Data Privacy Notice
1. Data Protection Principles
2. What is personal data
3. About the Report + Support took at Keele.
4. Categories of personal data to be processed
5. How we will use the information about you.
6. Data Sharing
7. Data Retention
8. Your Rights
9. DPO (data protection Officer)
Keele University is committed to looking after your data and is committed to protecting your personal data.
Please read this ancillary privacy notice carefully as it details the specific data processing activities which the Human Resources and Student Services teams at Keele will undertake in relation to data submitted for Report + Support. This Privacy Notice should be read in conjunction with other privacy information which you can find at: www.keele.ac.uk/privacynotices/
1. 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.
2. What is 'personal data'?
Personal data' means any information which identifies you as an individual. It may include your name but it may also be other information such as your date of birth, nationality and gender which when combined identify you.
It does not include information which does not relate to an identified or identifiable individual, or to personal data rendered anonymous in such a manner that the individual is not or no longer identifiable.
‘Sensitive personal data’ or 'special categories of personal data' such as information about racial or ethnic origin, political opinions, religious beliefs or other similar beliefs, trade union membership, physical or mental health and sexual life, are given a high level of protection under data protection law.
Personal data relating to criminal convictions and offences are also treated as requiring additional protections.
3. About the Report + Support tool at Keele
The Report and Support tool provides staff and students with a portal to report and also seek support in respect of all forms of bullying, harassment and discrimination and sexual misconduct.
Reports may be made by staff and students and may be either:
(a) anonymous, whereby no names or other information that could be used to identify the individual making the report are provided.
or
(b) named, whereby the names and contact details of the individual making the report are included, in addition to names or other information which could be used to identify third parties.
Further detail on the data collected and how we will use that data in each of the above circumstances is set out below.
Please note that where you make a report through the Report and Support tool, Keele will usually disclose information to its staff members on a need-to-know basis only.
In circumstances in which: (a) an anonymous report is received (in which case action will be taken on a 'no names' basis); or (b) you have made a named report, but you do not wish to take your report further, we will still offer required support.
Please also note that information relating to an individual's criminal convictions or offences must not be included in a report. We also strongly discourage the inclusion of speculation on an individual's potential criminal convictions and offences in a report. Any criminal convictions information included in a report will be removed before the report is processed.
4. Categories of personal data to be processed
• Name/Surname
• Contact Details
• Student number
• Thoughts/opinions
• Job role (If provided)
Where provided, this data is processed on the basis of the following UK GDPR conditions: Article 6(1)(e) – a task in the public interest; Article 6(1)(b) – for the performance of a contract.
Categories of sensitive personal data to be processed
• Race
• Ethnic origin
• Health data
• Religion or philosophical beliefs
• Sexual orientation
Where provided, this data is processed on the additional condition of: Article 9(2)(g) – substantial public interest.
5. How we will use information about you
The Report + Support tool provides staff and students with a portal to report and seek support in respect of issues of bullying, harassment, all forms of discrimination and sexual misconduct.
We may use the information you provide to:
▪ Help us to identify the best person for you to speak to in relation to your report;
▪ Provide the person with your contact details (if you have provided them) and some useful background information that will enable them to understand the nature of your concern or the incident you are reporting.
▪ Where applicable, review your report and take further action if required. We will write to you to keep you informed of what we are doing.
▪ Once we have concluded any actions we have taken, we will then write to you to inform you of the outcome if you have made a named report.
6. Data Sharing
Owing to the University’s duty of care, personal data may be shared with the police or other relevant external body where reports received include allegations relating to vulnerable individuals or raise safeguarding issues.
We will only share information with third parties when we have a lawful basis to do so. We require third parties to respect the security of personal data and to treat it in accordance with the law.
We do not transfer your personal data outside the UK in relation to the Report and Support tool.
7. Data Retention Period
Identifiable data submitted to the Report + Support system will be retained for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal or reporting requirements.
Identifiable data will be held for the academic year in which it was submitted to the Report + Support system plus two years. In the event that identifiable data forms the basis for further investigation by the University, that data will then be handled in accordance with the relevant processes and will be retained in line with the University’s Records Retention Schedule.
Anonymised information will be used to monitor the University’s work in relation to Report + Support, but individuals will not be identifiable from this information.
8. Your Rights
You have a number of rights with regards to how we process your information including access, correction and restriction. Full details of these rights and how to exercise them can be found at: www.keele.ac.uk/informationgovernance/yourdata-yourrights/
9. Data Protection Officer (DPO)
If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. 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.
DPO contact details: dpo@keele.ac.uk
ICO contact details: www.ico.org.uk
10. Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time and will keep it under regular review.