Students’ Union Privacy Notice

Eighteen-24 Students’ Union Privacy Notice 

Eighteen-24 (“we, us”) is a targeted Out-of-Home media Network and we value the security and privacy of personal data that we handle. This privacy notice details the measures and procedures we have in place to manage and protect your personal data as a student, staff member or visitor (“student”) in a students’ union, students’ association, guild of students or similar site (“union”) in which Eighteen-24 operates or sells media. The document details what data we collect and how we use it which can vary dependant on the nature of our relationship with you. 

Collecting Data

We collect different types of data dependant on our relationship with you as a student. The data we may collect about you is most likely to be your photographic likeness collected as part of B2B marketing activity or evidential campaign photography we take from time to time in sites across our network, where you may appear in the background of the photography. If you are positioned in the background of the photography you reserve the right to ask our photographer to obscure you from any materials we may use and our photographer must provide you with contact information and our privacy policy upon request. If you are prominently featured in the photography – that is to say in the foreground or not as part of a larger crowd, then we may ask for written consent which would involve the collection of any/all of the following:  name, address, email address and phone. 

We collect photography data for a number of reasons (predominantly for B2B marketing, social media marketing, and evidential photography). Data provided on consent forms is not shared externally but is stored on our servers until or unless the photographs to which they relate are deleted or removed. This data will be used for admin/record keeping; to comply with legal and regulatory obligations; to protect our business and properties and/or to protect or defend ours and your legal rights. 

The legal basis for our use of data about you is: to fulfil our legitimate business interests that shall not be overridden by your rights or protections; to comply with our obligation to B2B clients to provide evidential photography of their advertising campaigns in busy populated sites that have not been manipulated to appear as such; and/or to comply with legal obligations to which we are subjected. Should none of the above apply before we process your data, we will ask for your consent. 

Use of Data

Data we collect about/from you is processed and stored on servers in the UK and is not transferred overseas. We take appropriate measures, both organisational and technical, to protect the data that we hold from unauthorised access, use, disclosure or alteration. Photography will only take place when express permission for us to carry out such activity has been granted by the tenant, landlord or agent (that is to say the union) or the college or university in which the union is located. These institutions are subject to their own data policies and privacy notices. Photography data collected by us may be used for the following purposes: 

• Printed and digital marketing materials for B2B clients (e.g. sell sheets, newsletters, invitations)
• Social media posts aimed at a B2B audience
• Evidential photography as required by our advertising clients
• Use on our website (www.eighteen24.com) and in evidential galleries on the website, again aimed at B2B clients 
• With other third parties if required or where permitted by law (e.g. law enforcement, regulatory or government departments and authorities, etc.)
• When such disclosure of information can be considered necessary for the prevention of harm or loss (physical or financial) 

Where you have completed a consent form for use of your likeness in photography we will use the data on said form for the following purposes: 

• For admin/record keeping
• With other third parties if required or where permitted by law (e.g. law enforcement, regulatory or government departments and authorities, etc.)
• When such disclosure of information can be considered necessary for the prevention of harm or loss (physical or financial) 

Where we are not legally obliged to retain data for regulatory compliance, the length of time we will retain it shall vary dependant on the purposes for which it was collected or whether you have requested its deletion. We will not retain your data for longer than is considered necessary to fulfil the purposes for which we collected the data. 

Your Rights

You reserve the following rights in respect of the data that we hold about you: 

• You may request us to remove, alter or amend the data;
• You may request access to the data; 
• You may request us to restrict our use of the data;
• You may request your data is not used for marketing;
• You may withdraw your overall consent for our use of the data, where our use is based on your content; or
• You may lodge a complaint with an appropriate supervisory authority.

Our contact details are laid out below.

Enquiries

Eighteen-24 operates several highly targeted destination-based Out of Home networks. We work with the UK’s leading agencies and brands to deliver effective and flexible advertising campaigns. For information about our business activities and contact information please visit www.eighteen24.com.  If you have any questions, or wish to exercise any of your rights, you can contact us at: privacy@eighteen24.com, by calling 0207 291 6200 or by writing to Eighteen-24, Privacy & Data Protection, 34 Percy Street, London W1T 2DG. 

Should you have any further questions we are unable to resolve you may seek remedy before a UK court and/or reserve the right to liaise with the Information Commissioner’s Office. 

Changes to this notice

We may update this and any supplementary privacy notice from time to time. We will notify of the changes where required by applicable law to do so. 

Last modified 1 February 2024