Graduations 2025: Local privacy notice

Introduction 

VPEE Graduations’ Ceremonies’ team (“we” “us”, or “our”) respects your privacy and is committed to protecting your personal data.  

Please read this Privacy Notice carefully – it describes why and how we collect and use personal data and provides information about your rights.  It applies to personal data provided to us, both by individuals themselves or by third parties and supplements the following wider UCL privacy notice(s): 

• General privacy notice when you visit UCL’s website
• Student privacy notice
• Staff privacy notice 

We keep this Privacy Notice under regular review. It was last updated on 14th January 2025. 

About us 

Graduations’ Team is part of the VP External Engagement at University College London (UCL). 

UCL, a company incorporated by Royal Charter (number RC 000631), is the entity that determines how and why your personal data is processed. This means that UCL is the ‘controller’ of your personal data for the purposes of data protection law.

Personal data that we collect 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). 

We may collect, use, store and transfer different kinds of personal data about you. Most data we process and store about you is drawn from your student record. We process and store data including your name, contact details, qualifications which you are awarded and academic record while at UCL. We do not process data on your date of birth, ethnicity, or ID photograph.   

You have been asked to confirm if you or your guests require special arrangements such as Tier 4 Visa invitations, wheelchair provision, hearing loop capability to attend the ceremony via the online ticketing tool. Disclosed personal data relating to disabilities and special arrangements for graduates and guests will be processed directly by the Graduation team. Only relevant information necessary to provide assistance on the day will be shared with the team on the day. This information will not be shared with any other department within the University and will be deleted from our records after the graduation ceremonies. 

 We shall: 

• collect your audio and visual data at the Graduation Ceremony via a live stream recording; 

We will collect the following types of personal data about you:  

• Faculty awarding Degree
• Name, title,
• Visual image  

Additional information to the above that we may collect during the Graduation Ceremony and via the live stream includes:  

• Department awarding Degree
• Award level (undergraduate, postgraduate – Masters, PhD etc)
• Award name and title;

How we use your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

• To monitor number of ticket sales and registration per ceremony to ensure adequate catering is provided, for health and safety reasons. This data will not be retained beyond the relevant ceremony;
• We will live stream the Graduation Ceremony using social media sites (via encrypted YouTube link) to allow friends and family who are unable to attend to view the ceremony. This broadcast will broadcast via the UCL Channel within YouTube and will be retained for twelve (12) months after the ceremony date; or
• For the purpose of improving the student experience at UCL; or
• Live stream recordings may be used at the time of the event and in the future for the purpose of recruiting students or attracting external funding to UCL as part of our external engagement campaigns. 

If you have any concerns as to how we will process your personal data please contact us via ceremonies@ucl.ac.uk including Data Privacy in subject line.  

We may also use anonymised data, meaning data from which you cannot be identified, for the purposes of: 

• Service evaluation;
• Education and research; or
• Fundraising and promotional purposes.  

Anonymised data may also be used in published reports or journals and at conferences. 

Who we share your personal data with 

Your personal data will be collected and processed primarily by our staff and UCL. (Access to your personal information is limited to staff who have a legitimate need to see it for the purpose of carrying out their job at UCL). We may have to share your personal data with the parties set out below for the purposes outlined in section 4: 

• Attendees and viewers of 2025 Graduations as this will be a public event;
• 121 Captions for the purpose of live transcriptions to capture graduate names as they cross the stage and to promote accessibility for those with hearing disabilities;
• Marston Events for the purchase of ticket sales and to ensure that correct gown and hood are available for your chosen ceremony;
• Wonderland Events as the events’ management company for operational, safety and seating purposes. 

Your name will be announced by a member of UCL staff as you cross the stage and this will appear on the screen simultaneously; 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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. 

Lawful basis for processing 

Data Protection Legislation requires that we meet certain conditions before we are allowed to use your data in the manner described in this notice, including having a “lawful basis” for the processing. The basis for processing will be as follows:  

• Public task. The processing of your personal data may be necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us
• Legitimate interests. The processing of your personal data may be necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or by fundamental rights and freedoms which require protection of personal data  

International transfers 

Where we transfer your personal information across national boundaries to a third party, such as one of our service providers, we will protect your personal information by ensuring that those transfers are made in compliance with all relevant data protection laws. Generally, this means where we transfer your personal information to a third party that is located in a country which does not have adequate privacy protection, we will put in place a contract with the third party that includes the standard international data transfer contractual terms approved by the ICO.  

Information security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have established procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

Data retention 

We will only retain your personal data 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. 

We will keep your personal data according to the Records Retention Schedule. 

Your rights 

Under certain circumstances, you may have the following rights under data protection legislation in relation to your personal data: 

• Right to request access to your personal data;
• Right to request correction of your personal data;
• Right to request erasure of your personal data;
• Right to object to processing of your personal data;
• Right to request restriction of the processing your personal data;
• Right to request the transfer of your personal data; and
• Right to withdraw consent. 

If you wish to exercise any of these rights, please contact the Data Protection Officer. 

Contacting us 

You can contact UCL by telephoning +44 (0)20 7679 2000 or by writing to: University College London, Gower Street, London WC1E 6BT. 

Please note that UCL has appointed a Data Protection Officer. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact our Data Protection Officer using the details set out below: 

Data Protection & Freedom of Information Officer 

data-protection@ucl.ac.uk  

Complaints 

If you wish to complain about our use of personal data, please send an email with the details of your complaint to the Data Protection Officer so that we can look into the issue and respond to you.  

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) (the UK data protection regulator).  For further information on your rights and how to complain to the ICO, please refer to the ICO website.