Imperial White City Incubator Privacy Notice
What is the purpose of this document?
Imperial White City Incubator Limited (“IWCI”) and its service provider Imperial Innovations Ltd (“Innovations”; collectively “White City Incubator”) are committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the applicable data protection legislation (the Data Protection Act 1998 until 24 May 2018 and the General Data Protection Regulations (the “GDPR”) from 25 May 2018. As a wholly owned subsidiary of Imperial College London (“the College” or “Imperial”), IWCI abides by the College’s Data Protection Policy.
White City Incubator 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 Incubator programme applicants, licensees, Virtual members, attendees of courses / workshops and accelerator programmes. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice 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.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
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).
There are "special categories" of more sensitive personal data which require a higher level of protection.
We may collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Date of birth.
- Company details including nature of business, names of directors, company number, nature of business, shareholders and employee contact details as above
- Company financials including past and current turnover, projections, milestones, and investment history
- Bank account details and tax status information.
- Intellectual property ownership
- Location of employment or workplace.
- Copy of driving licence / passport and utility bill
- Supportive documents for Incubator programme application such as CV’s for directors of company, application forms and business plans
- Nature and number of courses/workshops attended and the feedback associated with them
We may also collect, store and use the following "special categories" of more sensitive personal information:
- Information about your race or ethnicity
How is your personal information collected?
We collect most of the personal information about you through application forms to our various programmes and the via email and website requests for further information of our services. We also collect business metrics and satisfaction ratings. These are through on line and digital forms submitted to us electronically or in person at the White City Incubator in the course of providing services to you or after we have provided services to you (e.g. feedback responses). We may sometimes collect additional information from third parties including Companies House and, credit reference agencies or other background check agencies
How we will use information about you and the legal basis for processing your data under the GDPR
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 the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
- 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.
Situations in which we will use your personal information
We need all the categories of information in the list above (see “The kind of information we hold about you”) primarily to allow us to perform our contract with you, record the impact of our support and to enable us to comply with legal obligations such as HMRC money laundering supervision. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. 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 provide you with the information and services that you request from us: * Incubation, events, Accelerators and other support programmes
- To contact you in relation to your application and/or licence or virtual membership experience. Including for the purposes of feedback.
- To ensure we meet any and all legal obligations with regards to the service we provide to you for the duration of your licence or use of our service
- To administer and fulfil requirements as agreed in the licence document and any related terms and conditions
- To notify you about changes to our service.
- Making a decision about your application
- Checking the company is correctly registered and directors not disqualified
- Administering the contract we have entered into with you.
- Business management and planning, including accounting and auditing.
- Conducting company reviews and updates to help inform our board on progress the company is making within the Incubator programme
- Dealing with legal disputes involving you, or other or other clients, workers and contractors, including accidents at work.
- Complying with health and safety obligations.
- To prevent fraud and prevent money laundering.
- 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.
- Equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, and we may be prevented from complying with our legal obligations such as Money laundering supervision.
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.
How we use particularly sensitive personal information
"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 written consent.
- Where it is necessary in the context of employment law, or laws relating to social security and social protection.
- Where the processing is necessary to protect your vital interests (or those of another person) where you are incapable of giving consent.
- Where the processing is carried out in the course of our legitimate interests, with respect to our own members, former members, or persons with whom we have regular contact in connection with our purposes.
- Where the processing relates to personal data which have been manifestly made public by you.
- Where the processing is necessary for the establishment, exercise or defence of legal claims, or for courts acting in their judicial capacity.
- Where the processing is necessary for reasons of substantial public interest, and occurs on the basis of a law that is, inter alia, proportionate to the aim pursued and protects your rights as a data subject.
We will use your particularly sensitive personal information in the following ways:
- We will use information relating to identity which may include taking a copy of your passport and a utility bill to comply with UK Money laundering laws.
- We will use information about your sex / race or national or ethnic origin, to ensure meaningful equal opportunity monitoring and reporting.
Do we need your consent?
We do not need your consent to process sensitive personal information if we use special categories of your personal information to as detailed in the preceding two sections.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
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.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties, including third-party service providers and other entities in the College group.
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 EU.
If we do, you can expect a similar degree of protection in respect of your personal information.
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 and their subcontractors, such as Abtec (to provide ICT services). The following activities are carried out by third-party service providers: Landlord duties at the Incubator, Incubator management, maintenance and building work, ICT services
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 may transfer the personal information we collect about you to the following country outside the European Economic Area:
United States of America
in order to perform our contract with you. The process of sharing your information with USA is in accordance with “Privacy Shield” (https://www.privacyshield.gov/participant_search)
This means that the country to which we transfer your data is deemed to provide an adequate level of protection for your personal information.
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. Details of retention periods are as follows:
- Personal information indefinitely unless you withdraw your consent.
- Licenses and other contracts will be kept for at least 10 years from the date of expiry of such contract.
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 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
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the College’s Data Protection Officer in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the College’s Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
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
Faculty Building Level 4
London SW7 2AZ
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.
Changes to this privacy notice
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.