Privacy policy

The College 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.

This notice applies to members and / or attendees at Move Imperial (https://www.imperial.ac.uk/sport/).

It is important that you read this notice, together with any other privacy notice or additional information we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Please note that this Privacy Policy should be read in conjunction with the Ethos privacy policy, College’s general Data Protection Policy and any other relevant information the College provides you with from time to time about how your data is used.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

As part of using any services, hiring facilities and/ or premises or taking part in /or providing any events and programmes, including sport scholarships, run by or provided via Sport Imperial we may collect, use and share the following personal data.

Contact Information such as;

• Name, title, addresses, telephone numbers, and personal email addresses.
• Date of birth.
• Gender.
• Emergency contact information.
• CID Number (for current Staff / Students of Imperial College London)
• CCTV footage and other information obtained through electronic means such as swipecard / attendance records.

Biographical information such as:

• Participation in events or programmes
• Visiting and workout history
• Personal targets and fitness objectives
• Wellbeing information

For scholarship athletes only, information such as:

• Previous sporting records
• Academic achievement

Financial information such as:

• Your payment history
• Bank details (scholarship athletes only)

Your information is held in the College’s secure servers, with access restricted to authorised personnel only. Please note that we do not collect or store any credit/debit card details in our database, if you have used these in transactions with the College.

We may also collect, store and use the following "special categories" of more sensitive personal information:

Information about your health, including any;

• Medical conditions,
• Health and sickness records.
• Height / weight / BMI where it forms part of a program being undertaken with us

We collect most of the personal information about you in the course of providing services to you or after we have provided services to you (e.g. feedback responses).

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 contract we have entered into with you or in order to take steps at your request prior to the entry into a contract.*
• Where we need to comply with a legal obligation.**
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.***
• Where it is necessary in order to protect your vital interests or someone else’s vital interests.****
• Where you have consented to the processing.*****

Situations in which we will use your personal information

We have indicated by [asterisks] the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.

• To operate, maintain, enhance and provide Sport Imperial’s services or services provided via Sport Imperial. This includes the running of events and programmes..*/*****
• To create / administer and oversee your membership.*/*****
• To monitor, analyse and understand the effectiveness of members’ interactions with our services; to improve our services; and to develop new products, services, features and functionality.***/*****
• To ensure we meet any and all legal obligations with regards to the service we provide to you (for example – Health and Safety legislation).**
• Paying you and, if you are an employee, deducting tax and National Insurance contributions.
• To monitor your use of our website / online portals to ensure compliance with our IT policies.**
• To monitor your use of our premises, including usage of CCTV for the prevention of crime and monitoring yours and are staff safety**/***
• To ensure the information we hold about you is up to date and accurate.***/*****
• To provide you with relevant news and special offers by email, phone or post where you have consented to receive this information.*****
• Sending and providing general communications, these would include;

- Providing you information about changes to our memberships or services that may affect you.*/***

- If you have signed up to participate in specific event or programme, to send relevant notifications.*/***

- If we are asking for survey feedback on our services.***

• Where required in case of an emergency****

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

Change of purpose

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 will keep this privacy policy under review and will make changes to it from time to time. Any significant changes we make will be posted on this page and where appropriate, contacting you directly via email. 

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.

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

• In limited circumstances, with your explicit consent.*
• Where the processing is necessary to protect your vital interests (or those of another person) where you are incapable of giving consent.**

Situations in which we will use your sensitive personal information

We will use your particularly sensitive personal information in the following ways:

• We will use information about your physical health, or disability status, to ensure your health and safety and to help you achieve your targets where they form part of a wellness / fitness program.*
• Where required in case of an emergency.**

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Why might you share my personal information with third parties?

We may share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within the College group. The following activities are carried out by third-party service providers:

We also use secure, third-party applications to carry out some of our operations including:

• Qualtrics for surveys and feedback
• XN, Advantage and Dimensions – 3rd party CRM systems and applications

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the College group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business and operations of the College. We may also need to share your personal information with a regulator or to otherwise comply with the law.

We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, 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 this case, we expect to retain details of your central membership records for the totality of your membership plus 2 years

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 notice to you.

Rights of access, correction, erasure, and restriction

We respect your right to privacy, and you can request to access, correct or delete any personal data we have obtained. In order to do this, please log a request with Sport through the service-now ASK system. We shall endeavour to action your request within the legally defined timeframe of one month.

Alternatively, please contact the College’s Data Protection Officer, details listed.

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer at:

Imperial College London Data Protection Officer Exhibition Road Faculty Building Level 4 London SW7 2AZ e-mail: [email protected]

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.