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Privacy Policy

The University Privacy Policy concerns the information we collect about students (prospective, current, and former), how we use it, and who we share it with. The University’s policy on student welfare and security can be found here.

1. What is the purpose of this document?

Richmond, The American International University in London, Inc. (“the University”) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you, in accordance with the Data Protection Act 1998 and the General Data Protection Regulation 2018 (GDPR). The University also complies with FERPA (Family Educational Rights and Privacy Act).

This Student Privacy Policy sets out the basis on which Richmond, The American International University in London, Inc. (“we / us”, “the University”, or “Richmond”) processes and shares students’ personal data. Please read this policy carefully, in particular in relation to Richmond’s use of Sensitive Personal Data.

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 data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to all those who enquire, apply to study, enrol at, and graduate from the University. It is important that you read this notice, together with other policies that we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

2. Data protection principles

We will comply with data protection law. The personal information we hold about you must be:

  • Used lawfully, fairly, and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

3. How we collect data about you

We may collect your personal data in a number of ways, for example:

  1. The information that you provide to us when you interact with us before joining, for example when you express your interest in studying at the University.
  2. When you apply to study at Richmond and complete an application through the Universities and Colleges Admissions Service (UCAS), the University’s online direct application, the Common Application, and through third-party educational counselling services or university partnerships.
  3. From third parties, for example from your previous or current school, sixth form college, secondary school, university, or employers who may provide a reference about you or who may sponsor your studies.
  4. Through marketing and recruitment campaigns.
  5. Through educational counselling services and local education representatives from whom you have sought support in applying to study at Richmond.
  6. Through third-party websites on which you expressed an interest in studying at Richmond.
  7. When you communicate with us by telephone, email, or via our website, for example in order to make enquiries or raise concerns.
  8. In various other ways as you interact with us during your time as a student and after you leave the University, for the various purposes set out below.

4. The type of information we collect

We may collect the following types of personal data about you:

  1. Your name; home address, correspondence address, and term-time address; email address and telephone number; date of birth (application); passport number; social security number; National Insurance number; national identity card or UK immigration Biometric Residence Permit (BRP) details if applicable; country of domicile; nationality; ethnic origin; and sexual orientation.
  2. The name and contact details of your next of kin.
  3. Information relating to your education and employment history, the schools, sixth forms, secondary schools, and other colleges or universities you have attended and places where you have worked, the courses you have completed, dates of study, and your examination results including predicted and actual grades.
  4. Information about your personal circumstances, and both academic and extracurricular interests, where this is relevant to the assessment of your suitability to receive a scholarship.
  5. Sensitive personal data and information about criminal convictions and offences if you disclosed this information.
  6. Sensitive information concerning your health, medical conditions, disability, and dietary needs if you chose to disclose this information.
  7. Sensitive information about your racial or ethnic origin; religion or similar beliefs; and sexual orientation if you chose to disclose this information.
  8. Your bank details for the purpose of fee payment, where required.
  9. A photograph for your University ID card, where required.
  10. Consent materials for University promotion, which may include photographs, videos, testimonials, or marketing copy. Where applicable, we will seek your consent and ask you to complete a release form.
  11. When you graduate from Richmond we may ask you for the following information (you can choose whether or not to provide this information):
    • Where you are or will be working or studying.
    • Your new address and contact details.
    • Your experience, future plans, decisions, and achievements.
  12. Information about you after you leave Richmond for the Destinations of Leavers from Higher Education survey (DLHE) or other surveys if required by the Higher Education Statistics Agency (HESA) and/or the Office for Students (OfS) or other agencies.
  13. Information about you from publicly available sources (for example, news reports about our alumni). We will seek your permission before using this information.
  14. Details of any donations you have given us.

5. Your consent

  1. When you express an interest in studying at Richmond, The American International University in London, and you enquire and/or apply directly for a programme of study, we will request that you give your consent to process and retain your personal data for legitimate processing. We will provide you with an opportunity to opt in and indicate your communication preferences about the types of communications that you wish to receive from Richmond.
  2. If you applied through a third party such as UCAS or the Common Application or another third party, we will inform you that we have received the data that you supplied in your application and that your data will be processed for the legitimate purpose intended.
  3. When you accept the Terms and Conditions of your study offer, you will be required to confirm your consent to process and retain your data while you are enrolled at Richmond.

6. How we will use information about you

We will only use your personal information when the law allows us to. We will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest or for official purposes.

7. How we use your personal data

We may process your personal data because it is necessary for the performance of a function or a contract with you, or in order to take steps at your request prior to entering into a contract when you express an interest in studying at Richmond, when you apply to study at Richmond, when you enrol, and when you graduate from Richmond. In this respect, we use your personal data for the following:

  1. To send you information about the University and its academic provision and services.
  2. To answer your enquiries about the University and its academic provision and services.
  3. To invite you to interviews, open days, applicant days, and webinars.
  4. To interact with you as part of the admissions process.
  5. To send you correspondence relating to your academic study offer and acceptance at Richmond.
  6. Assessing eligibility for bursaries and scholarships.
  7. To provide you with information about ancillary services such as accommodation or other University services.
  8. To deal with your concerns or feedback during the admissions process.
  9. To market the University, our academic programmes, and our services in marketing campaigns which may include emails, SMS, or telephone calls.
  10. To meet statutory and legal obligations which may include compliance with immigration legislation and regulations, compliance with regulators including student funding agencies, the prevention and detection of fraud, and assistance in criminal investigations when requested by civic authorities such as the police.
  11. To manage academic matters relating to your programme of study, including the provision of our core teaching, learning, and research services (for example registration, assessment, attendance, monitoring academic progress, academic misconduct investigations, certification, graduation).
  12. To maintain student records.
  13. To correspond with you during your enrolment and after you have graduated from Richmond.
  14. To provide library, IT, and information services.
  15. To provide non-academic matters in support of our core services, including student support services such as support with disability, additional learning support, careers and employability advice, counselling services, personal supervisors, and academic departments.
  16. Monitoring and promoting equality of opportunity.
  17. Safeguarding and promoting the welfare of our students.
  18. Ensuring students’ safety and security.
  19. Managing student accommodation and catering services.
  20. Managing car parking on campus.
  21. Administering finance (for example payment and collection of tuition and other fees, charges and fines, applying scholarships and bursaries to your tuition plan account).
  22. Undertaking audits (for example to ensure compliance with our regulatory and legal obligations).
  23. Providing operational information (for example IT support, information about building closures or access restrictions on campus, or safety advice).
  24. Promoting our services (for example providing information about summer schools, student exchanges, or other events happening on and off campus).
  25. Handling grievances and disciplinary actions.
  26. Handling complaints and enquiries.
  27. Compiling assessment, graduation, and degree information for the conferment of degree awards and degree certificates.
  28. Keeping in touch with our alumni for the purposes of delivering exclusive alumni services, fundraising, and promoting closer links between Richmond and its former students (we will seek your permission to do so).
  29. Other administrative purposes, including carrying out research and statistical analysis.

8. Sensitive information

Some of your personal data processed by us may be classified as “sensitive” under the DPA and GDPR. This includes your racial or ethnic origin, any disabilities and any associated medical conditions that you have chosen to declare to us. It also includes any criminal convictions you may hold either before or during the time you are registered as a student at Richmond, and the commission or alleged commission by you of any offences during the time you are registered as a student at Richmond.

We may also collect sensitive information from you in relation to any applications you submit for extenuating circumstances, complaints, disciplinary cases, and optional student services provided by Richmond. Sensitive personal information about you may also be provided to us in some circumstances by others (for example, other students or members of staff who may be concerned about you).

If you disclose sensitive personal information to us, we will only use that information for the purpose(s) for which the information was collected. We will collect and use your sensitive personal information either with your consent (this will be made clear when it is collected, through a specific request for consent) or without your consent where there is a legal basis to do so (such as for equal opportunities monitoring).

  1. We will use information you provide to us relating to a medical condition, disability, or learning support need you may have for the purposes of evaluating what suitable support may be available to you, and share this information with Richmond employees and third parties who are directly involved in the application process or the provision of student services, for example RIASA and AIFS. This information has no bearing on the academic assessment of your application.
  2. We will use information relating to any criminal conviction you may have for the purposes of evaluating your admission to Richmond or for evaluating whether to allow you to continue to study at Richmond, and share this information with Richmond employees and third parties for such purposes.
  3. We will share your sensitive personal data with other third parties without your consent if we have a legal basis to do so. This includes providing sensitive personal data, including your ethnicity and any disabilities you have declared, to the Higher Education Statistics Agency (HESA) and/or the Office for Students (OfS). Consent is not required for this under the DPA because it is collected for purposes of statutory equal opportunities monitoring and is not used to make decisions about you.

Other disclosures of sensitive personal data without your consent will be rare and include circumstances where it is vital to protect the interests of you or others (that is, where you or another person is perceived to be at significant risk), where it is necessary for the prevention of fraud, or where we are under a legal obligation.

9. Data sharing

We may have to share your data with third parties, including third-party service providers and other entities.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

We will 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 legitimate interest in doing so. “Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group, including:

  1. University administrative, professional, and academic employees.
  2. Third parties such as the Universities and Colleges Admissions Service (UCAS), the Common Application (USA), Natives Online Ltd (customer relationship management system provider), and other contractors as appointed from time to time.
  3. Educational counselling services (appointed UK, EU, EEA, and overseas representatives/agents with whom and through whom you may have applied to study at Richmond).
  4. University partners with whom you currently study or with whom you intend to study after completion of a Richmond programme.
  5. Partner universities with whom we have agreements for exchange or other collaborations that include student mobility. Data shared may include biographical information, academic achievement, attendance record, and disciplinary information resulting from any breaches of the University’s code of conduct.
  6. Where applicable, another educational provider so they can contact you to offer a pre-sessional or preparatory course relevant to your application to study at Richmond.
  7. Parents, guardians, and next of kin where you have given your consent or where there is a legitimate reason for concern and disclosure.
  8. Marketing agencies with whom we may share limited data for marketing campaigns.
  9. Internal and external auditors carrying out either statutory compliance or data integrity audit functions.
  10. Contractors where there is a legitimate reason for their receiving the information, which may include:
    • Third parties who work with us to provide student accommodation.
    • Third parties who work with us to provide student support services (for example counselling).
    • Third parties who are contracted to provide out-of-hours IT services for us.
    • Organisations operating anti-plagiarism software on our behalf (such as Turnitin®).
    • Organisations operating learning and teaching resource platforms (such as Blackboard®).
  11. Student sponsors (for example the Student Loans Company, the US Department of Education for those in receipt of Title IV funding, the Department of Veterans Affairs (USA), scholarship agencies, and education loan providers). The University may provide the following details to your sponsors if required by law to do so:
    • Enrolment confirmation.
    • Full-time/part-time study status.
    • Your academic progress.
    • Withdrawal and/or study intermission status.
    • Your graduation date.
    • Notification when you fall below any required threshold for sponsorship eligibility.
    • Your contact details when requested by the US Department of Education and the National Student Loan Data System (NSLDS) as required by US financial aid, including but not limited to Title IV regulation.
  12. Crime prevention or detection agencies (for example the police, the Department for Work and Pensions, and Trading Standards).
  13. Richmond’s Student Government for the purposes of contacting you regarding the services it offers (for example support, membership of student societies, event tickets, elections, and other Student Government matters).
  14. Professional bodies who accredit, validate, or assure the quality of what we do (including The Open University, Middle States Commission on Higher Education, the UK Quality Assurance Agency, the Office for Students, and relevant subject accreditation bodies including but not limited to the British Psychological Society (BPS) and the Association of Chartered Certified Accountants (ACCA)) in relation to the confirmation of qualifications, professional registration and conduct, and the accreditation of courses.
  15. Each year, the university is required to submit data about its students to the Higher Education Statistics Agency (HESA). HESA is the official body responsible for collecting and disseminating information about higher education in the UK. Data will be sent to HESA including your name, date of birth, your studies and qualifications. This information will be used by HESA in compliance with the Data Protection Act 1998 and from 25th May 2018, with the General Data Protection Regulation (GDPR). More information about the student data collection return can be found here: https://www.hesa.ac.uk/about/regulation/data-protection/notices The University will request the consent of new students on admission, and for returning students;
  16. The United Kingdom Visa and Immigration Services(UKVI) for those applicants and students that require a UK Tier 4 student visa to study in the UK, or are subject to other immigration controls as defined by the UKVI;
  17. The market research company appointed to carry out the National Student Survey and other survey contractors appointed to carry out surveys of student finances. For more information about use of your information for the National Student Survey please see http://www.thestudentsurvey.com/students.php You have the right not to participate in the survey;

10. International data transfers

  1. Some of the personal data that we process about you will be transferred to, and stored at, a destination outside the UK, for example where it is processed by our staff operating outside the UK or where personal data is processed by our study abroad partners who are based outside the UK or who use storage facilities outside the UK.
  2. In these circumstances, your personal data will only be transferred on one of the following bases:
    1. Where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (for example standard data protection clauses adopted by the European Commission).
    2. A European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection.
    3. There exists another situation where the transfer is permitted under applicable law (for example where we have your explicit consent).

11. How long your information is kept

Subject to any other notices that we may provide to you, we may retain your data for the purposes of marketing, recruitment and admissions, enrolment, assessment, and graduation for the following periods:

  1. For current and future intended years of study for those who have expressed an interest in and enquired about studying at Richmond, or have applied to study at Richmond.
  2. Richmond adheres to the principle under the DPA and the GDPR that personal data of applicants and enrolled students is not kept longer than is necessary and legitimate.
  3. We take measures to ensure that your personal data is securely destroyed or erased from our systems when it is no longer required.
  4. Anonymised information may be retained indefinitely by us in order to maintain demographic information for statistical and marketing research purposes.

12. Changes to your personal data

To enable us to comply with the DPA and the GDPR and keep accurate information about you, you agree to provide us with accurate and up-to-date information and to notify us of any changes to your contact details and circumstances including, but not limited to, any changes to your programme of study or if you intend to leave Richmond. Please contact us if you would like to update your data.

  1. If you are an enquirer (and you have not applied to study at Richmond) or applicant, you may update your details by contacting our Admissions Team at: [email protected]
  2. If you are an enrolled student you may update your details at any time by logging in to Self Service: https://selfservice.richmond.ac.uk/SelfService/Account/AccountHome.aspx
  3. If you are a Richmond graduate, you may update your details by contacting our Alumni Officer at [email protected]

13. Access to your data

To request access to the personal data that we hold about you, you may contact our Data Protection Office by email at [email protected], or by post at the following address:

Data Protection Officer
Richmond, The American University in London
Queen’s Road
Richmond, Surrey TW10 6JP

14. Data protection compliance

If you have any questions about this privacy notice or how we handle your personal information, please contact [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

15. Right to withdraw consent

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 the Data Protection Officer at [email protected]. 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.

16. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

17. Your rights

Under the Data Protection Act you have the following rights:

  1. To obtain access to, and copies of, your personal data.
  2. To require that we cease processing your personal data if the processing is causing you damage or distress.
  3. To request that we do not send you marketing email communications.

From 25 May 2018, you also have the following additional rights:

  1. To require us to correct the personal data we hold about you if it is incorrect.
  2. To require us to delete your personal data from our records.
  3. To require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal).
  4. To receive from us the personal data we hold about you which you have provided to us, in a reasonable and portable format specified by you, including for the purpose of transmitting that personal data to another data controller.
  5. To object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.

Contact us

If you have any questions about this privacy notice, how we process your personal data, or to request access to the personal data that we hold about you, you can contact our Data Protection Officer by email at [email protected] or by post: Data Protection Officer, Richmond, The American University in London, Building 12, Chiswick Park, 566 Chiswick High Road, London W4 5AN.

Privacy Policy

GDPR Privacy Notice for Employees, Trustees, Workers and Contractors.
Version 2.0 – January 2023

The University Privacy Policy concerns the information we collect about students (prospective, current and former), how we use it and who we share it with. Student and University Operational Policies can be found here.

Table of contents

What is the purpose of this document?. 1

Data protection principles. 1

The kind of information we hold about you. 2

How is your personal information collected?. 3

How we will use information about you. 3

How we use particularly sensitive personal information. 5

Information about criminal convictions. 7

Automated decision-making. 7

Data sharing. 8

Data security. 9

Data retention. 10

Rights of access, correction, erasure, and restriction. 10

Right to withdraw consent. 11

Data protection compliance. 12

Changes to this privacy notice. 12

What is the purpose of this document?

Richmond, The American International University in London, Inc. (“the University”) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, or as part of the recruitment process as an employment candidate, in accordance with the General Data Protection Regulation (GDPR).

It applies to all employees, trustees, workers, contractors and employment candidates.

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 data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, trustees, workers, contractors and candidates for employment that are unsuccessful via our recruitment process. 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.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. 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.

The kind of information we process about you

Personal data, or personal information, means any information about an individual from which that person 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.

Where you are a current/former employee, trustee, worker or contractors We may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Date of birth.
  • Marital status and dependants.
  • Next of kin and emergency contact information.
  • National Insurance number.
  • Bank account details, payroll records and tax status information.
  • Salary, annual leave, pension and benefits information.
  • Start date.
  • Location of employment or workplace.
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • Employment records (including job titles, work history, working hours, training records and professional memberships).
  • Compensation history.
  • Performance information.
  • Disciplinary and grievance information.
  • CCTV footage and other information such as electronic access controls and data stored on ID cards.
  • Information about your use of our information and communications systems.

In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your curriculum vitae and covering letter.
  • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, educational and professional qualifications.
  • Any information you provide to us during an interview.

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Information about your health, including any medical condition, health and sickness records.
  • Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about employees/prospective employees, trustees, workers or contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers or other background check agencies.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

We will only use your personal information where we have a justifiable lawful basis to do so. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform a contract we have entered into with you, this may include pre-contract tasks during the recruitment process.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).

2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

We may need the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

  • Making a decision about your recruitment or appointment.
  • Determining the terms on which you work for us.
  • Checking you are legally entitled to work in the UK.
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions.
  • Providing the following benefits to you: pension, life insurance, private medical insurance, season ticket loans, childcare vouchers.
  • Liaising with your pension provider.
  • Administering the contract we have entered into with you.
  • Business management and planning, including accounting and auditing.
  • Conducting performance reviews, managing performance and determining performance requirements.
  • Making decisions about salary reviews and compensation.
  • Assessing qualifications for a particular job or task, including decisions about promotions.
  • Gathering evidence for possible grievance or disciplinary hearings.
  • Making decisions about your continued employment or engagement.
  • Making arrangements for the termination of our working relationship.
  • Education, training and development requirements.
  • Dealing with legal disputes involving you, or other employees, trustees, workers and contractors, including accidents at work.
  • Ascertaining your fitness to work.
  • Managing sickness absence.
  • Complying with health and safety obligations.
  • To prevent fraud.
  • To monitor your use of our information and communication systems to ensure compliance with our IT and network policies.
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
  • To conduct data analytics studies to review and better understand employee retention and attrition rates.
  • Equal opportunities monitoring.

Where you are an unsuccessful recruitment candidate, we may use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for the role.
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers) or process your job application successfully.

Change of purpose

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.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations and in line with our Data Protection Policy or other relevant policies.

3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to the pension schemes offered by the University, and in line with our Data Protection Policy or other relevant policies.

4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

5. We may use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.

6. We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Less commonly, we may process this type of information 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 information public. We may also process such information about employees, trustees, workers or contractors or former employees, trustees, workers or contractors in the course of legitimate business activities with the appropriate safeguards.

Our obligations as an employer as part of your employment with us

We will use your particularly sensitive personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. 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.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy or any other relevant policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary 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 information public.

We may also process such information about employees, trustees, workers or contractors or former employees, trustees, workers or contractors in the course of legitimate business activities with the appropriate safeguards.

We envisage that we may process information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences to determine whether an offer of employment is appropriate

We are allowed to use your personal information in this way to carry out our obligations and provided we have a lawful basis for doing so and in line with our Data Protection Policy or any other relevant policy.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.

2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

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 envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will 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 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 our group. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities 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 data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the University?

As former or current employee, worker or contractor we may share your personal information with other entities as part of our regular reporting activities on University performance, in the context of a reorganisation or University restructuring exercise, for system maintenance, external IT support and hosting of data.

What about other third parties?

As former or current employee, worker or contractor we may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the University. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available from the IT Department.

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 need to know and have a contract to provide services to the University. 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 IT Department.

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.

Data retention

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 data retention policy which is available from the HR intranet site. 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.

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. Once your personal data is no longer necessary to be processed we will securely destroy your personal information in accordance with our data retention policy.

Rights of access, correction, erasure, and restriction

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

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 have any incomplete or inaccurate information we hold about you corrected.
  • 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 relying on a legitimate interest (or those 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.
  • 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.
  • Request the transfer of your personal information to another party.

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 HR Department in writing.

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.

Right to withdraw consent

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 the HR Department. 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.

Data Protection Compliance

If you have any questions about this privacy notice or how we handle your personal information, please contact [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.