Staff Privacy Notice
What is the purpose of this document?
The University of Worcester (“The University”) (“we”, “our” or “us”) is committed to protecting the privacy and security of your personal information.
The University is defined as the University of Worcester and its subsidiary companies: UW Developments Ltd, UW Enterprises Ltd and UW Worcester Wolves Ltd.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, together the data protection legislation.
It applies to all employees (including sessional staff, temporary staff and associate staff), workers and contractors. It is important that you read this notice.
The University is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to current and former employees, workers and contractors (“you” or “your”). This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
This Privacy Notice should be read in conjunction with the Staff Record of Processing Activities which sets out the various data records processed, the lawful basis for processing, and who the data is shared with.
The University has also published separate notices, which are applicable to other groups and activities. Those notices may also apply to you, depending on your circumstances, and it is important that you read this privacy notice together with other applicable privacy notices and webpages:
1. Current students and applicants Privacy Notice
2. Visitors to the University Privacy Notice (including those attending conferences, events or accessing other facilities offered by the University. This notice also applies to Alumni, members of the Board of Governors, members of the College of Fellows, and holders of other honorary appointments)
3. Website Privacy Notice (including how we monitor use of our website)
4. Cookie Notice
5. CCTV webpage (including information about how we use CCTV)
6. IT Regulations (which includes information about monitoring of network accounts – section 8)
This notice explains what personal data the University holds about you, how we share it, how long we keep it and what your legal rights are in relation to it.
We are the University of Worcester, Henwick Grove, Worcester, WR2 6AJ
If you need to contact us about your data for your general staff record please contact: Human Resources (HR@worc.ac.uk). For other data collections please contact in the first instance: Information Assurance (infoassurance@worc.ac.uk)
The University has a Data Protection Officer, whose contact details are: Helen Johnstone, University Secretary & Clerk to the Board of Governors (h.johnstone@worc.ac.uk)
We will comply with the data protection legislation. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
Personal data, or personal information, means any information relating to you as a living individual from which you can be identified. It does not include data where the identity has been removed (anonymous data)
There are “Special Categories” of more sensitive personal data which require a higher level of protection.
The categories of personal information that we may collect, store, and use about you include (but are not limited to):
We may during the course of your employment with us also collect, store and use the following “special categories” of more sensitive personal information:
Further categories of data what we hold in relation to you are set out in our Record of Processing Activity
We typically collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider (including your previous educational establishments and/or former employers if they provide references to us or credit reference agencies).
We will collect additional personal information in the course of job-related activities throughout the period of you working for us.
Our Record of Processing Activity indicates the sources of each of the various categories of data that we process.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered with you and/or we may be prevented from complying with our legal obligations. For example:
The consequences for any failure to provide such data will depend on the particular circumstances. For example, a failure to provide copies of your passport, right to work and visa information, may mean that we are unable to enter into, or continue, with your employment.
Some data that you give to us is provided on a wholly voluntary basis – you have a choice whether to do so. Examples include:
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Further legal controls apply to data relating to criminal convictions and allegations of criminal activity. We may process such data on the same grounds as those identified for “special categories” referred to above.
Details of the lawful bases we rely on for the processing of the categories of data that we hold in relation to you are set out in our Record of Processing Activity
Do we need your consent?
We do not need your consent if we use special categories of your personal information to carry out our legal obligations or exercise specific rights in the field of employment law in accordance with our written policy. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
We do not, and will not, sell your data to third parties.
We may have to share your data with third parties, including third-party service providers and partner organisations.
We require third parties to respect the security of your data and to treat it in accordance with the law.
Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legal requirement or legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within the University Group
Examples of bodies to whom we are required by law to disclose certain data include, but are not limited to:
Examples of bodies to whom we may voluntarily disclose data, in appropriate circumstances, include but are not limited to:
Where information is shared with third parties, we will seek to share the minimum amount of information necessary to fulfil the purpose.
How secure is my information with third-party service providers and other entities in the University Group?
All our third-party service providers and other entities in the University Group are required to take appropriate security measures to protect your personal information in line with our policies. 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
We have put in place measures to protect the security of your information. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business requirement to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer [Helen Johnstone, University Secretary & Clerk to the Board of Governors email:infoassurance@worc.ac.uk].
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Sharing your data outside the European Union
The law provides various further safeguards where data is transferred outside of the EU.
When you are resident outside the EU in a country where there is no “adequacy decision” (a country outside the EU that ensures adequate level of data protection due to its domestic laws or international commitments) by the European Commission, and an alternative safeguard is not available, we may still transfer data to you which is necessary for performance of your contract with us .
We intend to transfer the following information about you to the following countries:
In the case of the USA the providers used by the University are part of the EU Privacy Shield Framework which means the Commission has decided that it has an adequate level of protection for the time being.
How long will you use my information for?
We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our Records and Document Retention Schedule
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Retention periods may increase as a result of legislative changes, e.g. an increase in limitation periods for legal claims would mean that the University is required to retain certain categories of personal data for longer. Any such changes will be reflected in updated versions of our Records and Document Retention Schedule which is reviewed on a three year basis.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We may keep anonymised statistical data indefinitely.
Once you are no longer an employee, worker or contractor of the University we will retain and securely destroy your personal information in accordance with our data retention policy.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Where we are processing your personal information on the basis of your consent, you always have the right to withdraw that consent.
Under certain circumstances, by law you have the right to:
Please be aware that these rights are subject to certain conditions and exceptions as set out in the data protection legislation.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer [Helen Johnstone, University Secretary & Clerk to the Board of Governors email infoassurance@worc.ac.uk] in writing and they will explain any conditions that may apply.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Information Assurance (infoassurance@worc.ac.uk). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/). You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully.
We may need to update this notice from time to time, for example if the law or regulatory requirements change, if technology changes or to make the University’s operations and procedures more efficient. If the change is material, we will give you not less than two months’ notice of the change so that you can exercise your rights, if appropriate, before the change comes into effect. We will notify you of the change by email.