emailing dpo@lcca.org.ukno later than 5 weeks prior to the date of your ceremony*.
If you graduate in person your name and award title will be read out at the ceremony immediately prior to you walking across the stage.
Your photograph will be taken whilst you cross the stage and receive your ‘parchment’.
Crowd shots will be taken by the College photographers at the venue and at our graduation receptions and these may include images of you and your guests.
Your consent will be sought for smaller group or individual photographs prior to these being taken. If you do not wish to be photographed, you should tell the photographer before the photo is taken.
Live film feed may be used to stream the ceremonies externally.
If you do not wish to have your photograph taken/ video filmed/streamed when crossing the stage, including being handed your parchment you must tell us by emailing dpo@lcca.org.ukno later than 5 weeks before the date of your ceremony*.
Videos of the ceremonies may be produced and screened at relevant post-graduation receptions and, at a later date, will be made available for viewing from the College website.
Television companies may be present to interview our honorary graduands and other VIPs or film the event generally. If you do not wish to appear on television, you should maintain your distance from any filming that may take place.
Appropriate photographs and films of these events may be used to promote the activities of LCCA and these may appear in any of our promotional materials, in printed or electronic format, including worldwide web sites, multimedia productions, course leaflets or prospectuses. Please note that websites can be seen worldwide.
Visual images will be used and retained strictly in accordance with the UK Data Protection Legislation and the College records retention schedules.

If you have any queries or concerns about the use of your personal data for/at our Graduation ceremonies, please email dpo@lcca.org.uk no later than 5 weeks prior to the date of your ceremony. Please see the full privacy policy below:

*When emailing please ensure that you include your Student ID and Programme of Study.

Identity of controller

London College of Contemporary Arts (LCCA)

Purpose for collection/processing

The College processes personal data for the purposes of arranging graduation ceremonies, conferring awards on graduands and documenting the event for the purposes of celebrating graduands achievements and for the future promotion of the College.

Legal basis

Article 6(1) of the UK General Data Protection Regulation refers:

UK GDPR, Article 6(1) (a) consent, is the basis for including names in the press.

UK GDPR Art 6(1) (f), legitimate interests, is the basis for processing personal data for the purposes of photography and filming where this is for future promotion of the College. Please see the photography statement provided for further information. It is in the legitimate interests of the controller to use images of successful graduates and ceremonies for future promotion of the College. To balance the individual’s interests, rights and freedoms the College provides a fact sheet of all photography and filming activities to individuals prior to the event which details how they can avoid inclusion in the photography and filming and exercise their rights in the event that they are included. It is in the interests of both the College and individual graduands involved to document these auspicious occasions which are important life events to be celebrated.

Whose information is being collected/processed

Students, College employees and all other ceremony attendees, including those invited by students/graduands.

What information is being collected

Name, identifying numbers, contact details, educational details, photographs and moving images.

How is the information collected

College systems for the event organisation and images by camera on the day of the event.

Who is the information shared with outside the College

Publicly – the publication of names in graduation brochures, photographs online and in any of the College’s promotional materials, in printed or electronic format.

How is the information kept securely

Information/photographs are kept securely on College processing equipment in line with the College’s information security and data protection policies.

How is the information kept up to date

Students are required to keep their information up to date during the course of their studies to ensure that the personal data used at the time of graduation ceremonies is accurate, as this will be recorded at this point as a record of the event.

How long is the information kept

Please see the College’s Records Retention Schedules.

Will the information be used for any automated decision making

Is the information transferred outside the United Kingdom?

Ceremony live video streams are broadcast over the internet and may be accessed out with the UK.

Individual photographs and graduation brochures may be transferred outside the UK by third party individuals.

Your rights

Attendance at a Graduation Ceremony is optional and students can choose to graduate in-absentia (without attending). This selection is made at the time of registering a student’s intent to graduate.

Graduands can request that they are not photographed/captured on video while crossing the stage during the ceremony.

This request must be made in writing to dpo@lcca.org.uk and submitted no later than 5 weeks prior the date of the ceremony.

Graduands can request that their name does not appear on the official Graduation Brochure.

This request must be made in writing to dpo@lcca.org.uk and submitted no later than 5 weeks prior the date of the ceremony.

Data protection officer

Enquiries relating to data protection should be made to the College’s Data Protection Officer, email: dpo@lcca.org.uk

Further information

https://www.lcca.org.uk/

London College of Contemporary Arts (LCCA) Staff Privacy Policy

London College of Contemporary Arts ("we", "our", "us") are committed to protecting and respecting your privacy.

What is Personal Data?

'Personal data' means any information which identifies you as an individual. It may include your name but it may also be other information such as your date of birth, nationality and gender which when combined identify you.

London College of Contemporary Arts data protection obligations

In accordance with the United Kingdom General Data Protection Regulation (the “UK GDPR”) and the Data Protection Act 2018 (the “DPA”), together, the “Data Protection Laws”, we are a Data Controller as we determine the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This means that we are legally responsible for the personal data we collect and hold about you. It also means that we must comply with the data protection principles (see below). One of our responsibilities is to tell you about the different ways in which we use your personal data – what information we collect (and our legal basis for doing so), why we collect it, where we collect it from and whether (and with whom) we will share it. We also need to tell you about your rights in relation to the information. This policy provides further details about all of these issues.

In order to comply with our contractual, statutory, and management obligations and responsibilities, we need to process personal data relating to our employees, including ‘sensitive’ or special categories’ of personal data, as defined in the Data Protection Laws which includes information relating to health, racial or ethnic origin, and criminal convictions.

All personal data will be processed in accordance with the Data Protection Laws and LCCA Privacy Policy: https://www.lcca.org.uk/privacy-policy/

Using your information in accordance with Data Protection Laws

Data Protection Laws require that we meet certain conditions before we are allowed to use your data in the manner described in this policy, including having a 'legal basis' for the processing.

The legal bases on which your personal data are collected, the types of personal data, and the purposes for which they are processed is given below.

Application for employment (Subsection)

We need to process your personal data that you supplied to LCCA as part of your application for a position at LCCA. This is to ensure that your application can be considered by the relevant department. In your application we will collect the following information:

Personal data gathered

In your application we will collect the following information:

First Name(s)
Last Name
Title
Other Name(s)
Preferred Forename
Your Address
Postcode
Telephone (Home)
Telephone (Work)
Telephone (Mobile)
Your personal Email
Details of your Secondary and/or Tertiary education
Professional qualifications
Statement in support of your application
Details within your submitted Curriculum Vitae (CV)
Details of your right to work in the UK

Information about your present and employment history for the previous five (5) years including:

Name of Employer(s)
Address Line 1
Address Line 2
Town
County
Postcode
Job Title
Date From
Date To
Salary
Policy Required

In addition, we may contact your referees as provided in your application to confirm the employment information that you provided.

Special categories personal data

As part of the application you will be asked to provide equality and diversity information, this may include data concerning:

Any disability
Your ethnicity
Your sexual orientation
Your religious beliefs

You have the right to not provide this information, in which case LCCA will note to statutory bodies that you elected not to provide this information

Criminal records information

In some circumstances we may process your information to undertake a Disclosure and Barring Service (DBS) check, as required by law.

During your employment (subsection)

The Data Protection Laws define ‘sensitive personal data’ or 'special categories of personal data' as information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, data concerning sex life or sexual orientation. We will process this data, as well as the data provided in your application in order to perform our obligations arising from your contract of employment with us. The additional personal data we process to meet these responsibilities includes:

Additional data-personal information

The additional personal data (including some special category personal data) we process to meet our responsibilities as an employer includes the following:

Previous sickness information including the reasons for the absence
Bank account details
Passport details
Visa details
Sick pay
Leave entitlement
Parental pay
Pensions data
Remuneration and benefits
Emergency contacts
Trade Union Membership

Statutory responsibilities

We may process your personal data in order to meet responsibilities imposed on us by legislation. The personal data processed to meet statutory responsibilities includes, but is not limited to, data relating to:

tax;
national insurance;
statutory sick pay;
statutory maternity pay;
family leave;
work permits, and
equal opportunities monitoring.

Our lawful basis for processing

The lawful bases for processing personal data will be:

UK GDPR Article 6(1) (b) Contract

UK GDPR Article 6(1) (c) Legal obligation
UK GDPR Article 6(1) (f) Legitimate interest

Purpose of processing

We will use your personal data in connection with your employment relationship with us, including for the following purposes:

To facilitate staff training, such as e-learning.
Managing our accounts and records and providing commercial activities to our clients.

For the use of CCTV systems to monitor and collect visual images for the purposes of security and the prevention and detection of crime – The CCTV policy can be found HERE

To provide you access to relevant systems to undertake your role.
To fulfil our obligations for the contract of employment.
Processing recruitment applications.
Talent, performance and succession planning.
Paying and reviewing salary and other remuneration and benefits.
Providing and administering benefits (including pension, voluntary healthcare schemes, salary sacrifice schemes and others).
Undertaking performance appraisals and reviews.
Policy and Legal Governance requirements and compliance.
Internal audit and data collection.
Legal compliance, requirements and obligations.
Maintaining sickness and other absence records.
Providing references and information to future employers and, if necessary, governmental bodies.
Processing information regarding equality of opportunity and treatment of data subjects in line with the monitoring of equal opportunities and access.

The information we process may be held on LCCA Corporate systems some of which may be owned and operated by third parties. Where we engage with such third parties, we insist upon strict contractual requirements to be adhered to by them to protect the personal data.

Special categories personal data

The Data Protection Laws define ‘sensitive personal data’ or 'special categories of personal data' as information about racial or ethnic origin; political opinions; religious beliefs or other similar beliefs; trade union membership; physical or mental health; sexual life. In certain limited circumstances, the Data Protection Laws permit us to process such data without requiring the explicit consent of the employee.

(a) We will process sensitive personal data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and consent.
(b) Other than in exceptional circumstances, LCCA will process sensitive personal data about an employee’s racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for the purpose of monitoring and upholding LCCA’s equal opportunities policies and related provisions.
(c) Information about an employee’s criminal convictions will be held as necessary and only in accordance with Data Protection Legislation.

The lawful basis for processing this special category personal data will be:
The UK GDPR Article 9(2)(b) ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.

Sharing personal data

We sometimes need to share the personal information we process with you and also with other organisations. Where this is necessary we are required to comply with all aspects of the Data Protection Laws.

We may use third party providers to deliver our services, such as externally hosted software or cloud providers, and those providers may involve transfers of personal data outside of the UK. Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards, such as the UK model Standard Contractual Clauses or equivalent measures.

Where necessary or required we will share your information with:

family, associates and representatives of the person whose personal data we are processing;
current, past or prospective employers;
healthcare, social and welfare organisations;
suppliers and service providers;
financial organisations;
auditors;
police forces, security organisations;
courts and tribunals;
prison and probation services;
legal representatives;
local and central government;
consultants and professional advisers;
trade union and staff associations;
survey and research organisations, and
press and the media.

Furthermore, in order to fulfil its statutory responsibilities, LCCA is required to provide some of an employee’s personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.

Automated processing

LCCA does not use automated processing and decision making without manual intervention.

Principles

We will handle your personal data in accordance with the principles set out below:

Keeping personal data up-to date

The Data Protection Laws require us to take reasonable steps to ensure that any personal data we process is accurate and up-to-date. Employees are responsible for informing us of any changes to the personal data that they have supplied during the course of their employment. You can contact cezannehr@gus.global to update your personal data.

Retention of your data

LCCA retains personal information it collects from you where there is an ongoing business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When there is no ongoing business need to process your personal information, LCCA will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then LCCA will securely store your personal information and isolate it from any further processing until deletion is possible. Personnel files are retained for a period of at least 6 years from the date of termination of employment.

How does LCCA protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Your information will not be transferred outside of the UK.

Your rights

Under certain circumstances, you may have the following rights in relation to your personal data:

Right 1: A right to access personal data held by us about you.

Right 2: A right to require us to rectify any inaccurate personal data held by us about you.

Right 3: A right to require us to erase personal data held by us about you. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).

Right 4: A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.

Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation.

Right 6: A right to object to our processing of personal data held by us about you.

Enquiries relating to data protection should be made to the College’s Data Protection Officer, email: : A right to withdraw your consent, where we are relying on it to use your personal data.

Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer at: dpo@lcca.org.uk

Changes to our privacy Policy

Any changes we make to this privacy policy in the future will be [posted on this page] and, where appropriate, notified to you by e-mail.

Who regulates the use of my personal information?

Who do I contact with questions?

The data controller for the purposes of the United Kingdom General Data Protection Regulation is LCCA. If you have any questions or concerns about how your personal data is used, please consult https://www.lcca.org.uk/privacy-policy/, and if you have a complaint please email London College of Contemporary Arts Data Protection Officer at: dpo@lcca.org.uk

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the UK Information Commissioner's Office. Full details may be accessed on the complaints section of the ICO's website

Recruitment Privacy Policy

What is this policy?

This policy applies to individuals applying to work with us, including prospective directors, employees, trainees, apprentices, work experience students, workers, consultants and contractors. It applies whether the work applied for is part time or full time; or permanent, temporary or for a fixed term.

We are a data 'controller', which means we are responsible for deciding how we hold and use your personal information.

This policy explains how and why we will collect and use your personal information in the context of the recruitment process and your rights in relation to your personal information. We may amend this policy at any time.

Your personal information

In this privacy policy, 'your personal information' means your personal data i.e. information about you from which you can be identified. Sections 5 and 6 below set out your personal information that we may process.

Your 'personal information' does not include data where the identity has been removed (anonymous data).

It is important that your personal information is accurate and up to date. Please inform us if your personal information changes during the recruitment process.

Special categories of personal information

'Special categories of personal information' means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purpose of uniquely identifying you.

Data marked * in the table at section 5 below, and data described at section 6, falls within these 'special categories' or might disclose special categories of personal information. We must have additional legal grounds for processing special categories of personal information, and these grounds are set out at sections 5 and 6 below.

Where does your personal information come from?

Your personal information will come from you or us, and may also come from the following sources:

Recruitment agencies and apprenticeship providers may provide us with the following personal information: personal contact details, qualifications, schools attended, details of previous employment(s), skills and experience, hobbies and interests, and interview notes.
Credit reference agencies may provide us with the following personal information: personal contact details, date of birth, details of credit accounts and usage and an overall credit score.
Former employers or other referees, whom you have given us permission to contact, may provide us with the following personal information: role(s) held, dates of employment, details of skills and capabilities and any other information that helps to assess your suitability for the position applied for.
London College of Contemporary Arts staff may provide us with: personal information about you if they are referring you for recruitment.
Medical professionals may provide us with the following personal information: information relating to any disability that you may have, the effects of that disability, and adjustments that may need to be made to the recruitment process as a result of that disability.
Professional bodies such as the, Association of Chartered Certified Accountants, Law Society of England and Wales, and / or the Solicitors Regulation Authority may provide us with the following personal information: qualifications, registrations, practising certificates, accreditation details and membership details.
Google and social networking accounts (such as LinkedIn): as part of the recruitment process we may source personal information relating to roles you have held, details of skills and capabilities and any other information that helps us to assess your suitability for the position applied for.
Disclosure Scotland: as described at section 6 below.

Some of the sources above will only be relevant in certain circumstances, or if you have applied for a particular role. If you would like more information on the source of your personal information please contact the HR department.

Processing your personal information

We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.

In general, we process your personal information for the reasons, and on the legal grounds set out in the following table, and also to:

Retain records relating to the recruitment process;
Establish, exercise or defend legal claims;
Comply with the law or requirements of any regulator; and
Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).

Information about criminal convictions

To enable us to make recruitment decisions and assess suitability for particular work, we will process information about criminal convictions and offences (including alleged offences) as described in this section 6.

We will process this information to enter a contract with you, to comply with a legal obligation, for our legitimate interests (in selecting suitable employees, workers and contractors), and to exercise or perform employment law rights or obligations.

If you have accepted an offer of work from us that is subject to a criminal record check, we will ask you to obtain a disclosure check (at the appropriate level) from Disclosure Scotland, and provide us with a copy of this.

Data necessary for the contract

Sections 5 and 6 above identify personal information that we may need to enter a contract with you. You are not obliged to provide this information, but if you don't provide it, we may not be able to proceed with the recruitment process or enter into the contract.

Statutory requirement to provide your personal information

In some circumstances, the provision of your personal information relates to a statutory requirement. This includes:

Documentation confirming your right to work in the UK – you are not obliged to provide this information, but if you don't provide it, we will not be able to enter into a contract with you.

Sharing your personal information with third parties

We may share your personal information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

Health professionals and occupational health providers involved in your care, in order to consider reasonable adjustments to the recruitment process for disabled applicants.
Relevant regulators such as The Association of Chartered Certified Accountants, the Law Society of England and Wales and the Solicitors Regulation Authority.
Our professional advisors.
Other third parties as necessary to comply with the law.

Automated decision-making

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

Transferring your personal information outside the UK

We share your personal data within the GUS Group. This will involve transferring your data outside the United Kingdom (UK).

Some of our external third parties are based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards, such as the UK model Standard Contractual Clauses or equivalent measures.

Data retention

If you don't start work with us following the recruitment process, we will retain your personal information for six months thereafter:

to allow us to establish, exercise or defend legal claims; and
for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for becomes available again.

If you ask us to retain your personal information so that we can contact you to discuss future work opportunities, we will write to you separately, to obtain your explicit consent to retain your personal information for a fixed period of two years on that basis.

If you start work with us following the recruitment process, we will give you a copy of our Staff Privacy Policy, and will retain your personal information as detailed in the Staff Privacy Policy.

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data processed by us:

To gain access to your personal data;
To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month

If you require more information or have any queries, please contact our Data Protection Officer at: dpo@lcca.org.uk

Former employees Privacy Policy

London College of Contemporary Arts ("we", "our", "us") are committed to protecting and respecting your privacy.

This privacy policy applies to former employees of London College of Contemporary Arts.

It is important that you read this privacy policy together with our privacy policy at: https://www.lcca.org.uk/privacy-policy/ or any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you. This is so that you are fully aware of how and why we are using your data.

Information we collect

London College of Contemporary Arts does not collect personal data from former employees after they have left our employment, but it may hold the information that was collected before and during the employment relationship, including:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Date of birth
Gender
Marital status and dependants
Next of kin and emergency contact information
National insurance number
Copy of identification (Passport/driving licence)
Bank account details, payroll records and tax status information
Salary, annual leave, pension and benefits information
Start date
Location of employment or workplace
Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
Employment records (including job titles, work history, working hours, training records and professional memberships)
Compensation history
Performance information
Disciplinary and grievance information
CCTV footage and other information obtained through electronic means such as swipecard records
Information about your use of our information and communications systems
Photographs

Our lawful basis for processing

The lawful bases for processing personal data will be:

UK GDPR Article 6(1) (b) Contract

UK GDPR Article 6(1) (c) Legal obligation
UK GDPR Article 6(1) (f) Legitimate interest

How we process your information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the obligations in a contract we have entered into with you, such as the employment contract, or a settlement agreement. Some of the contractual obligations in these contracts continue after your employment has terminated, such as the duty to observe confidentiality.
Where we need to comply with a legal obligation.

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your vital interests (or someone else’s vital interests). UK GDPR Article 6(d).
Where it is needed in the public interest. UK GDPR Article 6(1) (e).

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may process your data for the following purposes:

Paying you and deducting tax and National Insurance contributions and other lawful deductions.
Providing you with any employee related benefits to which you are entitled after the termination of your employment.
To reimburse you for expenses incurred in the course of your employment.
Liaising with your pension provider and the trustees/administrators of pension schemes.
Administering any contract we have entered into with you.
Business management and planning, including accounting and auditing.
Gathering evidence for possible grievance or disciplinary hearings.
Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
To prevent and detect fraud.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
To conduct data analytics studies (such as the staff survey) to review and better understand employee retention and attrition rates.
Equality and diversity monitoring
Publicising our activities (e.g., group photos of events, site visits, etc.).

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

How we process “special categories” of more sensitive personal information

We may also store and use the following “special categories” of more sensitive personal information that we have collected from you:

Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
Trade union membership.
Information about your health, including any medical condition, health and sickness records.
Biometric data.
Information about criminal convictions and offences.

These “special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for storing and using this type of personal information. Our data protection policy contains details of the safeguards which we are required by law to maintain when processing such data.

We may process special categories of personal information in the following circumstances:

Where we need to carry out our legal obligations or exercise rights in connection with employment.
Where it is needed in the public interest: for example, we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equality and diversity monitoring and reporting. Where possible, we would seek to anonymise this data.
In limited circumstances, with your explicit written consent. However, we do not need your consent to use special categories of your personal information to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Who is the information shared with

We may share your data with third parties, including third-party service providers, Government departments and agencies.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.

London College of Contemporary Arts shares your data with:

Occupational Pension Scheme Trustees and Administrators.
Occupational Health providers screening
Trade Unions of which you are a member

Retention

London College of Contemporary Arts will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected.

London College of Contemporary Arts has a records retention schedule that outlines how long we will retain information.

To determine the appropriate retention period for personal data collected as part of your employment, we 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 process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further policy to you. Once you are no longer an employee we will retain and securely destroy your personal information after the following periods

12 months from date of leaving for employees; except
Payroll, tax and NIC records which must be retained required for 6 years. This is a legal requirement.

However, these periods only apply to your employment records and not for example to images and materials created and use for marketing and communication purposes (e.g. group photographs taken at away days etc.)

Your rights

Under certain circumstances, you may have the following rights in relation to your personal data:

Right 1: A right to access personal data held by us about you.

Right 2: A right to require us to rectify any inaccurate personal data held by us about you.

Right 3: A right to require us to erase personal data held by us about you. This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).

Right 4: A right to restrict our processing of personal data held by us about you. This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.

Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation.

Right 6: A right to object to our processing of personal data held by us about you.

Right 7: A right to withdraw your consent, where we are relying on it to use your personal data.

Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.

Changes to our privacy Policy

Any changes we make to this privacy policy in the future will be [posted on this page] and, where appropriate, notified to you by e-mail.

Who regulates the use of my personal information?

London College of Contemporary Arts maintains a data protection registration with the Information Commissioner's Office, the independent authority which oversees compliance with the Data Protection Legislation. London College of Contemporary Arts registration number is ZA184810 and sets out, in very general terms, the full range of purposes for which we use, staff and all other personal information. Please visit the Information Commissioners Office website for details.

Who do I contact with questions?

The data controller for the purposes of the United Kingdom General Data Protection Regulation is London College of Contemporary Arts. If you have any questions or concerns about how your personal data is used, please consult https://www.lcca.org.uk/privacy-policy/ and if you have a complaint please email London College of Contemporary Arts Data Protection Officer at: dpo@lcca.org.uk

PRIVACY POLICY

Privacy Policy

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