Employees, workers and agency workers - How we use your personal information

Keele 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, in accordance with the General Data Protection Regulation (GDPR).

Keele 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, workers and agency workers. 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 hold 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.

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.
  • Equalities monitoring data including date of birth, sex, disability and marital status
  • 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.
  • Copy of driving licence.
  • 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 start date, job titles, terms and conditions, periods of leave, work history, working hours, training records and professional memberships).
  • Performance information.
  • Disciplinary and grievance information.
  • CCTV footage and other information obtained through electronic means such as Keele card records.
  • Information about your use of our information and communications systems.
  • Photographs.

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

  • Information about your race or ethnicity, religious beliefs, and sexual orientation
  • Trade union membership.
  • 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 typically collect personal information about employees, workers and agency workers 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, credit reference agencies 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.

We use the University’s Employee Self Service system (Keele People) as a mechanism for you to keep your personal information up to date and we may use this to collect additional data

We will also obtain personal data about you from your interaction with university services e.g. CCTV, Keele card use, IT services and so on.

How we will use information about you

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

  1. Where we need to perform the contract (your contract of employment) we have entered into with you (or in preparation of that contract).
  2. Where we need to comply with a legal obligation.
  3. Where it is needed as a key part of our core tasks as a publically supported university (these will be tasks in the public interest for our official purposes as a public body).
  4. 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 (where we are processing your data for purpose outside our public tasks as a publically supported university)
  5. Where you have explicitly agreed to a particular use of your data (consent)

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

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

Conditon 1 above will include:

Making a decision about your recruitment or appointment; Determining the terms on which you work for us; Providing benefits to you (including pensions); Conducting performance reviews, managing performance and determining performance requirements; Making decisions about salary reviews and compensation and promotion; Gathering evidence for possible grievance or disciplinary hearings; Ascerttaining fitness to work; Managing sickness absence; Making decisions about your continued employment or engagement/terminating employment.

Conditon 2 above may include:

Paying you and dealing with tax authorities; Liasing with pension providers; managing our obligations under health and safety legislation and some equality monitoring requirements

Condition 3 or 4 may apply include:

Preventing fraud; conducting data analytics studies to review and better understand employee retention and attrition rates; managing research applications where salary costs is required to be processed and shared; the prevention or detection of crime (e.g. through CCTV).

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

How we will 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.
  3. Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our Data Protection Policy.
  4. Where it is needed to for the purposes of preventative or occupational medicine or for the assessment of your working capacity, subject to appropriate confidentiality safeguards.
  5. Where it is necessary for reasons of public health

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. 

Our obligations as an employer

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.
  • We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

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 envisage that we may hold information about criminal convictions.

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 manage our obligations to prevent and detect unlawful acts; to protect the public against dishonesty; preventing fraud and safeguarding children and vulnerable individuals.

Data Sharing

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

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 use a number of cloud based service providers who will or may store your personal data. These include Google (as part of the University's email and cloud storage provider). 

The University has a statutory requirement to share some of your personal data with the Higher Education Statistics Agency (HESA).This forms your HESA staff record which does not contain your name or contact details. Further information can be found at: www.keele.ac.uk/hr/publicationsandreporting/hesadatacollectionnotice/ or on the HESA website at: www.hesa.ac.uk/about/regulation/data-protection/notices

We may also share your data with Health Service provider (e.g. as part of Occupation Health services); with Learing providers and with the UKVI

Research applications: if you engage in research funding application, we may be required to share your data concerning career summary and salary details with collaborating institutions and/or funding bodies.

Data Security

We have put in place measures to protect the security of your information. Details of these measures are available at https://www.keele.ac.uk/informationsecurity/

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. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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 retention policy which is available from https://www.keele.ac.uk/recordsmanagement/recordsretentionschedule/. 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 you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our Data Retention Policy.

Your Rights

You have a number of rights with regards to how we process your information including access, correction, erasure and restriction.

Full details of these rights and how to exercise them can be found here: https://www.keele.ac.uk/informationgovernance/yourdata-yourrights/

Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. 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

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.