1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the UK GDPR we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2. Who are we?
2.1 Sanctuary Students is a trading name used by Sanctuary Student Homes Limited and Sanctuary Management Services Limited, subsidiaries of Sanctuary Housing Association.
2.2 Sanctuary Housing Association is an exempt charity and part of Sanctuary Group (“Sanctuary”), one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.
3. Our data protection officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing firstname.lastname@example.org.
4. Why are we collecting your information?
4.1 You have indicated that you are willing to provide credit support (in the form of a Guarantee) to Sanctuary to enable us to provide student accommodation services to your relative, friend or contact.
4.2 The information that you provide us during the Guarantor process is required by Sanctuary in order for us to enter into a legal contract of guarantee with you, and meet the obligations of that contract. We need to collect this information because without it we will not be able to establish and perform a contract of guarantee with you.
5. What information are we collecting?
5.1 The information that you provide to us via our web portal, in email, or in person will be used to set up and perform a contract of Guarantee between us. The information we collect may include:
Name, Address and Contact Details
A signed Guarantor Deed
Date of Birth
Proof of Address (e.g. a copy of a utility bill)
6. What we are going to do with your information
6.1 The information you provide to us will be used for the following purposes:
6.1.1 It will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 2018 and the UK GDPR;
6.1.2 It will be collected and used by us fairly and openly for the purpose of managing our contract and for debt recovery for those persons you are acting as a Guarantor for; and
6.1.3 It will allow us to make contact with you in the most appropriate way. For example, we can provide literature in large print if you have difficulty reading smaller print; or provide documents in an alternative language if English is not your preferred language.
7. What is the legal basis for using your information?
7.1 In accordance with the data protection laws, we need a "legal basis" for collecting and using information about you. There are a variety of different legal basis for processing personal data which are set out in the data protection laws.
7.2 The legal basis on which we rely in order to use the information which we collect about you, for the purposes set out in this notice will be either:
7.2.1 that it is necessary for us to provide accommodation services for the individual you are acting as a Guarantor for, and to enter into and perform the contract of Guarantee between us; and
7.2.2 that it is necessary for us to comply with a legal obligation to which we are subject.
Members of Sanctuary Group
8.1 Sanctuary is made up of a number of related companies. We will share your information with other members of our Group where necessary in order to best provide the services to you in accordance with the contract between us.
8.2 Your information will only be accessed by other Sanctuary group companies where it is necessary in accordance with your contract. The obligations which are set out in this notice shall apply to the other members of our Group to the same extent that they apply to us.
8.3 For more information on which companies make up Sanctuary, please go to Sanctuary.
Contractors and sub-contractors
8.4 It may be necessary to share information about you with our contractors and sub-contractors in order to enforce our rights under your contract of Guarantee. We will only share information about you with contractors and sub-contractors where relevant and necessary to address your individual needs. Our contractors and sub-contractors are contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 2018 and / or the UK GDPR.
8.5 Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on our behalf.
Regulators and other legal obligations
8.6 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
8.7 We may from time to time share your information with other organisations, such as:
8.7.1 Partner organisations whom we have data sharing agreements with for example University/NHS Trusts/Agencies acting on our behalf; and
8.7.2 The police for the purpose of detection and prevention of crime.
8.8 To assist with the management of our contracts we may utilise debt recovery/deposit protection and credit reference agencies where applicable.
9. Transferring your information abroad
9.1 Our payment platform provider, WPM, use sub-processors who are located outside of the UK – these sub-processers are located in the European Economic Area and the United States of America and are for the purpose of content distribution, security and data centres hosted outside of the UK. If you use our payment platform provider their processing of your personal data will involve a transfer of data outside the UK.
9.2 Whenever we transfer your personal data out of the UK in this way, we ensure a similar degree of protection is afforded to it by ensuring that we rely on an adequacy decision and/or use specific contract clauses which give personal data the same protection it has under UK law.
9.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK.
10. Security of your information
10.1 The information that you provide will be stored securely on our systems and any paper records you have completed will be shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
10.2 Only relevant members of staff will access the information you provide to us and all staff are subject to duties of confidentiality.
11. Can we use your information for any other purpose?
11.1 In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose
12. Storing your information and deleting it
12.1 We will store the personal data which you provide to us for as long as your contract of Guarantee remains in force, or for as long as the person you are acting as a Guarantor for remains a recipient of our accommodation services.
12.2 Once this is no longer the case we will review the information which we hold concerning you and determine whether there are any reasons why we need to continue holding that information. For example, there may be regulatory and/or our business best practice requirements which dictate the length of time the data is held.
12.3 Once the identified purpose comes to an end, unless there is another identifiable purpose for which it is necessary to hold on to your information, we will delete your information.
13. Your rights
13.1 In relation to the information which we hold about you, you are entitled to:
13.1.1 Ask us for access to the information;
13.1.2 Ask us to rectify the information where it is inaccurate or is incomplete;
13.1.3 Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it;
13.1.4 Ask us to limit what we do with your information;
13.1.5 Object to our use of your information and ask us to stop that use;
13.1.6 Instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another accommodation provider).
13.2 Our obligations to comply with the above rights are subject to certain exemptions.
13.3 Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
13.4 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing email@example.com.
13.5 You also have the right to complain to the Information Commissioner's Office (ICO) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.