The Report & Support tool is run by the Student Conduct & Appeals team, part of King’s College London (“King’s”, “we” “us”, or “our”). If you have any questions about Report & Support and its use at King’s please contact reportandsupport@kcl.ac.uk

King’s act as a controller in respect of the Report & Support tool, as we determine the purpose and the manner that any personal data is, or is likely to be, processed. This means that we are legally responsible for the personal data we collect and hold about you.
 
One of our responsibilities is to tell you about the different ways in which we use your personal data and your rights in relation to the information that you, or someone else provides, about yourself. Please see Section 3 of this notice for a detailed breakdown of the data processing.

This privacy notice supplements the following wider privacy notices: 

1. What is 'personal data' 

'Personal data' means any information which directly, or indirectly, identifies you as an individual. It does not include any information which does not identify you (anonymous information).

‘Special category data' is information that is more sensitive such as information about racial or ethnic origin, physical or mental health and sexual life, and are given a high level of protection under data protection law. Personal data relating to criminal convictions and offences are also treated as requiring additional protections.

2. About the Report and Support tool at King’s

The Report & Support tool at King’s provides staff, students, and visitors with a portal to report and seek support in respect of issues including bullying, harassment, and sexual misconduct. 
 
It enables the College, where appropriate, to manage and act on those reports as well as gather aggregated data for future preventative work. Aggregated data is high level data that does not identify an individual.
 
The Report and Support tool is not designed to be used when reporting potential safeguarding or other issues to King’s which may relate to an individual's criminal convictions and offences. If you become aware of a safeguarding issue or wish to report criminal offence data, please follow the procedures set out in King’s Safeguarding Policy
 
If criminal offence data has been provided, we will forward the information to the appropriate King’s department in line with the above Safeguarding Policy and redact it from the report. 

3. What information we collect, why we collect it & how long we keep it

Reports may be made by staff, students, and visitors. These reports may be submitted either anonymously or with contact details:

 (a) Anonymously
 
Where no names or other information that could be used to identify the individual making the report are provided.
 
When making an anonymous report, do not include names or other information that could be used to identify a third party. Where we receive an anonymous report containing third-party information, King’s will redact any information that directly or indirectly identifies an individual and will not take further action on that information, unless there are safeguarding issues.

(b) With contact details
 
Where names and contact details of the individual making the report are included. Named reports can include third-party information, such as names or other information which could be used to identify another individual. 
 
If a named report is made, we will collect, use, store and transfer different kinds of personal data about the individual making the report and the individual who is the subject of the report. 
 
In both cases, any personal data processed by King’s through Report & Support is voluntarily provided by the staff, students, or visitors making those reports. 
 
Please note that where you make a report through the Report and Support tool, King’s will only disclose information to its staff members on a need-to-know basis. We will not generally take steps such as investigating the complaint, initiating disciplinary or other formal proceedings (including litigation) or passing information on to third parties in order to take the report further unless: (a) you have made a named report; and (b) you agree to this action.

However, there are certain circumstances in which King’s may take steps such as those listed above even where: (a) an anonymous report is received (in which case action will be taken on a 'no names' basis); or (b) you have made a named report but you do not wish to take your report further. This is usually where there are concerns for your safety or another person’s safety. Please see Section 4 below for further information on information sharing.
 
Information is collected at the time you make a report or someone else makes a report. 

We will collect your personal details, and that of those named in the report, including:
  • Name, ID number, email address, contact phone number, Department, gender;
  • Sensitive or ‘special category’ personal data including race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about health etc.;
  • Details of the complaint, including bullying, harassment, sexual misconduct.
The purpose of the information collection is:
  • To enable staff, students, and visitors to more easily report cases of bullying, harassment, sexual misconduct etc.;
  • To enable staff, students, and visitors  to more easily seek support; 
  • To enable the College to manage and administer the process  as effectively as possible.
Where criminal offence data are provided unsolicited, we will forward the information to the appropriate King’s department in line with the College’s Safeguarding Policy and redact it from the report. 

The information provided will be retained for 6 years from the date of submission in line with the King’s Records retention Schedule. Any information or speculation around criminal convictions and offences is removed before the report is processed and not retained on the Report & Support website. However, it will be processed elsewhere in King’s for safeguarding purposes.

We will also process the names and other details about third parties who are involved in the issues reported or named in the report. If the decision is made to conduct an investigation into the contents of the named report we will contact the named individuals accordingly. 

4. Who we share your data with

Where you make a report through the Report & Support tool, King’s will disclose information to its staff members in the relevant departments on a need-to-know basis only. 

We will not normally take steps such as investigating the complaint, initiating disciplinary or other formal proceedings (including litigation) or passing information on to third parties in order to take the report further unless you have made a named report; and you have asked for and consented to this action unless safeguarding issues have been identified.

Our basis for sharing it:
  • Both ours and your legitimate Interests to enable you to access the platform to report bullying, harassment etc. and to enable us to act on those reports and for administration purposes.
  • Reasons of substantial public interest: such as safeguarding of children and individuals at risk.
  • Where we have your consent to share it.
  • To prevent or detect unlawful acts.
  • To protect the public against dishonesty.
  • For Statutory and government reporting purposes. 
  • To enable us to establishment, exercise or defend legal claims
Who we share it with internally:
  • Appropriate data-sharing between internal teams on a need to know basis for the purpose of providing support and investigating the report. Depending on the nature of the report, such teams will be likely include Student Services teams such as Student Conduct & Appeals, Counselling & Mental Health support, Advice Welfare and Well Being and Disability Support and International Advice. 
  • Human Resources and managers on a need-to-know basis.
Who we share it with externally:
  • The Culture Shift Report & Support Platform we use.
  • The police/social care services/local authorities/other similar bodies, where appropriate.
  • King’s College Student Union where the situation involves their premises, staff or their activity groups.
  • King's consultants and professional advisors such as legal advisors.
  • Relevant Government Departments to fulfil our legal obligations, for example, under the Equality Act.
  • Courts & Tribunals.

5. Transfer of data 

We use a third party platform, HubSpot owned by Culture Shift, to support our Report & Support management. HubSpot uses the Google Cloud Platform (GCP) in the EU (Frankfurt, Germany region) to support the processing of local customer data in Europe and the UK. This means your personal data will not leave the protections of UK/EU GDPR.

6. Your Rights 

As an individual whose data we process, you have certain rights in relation to that processing of your data.
 
To find out more about how the university deals with your personal information, including your rights and who to contact if you have a concern, please see the university’s core privacy notice.
 
If you need to get in touch with us about Report & Support please contact reportandsupport@kcl.ac.uk.

If you have any questions about this privacy notice, please write to info-compliance@kcl.ac.uk.

7. What happens if I am reported?

If you’re reported then what happens to your data depends on whether the reporting party wants a formal investigation or for it to be resolved informally.

Formal Investigation

The report will be forwarded on to the relevant teams (Student Conduct & Appeals for students and Human Resources for staff) and your data will be shared as above in 1 – 7.

Informal Resolution

Each case will be considered on an individual basis and where a reporting party only wishes for support then no further action will be taken other than for safeguarding purposes. Where there are safeguarding concerns and/or the reporting party wishes for an informal resolution such as a No Contact Agreement or mediation then the person who is reported will be contacted and your data will be shared as above in 1 – 7.

There are two ways you can tell us what happened