Context

The University of Namur offers a student accommodation service. The provision of this service involves the processing of data for the management of housing allocations and the execution of contracts. In the context of renting accommodation to students, the University of Namur also provides a support service for the daily life of the occupants of its accommodation. This involves the processing of data for the management of this support and the monitoring of compliance with the internal regulations governing the occupation of the accommodation. 

Management of the student accommodation service

Categories of personal data processed and purposes of use

For the purposes of this activity, the University of Namur processes data in the following categories:

  • General identification data [category including the following types of data: surname, first name, postal address, e-mail addresses, copy of identity card, passport photograph, telephone number, etc.].
  • Personal characteristics data [category covering the following types of data: date of birth, gender, place of birth, marital status and nationality, residence status in Belgium, mother tongue, languages spoken, possession of a driving licence, etc.].
  • Data relating to family situation [category grouping the following types of data: marital status, data relating to parents, guardians and spouses, household composition, children, etc.].
  • Data relating to the allocation and use of housing [category covering the following types of data: dates and purpose of allocation of housing, incidents relating to occupation or end of occupation, etc.].
  • Banking and financial data on individuals [category covering the following types of data: bank account number, IBAN code, VAT details, etc.].
  • Invoicing and payment data [this category includes the following types of data: data relating to a transaction, amount, date of payment, debtor, creditor, purpose of the transaction, etc.].
  • Data relating to the enrolment of students and doctoral students [this category covers the following types of data: data relating to the enrolment file, amount, date of payment, debtor, creditor, purpose of the transaction, etc.]: data relating to the enrolment file, reductions [1st cycle & 2nd cycle], the study cycle of enrolment [1st & 2nd & 3rd cycle], co-degree, study code and study area [1st & 2nd cycle & continuing education], academic grade code, etc. habilitation [ARES], individual courses, PAE credits [1st cycle & 2nd cycle & continuing education], types of gateway, anticipated UEs, recognition of prior learning & credits, exemptions granted, fraudulent student status, prerequisites (such as mastery of the French language [exam date] ...]
  • Data relating to insurance cover taken out by an individual [category grouping the following types of data: type of contract, date of cover, amount insured, insurance interventions, etc.].
  • Identifiers assigned by UNamur [category covering the following types of data: student number, internal registration number, eID for access to internal resources, access card identifiers, student card number, etc.].
  • Social data [category grouping the following types of data: data relating to the receipt of a study allowance from the Wallonia-Brussels Federation, social assistance from a CPAS, family allowances, the award of a grant by the University or another body, etc.].
  • Financial data relating to the enrolment of students and doctoral students [category grouping the following types of data: data relating to the payment of enrolment fees, the granting of a scholarship, financing plan (for non-EU students who cannot be financed (not assimilated)) ...].
  • Data relating to complaints, accidents or incidents [this category includes the following types of data: data relating to the circumstances, dates, places, facts recorded, and more generally all data relating to the handling and follow-up of the complaint, accident or incident, etc.].
  • Data relating to student mobility [category grouping together the following types of data: data relating to participation in a mobility programme (e.g. Erasmus), dates, institution of origin or destination, etc.].
  • Data relating to the storage of proof of authorisation or consent [category grouping together the following type of data: dates of authorisation, purpose, etc.].
  • Data relating to the allocation of equipment and goods [this category covers the following types of data: dates and purpose of allocation/return of computer equipment, telephones, keys, company car, incidents relating to the use of this equipment, etc.].
  • Data relating to membership of a project kot
  • Data relating to the activation and deactivation of access badges
  • Data relating to supporting documents for requests to modify the lease contract (end of training period, etc.). 

This data is used to:

  • Monitor housing applications
  • Manage the allocation of accommodation
  • Manage the issue of occupancy certificates
  • Manage lease contracts and their execution (including inventories of fixtures, rental damage, etc.)
  • Manage the accounts relating to housing services
  • Managing any disputes relating to the use of the accommodation service 
Basis of lawfulness of data processing 

The activity is necessary for the performance of a contract with the person whose data is processed or for the performance of measures taken with a view to concluding a contract at that person's request (article 6, 1, b) of the RGPD).

Processing of special categories of data

In pursuit of the aforementioned purposes, the University of Namur is also required to process data contained in a certificate drawn up by a health professional. 

The processing of data in this special category is justified by the fact that it is carried out with the consent of the data subject (article 9, 2, a) of the RGPD).

The lessee may obtain reduced renunciation compensation if he can prove exceptional circumstances. If a hirer sends a supporting document containing information relating to health, he or she authorises the University to use it to assess the existence of exceptional circumstances. 

Categories of data subjects

The categories of persons whose data is processed for the purposes of the activity are as follows:

  • Tenants
  • Students or future students applying for accommodation
  • Students benefiting from accommodation
  • Student contact persons
  • Account holders through whom rents are paid
Data sources

The data included in the processing activity comes from the following source(s):

  • The data was supplied by the individual him/herself
  • The data is stored in a University database.
Data Recipients

Data is processed solely by University staff and departments for the purposes of carrying out the activity. The internal recipients of the data mainly belong to the following categories:

  • University administrative staff

External recipients of data fall into the following categories:

  • Tax authorities
  • Company auditors
  • Local authority agent (in the case of a residential address)
  • Insurance company (in the event of a claim)
  • External advisers (in the event of a dispute or contractual problem)
  • Legal representatives
  • Service providers acting on behalf of and on the instructions of the University
Characteristics of processing 

The retention period is determined according to the following criterion(s):

  • the need to retain data for operational purposes in accordance with the purpose for which it is used. 

Data relating to unsuccessful housing applications may be kept until the end of the current academic year. 

Contract data is kept for 5 years after the end of the last contract concluded with the tenant, unless there is a dispute justifying keeping the data beyond this period in order to defend the University's rights and interests.

  • compliance with one or more of the mandatory legal retention periods imposed by legislation.

The data contained in the accounts are kept for the legally required periods. 

Furthermore, if the database relating to the processing activity is hosted on European territory, in the event that the student applying for accommodation is established outside European territory, the University of Namur may send communications including personal data to this territory. The transfer is necessary for the performance of a contract between the person and the University or for the implementation of pre-contractual measures taken at the request of the person concerned.

Management of daily living support in accommodation 

Categories of personal data processed and purposes of use

For the purposes of this activity, the University of Namur processes data in the following categories:

  • General identification data [category covering the following types of data: surname, first name, postal address, e-mail addresses, copy of identity card, passport photograph, telephone number, etc.].
  • Personal characteristics data [category covering the following types of data: date of birth, gender, place of birth, marital status and nationality, residence status in Belgium, mother tongue, languages spoken, possession of a driving licence, etc.].
  • Data relating to the enrolment of students and doctoral candidates [category grouping together the following types of data : data relating to the enrolment file, reductions [1st cycle & 2nd cycle], the study cycle of enrolment [1st & 2nd & 3rd cycle], codiplomation, the study code and study field [1st & 2nd cycle & continuing education], the academic degree code & habilitation [ARES], individual courses, PAE credits [1st cycle & 2nd cycle & continuing education], types of gateway, anticipated UEs, recognition of prior learning & credits, exemptions granted, fraudulent student status, prerequisites (such as mastery of the French language [exam date], etc.), etc.]
  • Data relating to the imposition of a sanction [category grouping the following type of data: data relating to circumstances, dates, facts recorded, sanction imposed, measures taken ... ]
  • Data relating to complaints, accidents or incidents [this category includes the following types of data: data relating to circumstances, dates, places, facts recorded, and more generally all data relating to the handling and follow-up of the complaint, accident or incident, etc.].
  • Data relating to discipline [category grouping the following types of data: data relating to disciplinary measures/sanctions, facts giving rise to sanctions, procedure, etc.].
  • Data relating to the allocation and use of accommodation [this category includes the following types of data: dates and purpose of allocation of accommodation, incidents relating to occupation or end of occupation, etc.].
  • Data relating to the monitoring of compliance with regulations applicable to students, including plagiarism [this category includes the following types of data: data relating to the verification of the use of IT resources, compliance with regulations, analysis of copies using anti-plagiarism software, etc.].
  • Data relating to the specific needs of students [category grouping the following type of data: data relating to the specific needs of the support file, support plan, accommodation granted, etc.].
  • Identifiers allocated by UNamur [category covering the following types of data: student number, internal registration number, eID for access to internal resources, access card identifiers, student card number, etc.].
  • Data relating to family situation [category grouping the following types of data: marital status, data relating to parents, guardians and spouses, household composition, children, etc.].
  • Social data [category grouping the following types of data: data relating to the receipt of a study allowance from the Wallonia-Brussels Federation, social assistance from a CPAS, family allowances, the award of a grant by the University or another body, etc.].
  • Data relating to lifestyle [category grouping the following types of data: data relating to means of transport, travel habits, food preferences, lifestyle, hobbies and interests, etc.].
  • Data relating to student mobility [this category includes the following types of data: data relating to participation in a mobility programme (e.g. Erasmus), dates, home or destination institution, etc.].
  • Data relating to the student's academic career [this category includes the following types of data: data relating to the student's academic career, annual programme - teaching units taken -, PAI - Programme d'accompagnement individualisé, grades, credits, exam registrations, honours, diplomas obtained, country(ies) of issue of diploma(s), jury opinions, disciplinary decisions and appeals, end-of-study work, work placements carried out, etc.].
  • Data relating to participation in an activity [category grouping the following types of data: presence, purpose of the activity, etc.].
  • Data relating to the allocation of equipment and goods [this category covers the following types of data: dates and purpose of allocation/return of computer equipment, telephones, keys, company car, incidents relating to the use of this equipment, etc.].
  • Any data contained in an incident report
  • Data relating to work placements and other cases of absence from the residence  

This data is used to:

  • Manage the daily living support service in the accommodation, which includes: 
    • Welcoming new arrivals,
    • Logistical management of accommodation occupancy,
    • Managing the activities offered to student tenants,
    • Providing social support for student tenants according to their needs and background, 
    • Advising student tenants in conjunction with other student services,
    • Incident management
  • Detecting breaches of the internal regulations
  • Applying the sanctions provided for in the rules
Basis for lawfulness of data processing 

The University of Namur is entrusted with public interest missions in terms of teaching, research and community services. For the purposes of carrying out these missions, the Université de Namur processes tenants' data in order to organise their reception and the logistics of occupancy as well as to manage compliance with the internal regulations governing the conditions of occupation of the accommodation (article 6, (1), e) of the RGPD).

Processing of special categories of data 

In the event of a dispute or incident, UNamur may process data in the following categories insofar as this is necessary for the management of its own litigation, in particular for the establishment, exercise or defence of a legal right (Article 9, 2, f) of the RGPD and Article 10 of the Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data).   

  • Data relating to philosophical or religious beliefs
  • Data contained in a certificate issued by a health professional
  • Data relating to criminal convictions or offences
Categories of data subjects

The categories of persons whose data is processed for the purposes of the activity are as follows:

  • Student tenants of University accommodation
  • Contact persons reported by tenants 
Data sources

The data included in the processing activity comes from the following source(s):

  • Data from a University database
  • The data is generated by an activity carried out by the individual
  • The data was supplied by the individual him/herself
Data Recipients

Data is processed solely by University staff and departments for the purposes of carrying out the activity. The internal recipients of the data mainly belong to the following categories:

  • University administrative staff
  • Members of the Disciplinary Committee 

External data recipients fall into the following categories:

  • External service providers acting on behalf of and on the instructions of the University.
Characteristics of Processing 

The retention period is determined on the basis of the need to retain the data for operational purposes in accordance with the purpose for which it is used. 

The data is kept for the duration of the occupancy of a housing. 

Data subjects rights 

The rights of data subjects are described at https://www.unamur.be/en/privacy-policy. Any requests or questions relating to the files processed may be addressed to logement-etudiants@unamur.be.