Data Protection Policy

(Last updated 11/08/2019 18:46:00)

Data Protection Principles

We (Hills Road Student Council) are committed to processing the data that you give us in accordance with its responsibilities under the GDPR. We have checked that our interests in your data are legitimate and understand our responsibility to protect your interests. We only use your data in ways you would reasonably expect unless we have a very good reason.

What we use your data for

We hold your name and email address, so we can make sure you attend Hills Road and so users can more easily send a friend request to you. Upon logging into the app, we store your Hills Road timetable so that friends you allow can view it and see when you’re free. This list of allowed friends is also stored by us. We also collect data about the devices you use to access the app and the pages you visit to help prioritise feature development and understand how people are using the app.

Data accuracy & retention

We entrust you to sign up with accurate data and will try and validate that we hold the correct data. We will hold your data until you either leave the college or ask us to explicitly remove it.

If you wish for any of your data to be removed from our systems, please contact us and we will remove it from all active processes. We cannot remove your data from backups. After clicking the start button, you agree to us using your data for better maintaining the app. By logging into the app, you are expressing consent for us to use your data to help you use the features of the app that require a login. If data which we hold about you is incorrect, please contact us via email and we will correct it. Both removal and rectification of data will be carried out in less than 30 days.

Your rights

As outlined in the Data Accuracy section you may request your data be removed. Under the GDPR you are given a set of rights. We will work to ensure that all these rights are given to you. If you feel that a right has been violated and would like to complain, please contact us.

Third parties & foreign law

We share your data with Google for analytics and authentication purposes. For Google to process this data it may be sent to the United States of America. We will ensure that we comply with both legalisations for the UK and USA.

Your requirements to provide data

Using the app requires us to provide you with a service. This service cannot and will not be provided unless all data which is requested is given to the Hills Road Student Council. We will be unable to allow you to use the app unless you provide this data.

Data Security

We are committed to ensuring that your data is kept secure. We will use modern and secure standards of data encryption for storing and transmitting sensitive data.

Processing Minors information

We are aware that a large percentage of the users of this app are minors. We design our processing with children in mind from the outset and use a data protection by design and by default approach. When relying on ‘necessary for the performance of a contract’, we consider the child’s competence to understand what they are agreeing to, and to enter into a contract. When relying on consent, we make sure that the child understands what they are consenting to, and we do not exploit any imbalance of power in the relationship between us. When relying upon ‘legitimate interests’, we take responsibility for identifying the risks and consequences of the processing and put age-appropriate safeguards in place.

Data Protection Officer

As we are not an incorporated entity, we are not legally required to have a DPO or a data controller. However, you may contact us with any queries and we will attempt to resolve the role of a DPO.