Statement concerning the processing of sensitive data relating to employees
The University needs to collect and use certain data which are defined as “sensitive personal data” under section 2 of the Data Protection Act 1998. The data which may be collected, and the purposes for which they may be used, are listed below. These purposes fall within the conditions for processing personal data which are set out in Schedule 2 of the Act and, more particularly, are covered by one or more of the conditions for processing sensitive personal data contained in Schedule 3 of the Act. Data will not be disclosed or processed for any other purposes without the specific consent of the data subject.
Race and ethnic origin: Information is collected from Application forms. It is used to ensure the University’s compliance with Race Relations and Equal Opportunities legislation, and for statistical purposes sent to the Higher Education Statistics Agency and other such bodies. Although collected and stored in a form accessible by individual name, the data will only be disclosed to other organisations in an anonymised aggregate form.
Membership of Trade Union: Information is provided either by individuals or by the Unions. It is used for administering payment of membership dues.
Physical or mental health, or medical condition: Information is collected from details supplied on appointment, and from medical certificates submitted during employment. It is used for the purpose of:
- Administering statutory and institutional sick leave, sick pay, maternity leave and maternity pay schemes, including the record of absence for sick leave.
- Checking suitability and fitness for work in specific appointments in the University and for any placements, secondments or honorary appointments with other employers.
- Ensuring University compliance with Disability Discrimination and Health and Safety legislation.
- Managing and maintaining a safe environment in the University.
- Providing accurate records of sickness in response to requests from other prospective employers in cases where the employee has given explicit consent.
- Supplying information on accidents where industrial injuries benefit may be payable.
Except as is necessary for the above purposes, these data will only be provided if required by law (e.g. for entry into certain professions) or in aggregate and anonymised form for statistical purposes.
Criminal records: The University may require staff to give information about criminal convictions. This would be used:
- To assess suitability for certain occupations involving financial responsibility, or responsibility for other staff or students.
- To ensure compliance with requirements of insurers (e.g. for car driving, safety, etc.).
- To enable the University to satisfy itself that is complying with any legislative requirements (e.g. in relation to Health and Safety at Work or Children Act matters).
In addition, the University will require a disclosure from the Criminal Records Bureau in relation to posts which involve working with children or vulnerable adults.
Apart from the above uses, the data will only be disclosed to third parties where there is a legal requirement so to do.
Internal Disciplinary Records: Data relating to internal disciplinary action will be retained in the first instance long enough to be available for any subsequent appeal, and thereafter for the period of time stated in the University’s disciplinary procedures, and which will be clearly stated in the letter indication the action to be taken. Disciplinary records will only be made available to members of University staff where duties require that they should have access to them.
Professional registration: In occupations where professional registration is required or normally expected by external bodies with whom staff are required to work, the University will retain details of, and reasons for, the non-registration of a member of staff. These details may be supplied by the staff concerned or provided by the professional body. Such details may be disclosed to other bodies in the course of arranging placements, secondments or honorary contracts, although wherever possible the data will be anonymised.
Dr Jonathan Davies, Data Protection & Copyright Manager, Information Services, Hugh Owen Library, Penglais, Aberystwyth, Ceredigion, SY23 3DZ
Tel: 01970 628592 Fax: 01970 622404 Email: email@example.com