Brasenose College GDPR ROPA – Student / Visiting Student / Related Functions
Version 1.5 (Reviewed May 2024)
| ID | Category of personal data | Source of the data | Why we process it | How long we keep it | Our lawful basis for processing | Details relating to lawful basis (where applicable) | Special category / public interest / criminal data |
|---|---|---|---|---|---|---|---|
| 1 | Your dates of attendance, course of study and results, awards, scholarships, prizes, student status (including visiting/full-time/part-time) and your official photograph. | Generated by us; obtained from the University of Oxford. | To administer your course, record results, verify attendance and maintain College archives. | Permanently. | Performance of contract; public task; legitimate interests. | The College has a legitimate interest in maintaining academic and historic student records. | |
| 2 | Information about your health, dietary requirements or disabilities, and decisions taking that information into account. | Obtained from you, the University, or authorised third parties (e.g. medical professionals). | To make reasonable adjustments, take account of dietary or health needs, and ensure wellbeing. | 25 years after leaving or permanently if archived. | Legitimate interests; legal obligation. | The College has a legitimate interest in supporting equality and wellbeing; also required by equality and safety law. | Substantial public interest under the UK Data Protection Act 2018; Equality Act and health/safety compliance. |
| 3 | Information about ethnicity, religion, sexuality and/or health processed for equality monitoring. | Obtained from you or the University. | For equality monitoring and reporting. | 25 years after leaving or permanently if archived. | Legitimate interests. | Monitoring and promoting equality of opportunity. | Substantial public interest under the Data Protection Act 2018. |
| 4 | Records of academic performance, attendance and self-assessment. | Generated by tutors and obtained from you. | To guide and assess progress during your studies. | 25 years after leaving or permanently if archived. | Performance of contract; legitimate interests. | To provide academic feedback and progression support. | |
| 5 | Requests for special exam arrangements, extensions or extenuating circumstances and related decisions. | Obtained from and generated about you. | To review and decide academic requests per College policy. | 25 years after leaving or permanently if archived. | Performance of contract; legitimate interests; public task; legal obligation. | Ensuring fair and compliant decision-making under College procedures. | Substantial public interest under Data Protection Act; Equality Act compliance. |
| 6 | Records of student helpers/hosts at open days, including name, contact details, hours worked, and payments. | Obtained from you. | To record and manage open-day helpers and payments/benefits. | 6 months after leaving, or longer if required for accounting. | Performance of contract (if paid); legitimate interests. | Legitimate interest in students assisting at outreach events. | |
| 7 | Accommodation tenancy/licence details, duration, payments and allocation. | Generated by the College. | To provide accommodation and manage related records. | 7 years after tenancy/licence ends. | Performance of contract; legitimate interests. | Interest in providing and managing accommodation safely. | |
| 8 | Accommodation requests, guests, dependants, inventories, lost property and safety records. | Obtained from you. | To manage accommodation safely and provide services. | 7 years after tenancy/licence ends. | Performance of contract; legitimate interests. | To maintain safe and efficient accommodation operations. | |
| 9 | Room/facility bookings for student events, including compliance with freedom of speech law. | Obtained from and generated about you. | To administer room bookings and ensure legal compliance. | 7 years after tenancy/licence ends. | Legitimate interests; public task; legal obligation. | Complying with the Education (No 2) Act 1986. | Substantial public interest under Data Protection Act 2018. |
| 10 | Financial and payment records (“battels”) including banking and card details. | Obtained from you and generated by us. | To provide and account for services such as fees, accommodation, and meals. | Until settled, or six months after leaving; permanently if archived. | Performance of contract. | ||
| 11 | University fee collection information — details of fees due to the University, received and transferred to them by the College. | Generated by the College; obtained from the University of Oxford. | To collect University fees on behalf of the University and maintain proper financial records. | 25 years after end of study or permanently if archived. | Performance of contract with the University; legitimate interests. | The University has a legitimate interest in collecting fees due to it. | |
| 12 | Application and admission data submitted to UCAS, University or College, including academic and employment history, predicted grades, written work, research proposals, references, and feedback. | Obtained from you, the University, and referees; generated by us. | To record admission decisions, administer your application and course, and provide references. | 25 years after leaving or permanently if archived. | Performance of contract; legitimate interests. | To maintain records for reference requests and academic history. | |
| 13 | Criminal records or allegations declared or reported, and results of Disclosure and Barring Service (DBS) checks. | Obtained from you, third parties, or generated by us. | To ensure College safety and compliance with safeguarding obligations. | DBS data: 6 months from receipt; other criminal records retained 6 years after leaving, or permanently if archived. | Performance of contract; legitimate interests. | The College has a legitimate interest in safeguarding members and meeting legal requirements. | Substantial public interest under Data Protection Act 2018; compliance with health, safety and equality law. |
| 14 | Fee status, funding, residence, and guarantor or sponsor information (e.g. loans, grants, parental support evidence). | Obtained from you, the University, and third parties (parents, sponsors). | To determine fees payable and confirm financial arrangements for study. | 25 years after leaving or permanently if archived. | Performance of contract; legitimate interests; legal obligation. | Legislation sets fees based on residence; the College must ensure students can meet costs. | |
| 15 | Disciplinary, harassment or grievance records, including complaints, investigations, decisions and appeals. | Obtained from you, the University, third parties, or generated by us. | To maintain standards of conduct and behaviour for all College members. | 25 years after leaving or permanently if archived. | Performance of contract; legitimate interests. | The College has a legitimate interest in operating disciplinary and grievance procedures fairly. | Substantial public interest under the Data Protection Act 2018; Equality Act 2010 compliance. |
| 16 | Records of cultural life — photographs, written records, participation in events, sports, clubs, choirs and societies. | Obtained from you or third parties; generated by the College. | To record and celebrate College cultural life and achievements, and to maintain College archives. | Permanently. | Legitimate interests. | To preserve a record of College life for current and future students and researchers. | |
| 17 | Meal bookings and attendance records, including table plans for formal dinners. | Obtained from you. | To manage catering services, charge correctly, and plan formal events. | 3 months after the end of the academic year you leave. | Performance of contract. | ||
| 18 | Records created for legal or statutory compliance (e.g. data protection, freedom of information, safeguarding, H&S, legal claims, audit records). | Generated by the College. | To document compliance and meet legal or regulatory requirements. | 6 years from creation, unless extended for legal reasons. | Legal obligation. | To comply with law and accountability standards. | Substantial public interest under Data Protection Act 2018; compliance with statutory duties. |
| 19 | Right to study documentation — passport, visa, biometric permit, and attendance records. | Obtained from you and the University. | To verify entitlement to study and report to immigration authorities as required. | 25 years after leaving or permanently if archived. | Performance of contract; legal obligation; legitimate interests. | College, University and students share an interest in immigration law compliance. | |
| 20 | Visa application and extension assistance, including passport and visa copies shared with University and Home Office. | Obtained from you; generated by the College. | To assist international students with visa processes and ensure compliance with immigration law. | 25 years after leaving or permanently if archived. | Performance of contract; legal obligation; explicit consent. | ||
| 21 | Emergency contact details. | Obtained from you. | To contact someone you nominate in the event of an emergency. | 6 years after the end of the academic year in which you leave. | Legitimate interests. | College and students share an interest in emergency communication arrangements. | |
| 22 | Contextual admissions information for undergraduate applications (e.g. school performance, postcode, care background). | Obtained from the University of Oxford. | To support fair admissions processes and comply with Office for Students access agreements. | 25 years after leaving or permanently if archived. | Legitimate interests; legal obligation. | College has a legitimate interest in widening participation and fair access. | |
| 23 | Contractual details, tutor information, University card number, contact details, and any disclosed caring responsibilities. | Obtained from you and generated by us. | To administer your course and take account of your personal circumstances. | 25 years after leaving or permanently if archived. | Performance of contract; legitimate interests. | College has an interest in considering individual circumstances when providing teaching. | |
| 24 | Records of attendance and participation in College committees (where students are members). | Generated by the College. | To record committee attendance and participation in College governance. | Permanent in archives if in minutes; otherwise 6 years after leaving. | Legitimate interests. | College has a legitimate interest in recording student representation in governance. | |
| 25 | Applications for and decisions about financial support (scholarships, bursaries, hardship funds), including correspondence with funders. | Obtained from you; generated by us; sometimes received from third parties. | To assess financial support applications and promote participation from all backgrounds. | 25 years after leaving or permanently if archived. | Legitimate interests; public task. | College has an interest in offering and recording financial support for students. | |
| 26 | Degree ceremony records, including attendance, catering requirements and guest names. | Obtained from you; generated by us. | To organise and operate degree ceremonies. | 1 year after the ceremony, or permanently if archived. | Performance of contract. | ||
| 27 | Prize, scholarship and award nominations and decisions (College-funded). | Obtained from you; generated by us. | To determine recipients of scholarships, prizes and awards. | 25 years after leaving; record of award kept permanently. | Legitimate interests. | College has an interest in recognising student achievement and fulfilling benefactors’ wishes. | |
| 28 | Prize, scholarship and award nominations and decisions (third-party funded). | Obtained from you; generated by us; provided by third-party donors. | To determine recipients of awards funded by external benefactors. | 25 years after leaving; record of award kept permanently. | Legitimate interests. | College has an interest in fulfilling donor wishes and recognising student achievement. | |
| 29 | Student debtor records, recovery actions and related decisions. | Generated by the College. | To manage debt collection and consider financial support or disciplinary actions. | Until debt settled or final decision; otherwise 6 years after leaving, or permanently if archived. | Performance of contract; legitimate interests. | College has an interest in recovering fees owed by students or alumni. | |
| 30 | Library records: access logs, borrowing history, overdue items and fines. | Generated by the College. | To manage library facilities and enforce regulations. | 1 year after library account closure. | Performance of contract; legitimate interests. | College has an interest in operating a library and managing usage and fines fairly. | |
| 31 | Records of decisions regarding course options, changes, withdrawals, suspensions, or intermissions. | Obtained from you; generated by the College. | To record and decide requests concerning course or study changes. | 25 years after leaving or permanently if archived. | Performance of contract; legitimate interests. | To record and implement academic decisions according to College regulations. | |
| 32 | Welfare records, including confidential counselling and support requests or provision. | Obtained from you; generated by us. | To provide welfare and counselling support services to students. | 25 years after leaving. | Legitimate interests. | College and students have a legitimate interest in access to welfare and counselling services. | Explicit consent; vital interests where appropriate. |
| 33 | Mailing lists used to inform you about College and University events or information. | Generated by the College. | To enable communication about events and news during your studies. | Removed from lists within 3 months after you leave. | Legitimate interests. | Ensuring students are aware of College and University activities. | |
| 34 | Student information used in marketing and outreach materials (photographs, testimonials, participation records). | Obtained from you. | To promote the College to potential applicants. | Permanently (transferred to archives). | Legitimate interests. | The College has an interest in recruiting and retaining students under its charitable aims. | |
| 35 | Research student records (supervisor details, examiners, advisors, thesis title, progress reports, meeting notes, viva outcomes). | Obtained from the University; generated by us. | To monitor postgraduate progress and record assessment outcomes. | 25 years after leaving or permanently if archived. | Performance of contract. | ||
| 36 | Consultations and treatment records by the College Nurse. | Obtained from you; generated by the Nurse. | To provide basic medical advice or treatment to students. | 3 years after leaving or reaching age 21, whichever is later. | Legitimate interests. | College has an interest in student welfare and healthcare provision. | Explicit consent or vital interests where necessary. |
| 37 | Data retained post-contract for archiving, research, references, legal or regulatory purposes. | Retained from other categories listed in this document. | For reference provision, regulatory compliance, archiving and research. | As specified elsewhere in this table. | Legitimate interests. | College has an interest in providing references, complying with legal requirements, maintaining archives, and supporting research. | Necessary for establishment or defence of legal claims; archiving in the public interest; historical research purposes. |
| 38 | References provided for students or alumni. | Generated by the College. | To provide references when requested by or for you. | 25 years after leaving or permanently if archived. | Legitimate interests. | College, students, and reference recipients have a shared interest in providing accurate references. | |
| 39 | Student performance records appearing in alumni publications (completion of courses, awards, etc.). | Generated by us; obtained from the University. | To record and share academic achievements and maintain archives. | Permanently (archived). | Legitimate interests. | College has an interest in maintaining an archive of achievements and activities as part of its historic record. |
Version control: Version 1.5 (Reviewed May 2024)