Research Participants, Supporters and Visitors Privacy Notice
This Privacy Notice applies to all research participants, supporters and visitors to the University.
Definitions
‘Research Participant’
Individuals who have agreed to participate in a research project through, for example, taking part in an experiment or trial, completing a survey, being interviewed, or providing information through other means for the purposes of research.
‘Supporters’
Individuals who support the University in its aims and objectives through, for example, being a Governor of the University, belonging to the College of Fellows, being an Alumnus of the University, belonging to a society, group of association hosted by the University.
‘Visitor’
Individuals who attend events organised by the University either on or away from the University Campus, who use the University’s facilities such as the Arena, Lakeside, or other sports facilities, who visit or access University facilities for any other reason.
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 research participants, supporters of the University, visitors to the University, users of University facilities and attendees at University organised events held at the University or other venues. 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 all research participants, supporters of the University, visitors to the University, users of University facilities and attendees at University events held away from the University campus (“you” or “your”). This notice does not form part of any contract of employment or other contract to provide services. We will update this notice at any time.
This notice should be read in conjunction with the Research Participant, Supporter and Visitor Record of Processing Activities
The University has also published separate notices, which are applicable to other groups and activities. This 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:
1. Employees, Workers and Contractors Privacy Notice
2. Student and Applicant Privacy Notice (this includes graduates of the University)
3. Website Privacy Notice (including how we monitor use of our website)
4. Cookie Notice
4. CCTV webpage (including information about how we use CCTV)
5. IT Regulations (which includes information about monitoring of network accounts – see 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
The University has a Data Protection Officer, whose contact details are: Helen Johnstone, University Secretary & Clerk to the Board of Governors (infoassurance@worc.ac.uk)
If you need to contact us about your data in the first instance please contact your initial point of contact when you provided your data. For queries in relation to your various rights and the data we hold about you please contact the University’s Data Protection Office.
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, depending on the nature of your interaction with the University, also collect, store and use the following ‘special categories’ of more sensitive personal information:
· Information about your race, ethnicity (including nationality), religious or philosophical beliefs, political opinions and sexual orientation (Information about your trade union membership
· Information about your health, including any medical condition or disability and health and sickness records.
Further categories of data what we hold in relation to you are set out in our Record of Processing Activity
The law requires that we provide you with information about the lawful basis on which we process your personal data, and for what purposes.
Most commonly for research participants we will process your data where this is necessary for the performance of a task carried out in the public interest (if the research is funded by a public body) or we will process your data where this is necessary for the purposes of the legitimate interests pursued by the University or by a third party (if the research is funded by a commercial entity).
Most commonly, for visitors to the University and users of the University’s facilities, we will process your data on the basis of your consent.
We may also use your data, typically in an emergency, where this is necessary to protect your vital interests, or someone else’s vital interests.
In a small number of cases we may process your data on the following lawful grounds:
How we apply further protection in the case of “Special Categories” of personal data.
“Special Categories” of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.
The Special Categories of personal data consist of data revealing:
They also consist of the processing of:
We may process Special Categories of personal data in the following circumstances:
– necessary for the purposes of the prevention or detection of an unlawful act and must be carried out without your consent so as not to prejudice those purposes; or
– for equal opportunities monitoring;
Less commonly, we may process this type of data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the data public.
Criminal Convictions and allegations of criminal activity
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.
We have prepared a Record of Processing Activities setting out the processing activities that we undertake, the source of the data, the reasons why we process it, how long we keep it and the lawful basis we rely on.
Details about the relevant processing activity will be included on the specific Privacy Notice relevant to your interaction with the University.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
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 (as detailed below)
We require third parties to respect the security of your data and to treat it in accordance with the law.
Which third party service providers process my personal information?
“Third parties” include third party service providers (including contractors and designated agencies) 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 fulfill 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 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 (as written in the contract between us) and in accordance with our instructions.
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 or other third parties who have a business requirements 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 any contract with you.
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 personal data for the time being.
How long we keep your data
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 requirement.
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 require to retain certain categories of personal data for longer. Any such changes will be reflected in updated versions of 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.
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 relationship with the University.
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:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are processing your information on the basis of our legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. The lawful basis for any particular processing activity we carry out is set out in our detailed table of processing activities.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Suspend processing of your personal information, for example if you want us to establish the accuracy of the data we are processing.
• Object to any direct marketing (for example, email marketing or phone calls) by us, and to require us to stop such marketing.
• Object to any automated decision-making about you which produces legal effects or otherwise significantly affects you.
• Request the transfer of your personal information to another party.
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.
Further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/). You may also wish to contact the University’s Data Protection Officer [Helen Johnstone, University Secretary & Clerk to the Board of Governors email: infoassurance@worc.ac.uk] if you are considering how or whether to exercise your rights.
You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office if you believe that your data has been processed unlawfully.
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.
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. An updated Privacy Notice will be published on the University webpages.