Who we are
The University of St Andrews Students’ Association (‘the Students’ Association’) offers a range of services to students of the University of St Andrews, who are automatically members of the Students’ Association. We are here to make the student experience as strong as it can be, provide services you need and to represent your views to the University and beyond. We operate premises in St Andrews at St Mary’s Place, St Andrews, Fife KY16 9UZ. We are a charity registered in Scotland (SCO19883) regulated by the Scottish Charity Regulator (OSCR).
This Policy explains when and why we collect personal information about our members and other people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
The Students’ Association is a “data controller”. 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.
The Students’ Association is fully committed to handling personal information in accordance with data protection legislation and data protection and information security best practices. This means that your personal information will be:
- Processed lawfully, fairly, and in a transparent manner.
- Collected for specified, explicit and legitimate purposes.
- Only collected so far as required for our lawful purposes.
- As accurate and up to date as possible.
- Retained for a reasonable period of time, in accordance with retention policies.
- Processed in a manner which ensures an appropriate level of security.
Whether through this notice or otherwise, we hope to ensure that everyone has a good understanding of why we processes personal information and, where we do, the rights they may have.
How do we collect personal information?
As students at the University are automatically enrolled as members of the Students’ Association we obtain information about our members directly from the University as part of the matriculation process. We also obtain information about you when you use our website, for example, when you contact us about events and room bookings, to enquire about commercial services, to purchase goods or tickets from our online shop, and if you register to receive our newsletter. In addition, like most organisations that handle personal information, there are various ways in which we collect information from the people we deal with.
- Email and written correspondence.
- Telephone discussions.
- Social media.
- Application forms and other information requests.
- Direct contact at the Students Association and elsewhere.
In nearly all instances, it should be obvious to you when we are collecting your personal data.
What personal information do we collect?
The personal information most commonly collected is as follows:
- Contact details (including term time and home address, business addresses, email – both University and personal, telephone number).
- For visitors to our website – your IP address, and information regarding what pages are accessed and when.
- If you make a purchase via our website, your card information is not held by us, it is collected by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions, as explained below.
- Date of birth.
- Records of enquiries, meetings and other direct engagement.
- Copies of physical and electronic correspondence.
- Images obtained from our CCTV system for the purposes of crime detection and health and safety.
How is your information used?
We may use your information to:
- keep your membership details up to date;
- to carry out our obligations arising from any contracts entered into by you and us;
- dealing with entries into a competition;
- seek your views or comments on the services we provide;
- notify you of changes to our services; and
- send you communications which you have requested and that may be of interest to you. These may include information about events, campaigns, societies, appeals, other fundraising activities or promotions of our services; and
- process a room booking.
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example the collection of Gift Aid). We will hold your personal information on our systems for as long as is necessary for the relevant activity, such as membership or for room / event bookings, or as long as is set out in any relevant contract you hold with us.
What is the lawful basis for the Students Association’s processing activities?
We will only process personal information where we believe we have a lawful basis to do so. The basis for processing will vary from activity to activity. In some instances, processing may have more than one lawful basis.
The following information below summarises the basis on which we process personal information.
Examples of processing activities
Processing is necessary for us to meet our legitimate interests as a provider of certain services to our members, including:
- the maintenance of our membership database, and delivery of services we provide to our members, guests and visitors.
- General administration for maintaining our membership database.
- Corresponding with members in respect of the delivery of our services within the terms of our conditions of membership.
- Regulatory activity (e.g. complying with the requirements of OSCR, and fulfilling our responsibilities with regards applicable legislation).
- Providing members with relevant news and updates which may be of interest to them
- Processing carried out in the public interest
- Regulatory activity (e.g. complying with requirements of OSCR and fulfilling our responsibilities with regards applicable legislation).
- Processing necessary for us to comply with our legal obligations.
- Providing information to statutory bodies (e.g. HMRC).
- Providing information to law enforcement agencies.
- Providing members, guests and customers with relevant news and updates, marketing and other information.
- Use of financial, personal or sensitive information relevant to the delivery of services provided to our members / guests / customers.
- Processing is necessary for the performance of a contract with our staff members or suppliers.
- Processing is necessary for the purposes of carrying out our obligations as a data controller with respect:
- our staff members in the field of employment; and
- where we use third party suppliers for processing data, such as images captured during our events and published on our website and social media sites.
Do we share personal data with third parties?
We will not sell or rent your information to third parties and we will not share your information with third parties for marketing purposes. However, in certain circumstances the processing activities set out above will require us to share personal information with third parties. Whenever we share personal data, we take all reasonable steps to ensure it will be handled appropriately and securely by the third party. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
When you are purchasing event tickets and merchandise via our website, your transaction is processed using an encrypyted payment system which ensures that card data is captured and processed securely. If you have questions regarding secure transactions, please contact us.
The following is a list of the main third parties with whom we share personal information:
- Oversight regulators and statutory bodies (e.g. HMRC and OSCR).
- Local authorities and health care agencies, such as the NHS.
- Software providers which allow us to operate efficient digital processes, including: Sage and Sage Pay
For practical reasons, this is an indicative, but not exhaustive list. Please also note that the list may be updated from time to time.
How long do we retain personal information?
The periods for which we retain personal information depends on the purpose for which the information was obtained but, in general terms, we will retain personal data for so long as required by law, or as may be required for record keeping and legal claims purposes.
Where do we store personal information?
Personal information is mostly processed by our staff at the Students’ Association in St Andrews. To allow us to operate efficient digital processes, we need to store information in servers owned by the University which are located in the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
We use Sage Pay for our online payment processing. Sage pay holds users personal information on servers located in the United States of America (the U.S.), which is recognised by the EU as an 'adequate' country (i.e. safe country) to receive and process EU personal data, pursuant to European Commission Decision 2013/65/EU. For EU residents, this means that your personal information will be transferred to the U.S. Sage Pay has in place transfer mechanisms that satisfy the requirements relating to the transfer of data from the European Union to the U.S.
By entering personal information into the Services, you consent to that personal information being hosted on servers located in the U.S. While your personal information will be stored on servers located in the U.S., it will remain within Sage Pay’s effective control at all times. Each data hosting provider’s role is limited to providing a hosting and storage service to Sage Pay, and Sage Pay have taken steps to ensure that its data hosting providers do not have access to, and use the necessary level of protection for, your personal information. They do not control, and are not permitted to access or use your personal information, except for the limited purpose of storing the information.
To ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection: For example, a binding data sharing agreement which includes data access, data security and information sharing clauses. If you require further information about these protective measures, you can request it using the contact details below.
We may collect information about the computer or device which is used to access our website. We use this information to improve the user experience and to help us better understand the ways in which our website is used. This may include information about:
- The computer or device type.
- IP address.
- Operating system.
- Browser type and version.
- Time zone setting and browser plug-in types and versions.
This is statistical data about our users' browsing actions and patterns. It is collected on an anonymous, aggregated basis, and does not identify individual users.
Security precautions in place to protect the loss, misuse or alteration of your information
When you give us personal information, we take steps to ensure that it’s treated securely. Any personal information submitted on our website is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the URL bar of the web browser such as Microsoft Internet Explorer, or the web address will start https://
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We may analyse the personal information which you have submitted to create a profile of your interests and preferences so that we can contact you with information relevant to you. We do not make use of additional information about you from external sources. In some circumstances we may use your personal information to detect and reduce fraud and credit risk.
Our website makes use of cookie files to distinguish you from other users of our site, to provide you with a bespoke user experience tailored to your individual preferences. A cookie file (a small file of letters and numbers) will be placed on your computer or other access device each time you visit our site.
We also use analytical cookie files. These allow us to recognise and count the number of visitors to our site and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
If you wish to delete any such cookie files, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Our cookies will contain the domain name standrewsSA.uk within the file name.
You may refuse to accept cookie files when visiting our site, by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you choose this setting, you may not get an optimal web site experience and be unable to access certain parts of our site.
Our website and emails may contain links to other websites, such as the University or carefully selected commercial partners. We are not responsible for the content or practices of these other sites and we recommend that you check their own privacy policies.
Your rights where we are processing your information
The law in the UK gives certain rights to individuals whose information is being processed by a third party. The following is a quick summary of these rights:
- Access to your information – you have the right to request a copy of the personal information about you that we hold.
- Correcting your information – we want to make sure that your personal information is accurate, complete, and up to date, and so you may ask us to correct any personal information about you that you believe does not meet these standards.
- Deletion of your information – you have the right to ask us to delete personal information about you where:
- You consider that we no longer require the information for the purposes for which it was obtained
- We are using that information with your consent and you have withdrawn your consent – see ‘withdrawing consent to using your information’ below.
- You have validly objected to our use of your personal information – see ‘objecting to how we may use your information’ below.
- Our use of your personal information is contrary to law or our other legal obligations.
- Objecting to how we may use your information – you have the right at any time to require us to stop using your personal information for marketing or newsletter purposes. In addition, where we use your personal information to perform tasks carried out in the public interest, or in exercising official authority vested in us then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
- Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold, or assessing the validity of any objection you have made to our use of your information. The right might also apply if we no longer have a basis for using your personal information but you don't want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims, or where there are other public interest grounds to do so.
- Withdrawing consent using your information – where we use your personal information with your consent, you may withdraw that consent at any time, and we will stop using your personal information for the purpose(s) for which consent was given.
Please contact us in any of the ways set out in the ‘contact information and further advice’ section if you wish to exercise any of these rights.
When in the Association we will not take a photo of an individual or small group without consent. If there are group shots of people these will be taken at our discretion. Photos taken within the Association may be used on our social media channels and for future publicity. However if you would like a photo of yourself removed from any of our social media channels please contact us and we will remove it as soon as possible. If you would like removed from any printed publicity please contact us and we will remove your image from any future print runs. Please note we may also share photos with third parties such as the University or media.
We keep this notice under regular review and will place any updates on this website. Paper copies of the privacy statement may also be obtained by emailing firstname.lastname@example.org in writing to our office at University of St Andrews Students’ Association, St Mary’s Place, St Andrews, Fife KY16 9UZ.
This privacy statement was last updated on 18/05/2018
You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the services we offer then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information at matriculation, or you can opt out at any time by clicking the following link www.yourunion.net/contactoptions/
We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us by email: email@example.com or telephone on 01334 462700.
Contact information and further advice
If you have any questions which are not covered in this notice, we suggest that you email us through firstname.lastname@example.org. To help us deal with your query as quickly as possible, we recommend that you include the following in the email subject ‘FAO Data Protection Lead’. If you would prefer to submit your questions in writing, please write to us at University of St Andrews Students’ Association, St Mary’s Place, St Andrews, Fife KY16 9UZ.Kingdom addressing your letter to the Data Protection Lead.
While we seek to resolve directly all complaints about how we handle personal information, you also have the right to lodge a complaint with the Information Commissioner's Office, whose contact details are as follows:
Information Commissioner's Office - Scotland
45 Melville Street
Telephone - 0303 123 1115
Email - Scotland@ico.org.uk