Centurion Student Services UK Ltd operating under the brand name dwell student living, and/or its related corporations (each, “dwell”, the “Company”, the “Group”, “we”, “us” or “our”) collectively or singularly as the context requires, recognises the importance of protecting Personal Data.
dwell adopts a pragmatic approach in our business conduct. dwell collects Personal Data only for what is required in business or in activities conducted by our organisation and will properly destroy the Personal Data once there is no business or legal purpose for retaining it. We do not collect Personal Data randomly or indiscriminately without purpose.
dwell does not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Data. This does not affect any rights which Centurion may have at law in connection with the collection, use or disclosure of your Personal Data.
i. your name, NI number, passport number or other identification numbers, telephone number(s), mailing address, email addresses, date of birth, title, gender, [marital status] and any other information relating to you which has been provided by you or on your behalf to us in any form or application submitted to us (which includes student accommodation application forms and job application forms) or in any other interaction you may have with us either directly or indirectly;
ii. information about your use of our websites and services, including cookies, IP addresses, email subscription, and membership details (where applicable);
iii. your Curriculum Vitae, employment history, testimonials, and referrals, previously drawn income, education background, medical history, conditions and disabilities (including any doctors notes/letters you provide to us), and legal and bankruptcy history (if applicable); and
iv. your payment-related information, such as your bank account details (where applicable) and transaction details;
v. your credit history and credit score.
1.3 we rely on the following lawful basis to process your personal data:
|Consent||You have given your express consent for us to process your personal data for a specific purpose.|
|Contract||The processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you.|
|Legal obligation||The processing is necessary for us to comply with legal or regulatory obligation.|
|Legitimate interests||The processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our Site. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we
will not use your personal data on this basis where such impact outweighs our interest.
Further details on how and the circumstances in which we use your Personal Data are set out in part 3 below.
i. when you submit soft or hard copy forms relating to any of our products or services;
ii. when you register for or use any of our services on websites owned or operated by dwell or when you register as a member of websites owned or operated by us;
iii. when you interact with dwell’s employees and staff, including during face-to-face meetings or by way of the telephone;
iv. when you enter into a contract with us or use or purchase our services or products;
v. when you establish any online accounts with us;
vi. when you submit a request for us to contact you;
vii. when you respond to our request to submit additional Personal Data;
viii. when you subscribe or ask to be included in an email or other mailing list;
ix. when you respond to our promotions and other marketing and publicity initiatives;
x. when you respond to our market surveys;
xi. when you submit a job application or a scholarship application;
xii. when we receive references from business partners and third parties;
xiii. when you submit your Personal Data to us for any other reason;
xv. we may receive personal data about you from third parties and public sources, including (as applicable) your university or higher education provider, electoral registers, credit reference agencies, analytics providers such as google these may be based both inside and outside the UK.
2.2 If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children, parents, next of kin and/or guarantor details) to us, you represent and warrant that you have obtained the consent of that third party for the collection, use and disclosure of their Personal Data for the purposes set out above.
2.3 If you provide any special categories or personal data to us when completing our forms or applications, you are providing your explicit consent to us processing such Personal Data for the purpose of the considering the content of such forms and or progressing your application and other matters that are ancillary to such forms/application. If you do not wish us to use such categories of personal data in this manner please do not provide the special categories of data to us.
3.1 dwell’s goal is to understand your needs and provide you with products and services that you require. To do this effectively, dwell needs to collect certain Personal Data.
3.2 In general, dwell may collect, use and disclose your Personal Data for the following purposes:
a. to provide you with the products or services that have been purchased or requested;
b. to help manage the delivery of and enhance our products and services, including analysing current customer needs and identifying potential future needs;
c. updating your records in our databases; monitoring and maintaining a copy of your record of previous transactions with dwell;
d. to communicate and respond to your queries, requests and complaints;
e. to provide ongoing marketing and publicity information about our products and services and upcoming events which may be of interest to you and you have not unsubscribed from our mailing list or withdrawn your consent;
f. to ascertain security clearances and access controls at dwell facilities;
g. for security, surveillance and employee monitoring purposes;
h. to handle disputes and complaints and conduct and facilitate investigations and proceedings when required;
i. to protect and enforce dwell’s contractual and legal rights and obligations;
j. to prevent, detect and investigate crime, and to analyze and manage other commercial risks;
k. to manage the infrastructure and business operations of dwell and to comply with other dwell internal policies and procedures;
l. to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving dwell; and m. to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.
3.3 We may process your Personal Data (without your knowledge or consent) where this is required or permitted by law.
3.4 In addition, dwell may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
a. If you have a customer account with us, are a prospective customer or a customer:
i. to process your application for a dwell account;
ii. to maintain and administer your dwell account with us;
iii. to verify your personal particulars and process payment requests in relation to provision of products and services, which you may be entitled to, or which you may have requested for;
iv. to provide you with the products and services which you have may have entered into a contract with dwell for or purchased from dwell;
v. to communicate changes and developments to dwells policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
vi. to send marketing and publicity emails which may of interest to you and you have not unsubscribed from our mailing list or withdrawn your consent; vii. to resolve complaints and handle requests and enquiries;
viii. to conduct market research for statistical, profiling, statistical analysis and planning for the improvement of dwell’s products and services provided to you; and
ix. to process your Personal Data in relation to any of the purposes stated above.
b. If you use download or use any of our mobile applications (“apps”):
i. to process your application for subscription services if such services provided for in the apps;
ii. to administer and maintain your account with us;
iii. to verify and process your personal particulars and process payment requests in relation to provision of products and services connected to the app;
iv. to provide you with the goods and services which you have purchased or signed up for via the app;
v. to communicate changes and developments to dwell’s policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
vi. to resolve complaints and handling requests and enquiries; vii. to conduct market research for statistical, profiling, statistical analysis and planning for the improvement of dwell’s products and services provided to you; and
viii. to process your Personal Data in relation to any of the purposes stated above.
c. If you are a prospective tenant/resident or a tenant/resident or a guarantor or next of kin of a tenant/prospective tenant:
i. to administer and conduct appropriate due diligence and/or credit checks against you;
ii. to prepare the relevant dwell lease and/or licence documentation and any other documents as may be required;
iii. to administer the relevant leases or licences, including to liaise with you (whether you are the prospective tenant/resident or a tenant/resident, guarantor or next of kin);
iv. to administer and perform financial transactions such as rental payments, including where there are outstanding rental payments due to us, liaising with the tenant/residents or prospective tenant’s/resident’s University or higher education provider as part of our debt recovery procedures;
v. to resolve complaints and handling requests and enquiries and this may include us sharing your personal data with the tenant/resident’s University or higher education provider;
vi. to communicate changes and developments to dwell’s policies, terms and conditions and other administrative information; and
vii. any other purpose related to any of the above.
d. If you are a vendor, a prospective vendor or a contractor:
i. to evaluate your proposals for working with dwell and to conduct relevant background checks on you;
ii. to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or security concerns; and
iii. any other purpose relating to any of the above.
e. If you submit a job application to us as a candidate for employment:
i. to evaluate your suitability for employment with dwell, including pre-recruitment checks and checking on provided references for more detailed background screening/vetting;
ii. to organise training and staff development programs;
iii. to maintain and manage employee relations, including annual performance assessments/appraisals;
iv. to administer and manage benefits and payroll processing; v. to provide you with the relevant/correct tools as required for you to do carry out your job responsibilities;
vi. to resolve complaints and handling requests and enquiries;
vii. to communicate dwell’s policies and processes, codes of conduct and standard operating procedures, including for business continuity purposes; and
viii. any other purposes relating to the aforesaid.
3.5 In relation to particular products or services or during your interactions with dwell, we may also notify or have specifically notified you of other purposes for which dwell collects, uses or discloses your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.6 Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:
a. other divisions, business units or entities within dwell;
b. dwell’s joint venture/alliance partners;
c. agents, contractors, sub-contractors, third party service providers and specialist advisers contracted by dwell to provide administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
d. any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with dwell or not;
e. insurers or insurance investigators and credit providers;
f. in the event of default or disputes, any debt collection agencies or dispute resolution centres;
g. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the whole dwell or entities within the dwell;
h. dwell’s professional advisors such as our auditors and lawyers;
i. relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
j. anyone to whom we may transfer our rights and obligations;
k. banks, credit card companies and their respective service providers;
l. the tenant/resident, prospective tenant/resident’s University or higher education provider;
m. the tenant/resident or prospective tenant/resident that has provided your personal data as part of their application and you are nominated as their guarantor or next of kin; and
n. any other party as may be consented to by you, as specified by that individual or in the applicable contract.
dwell requires that third party organisations which handle or obtain Personal Data, such as service providers to dwell, acknowledge the confidentiality and sensitivity of this personal data, undertake to respect any individual’s right to privacy and comply with the GDPR. dwell also requires that these organisations use this information only for limited purposes which have been agreed upon and follow dwell’s reasonable directions with respect to this information.
4.1 dwell endeavours to ensure that Personal Data stored by us is accurate and up-to-date. dwell also understands that Personal Data may change frequently, such as changes of address and other personal circumstances. As such, dwell encourages you to contact the DPO at firstname.lastname@example.org to update your Personal Data. Incomplete or outdated Personal Data may result in our inability to provide you with the products and services you have requested.
4.2 If we are required by law or under the terms of a contract we have with you to collect your Personal Data and you fail to provide it we may:
a. not be able to enter into or perform the contract with you; or
b. have to cancel a product and/or the contract (as applicable); and we will notify you of this at the time.
Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent. All electronic storage and transmission of personal data is secured and encrypted with appropriate security technologies. Although every reasonable effort has been made to ensure that all personal data will be so protected, dwell cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.
8.2 Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a. we will only transfer Personal Data to countries that have been deemed to provide an adequate level of protection for personal data;
b. we use specific contracts which give personal data the same protection it has in the UK with our services providers.
9.1 You have the following legal rights in relation to your Personal Data:
|Access your data||You can ask for access to and a copy of your Personal Data and can check we are lawfully processing it.|
|Correction||You can ask us to correct any incomplete or inaccurate Personal Data we hold about you.|
|Erasure||You can ask us to delete or remove your Personal Data where: there is no good reason for us continuing to process it;
you have successfully exercised your right to object (see below); we may have processed your information unlawfully; or
we are required to erase your personal data to comply with local law. We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request.
|Object||You can object to the processing of your Personal Data where: we are relying on our legitimate interest (or those of a third party) as the basis for processing your Personal Data, if you feel it impacts on your fundamental rights and freedoms; we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and in such circumstances, we can continue to process your Personal Data for such purposes.|
|Restrict processing||You can ask us to suspend or restrict the processing of your Personal Data, if: you want us to establish the accuracy of your Personal Data; our use of your Personal Data is unlawful, but you do not want us to erase it; you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or you have objected to our use of your Personal Data, but we need to verify whether we have overriding legitimate grounds to use it.|
|Request a transfer||You can request a transfer of your Personal Data which is held in an automated manner and which you provided your consent for us to process such Personal Data or which we need to process to perform our contract with you, to you or a third party. We will provide your Personal Data in a structured, commonly used, machine-readable format.|
|Withdraw your consent||You can withdraw your consent at any time (where we are relying on consent to process your Personal Data). This does not affect the lawfulness of any processing carried out before you withdraw your consent.|
9.2 Please contact us via email@example.com should you wish to exercise any of your rights. Your email should identify yourself and state which Personal Data and information about its use and / or disclosure is requested. You will not have to pay a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive. In which case, we may charge a reasonable fee for this information or refuse to comply with your request.
9.3 We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that Personal Data is not disclosed to any person who does not have the right to receive it.
9.4 We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests it may take us longer to respond. In this case, we will notify you and keep you updated.
11.1 If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested), please contact the designated Data Protection Officers for the respective business units as follows:
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK
regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with
your concerns before you approach the ICO so please contact us in the first instance.
Published date: Jan 17 2023
Effective date: Jan 17, 2023