Data Protection Policy

Introduction

The University needs to keep certain personal data, for example about its staff and students, to fulfil its purpose and to meet its legal obligations to funding bodies and government. To comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. To do this, the University must comply with the Data Protection Principles which are set out in the Data Protection Act, 1998.

Principles

Personal data shall:

  • Be obtained and processed fairly and lawfully and shall not be processed unless certain conditions are met.
  • Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose.
  • Be adequate, relevant and not excessive for those purposes.
  • Be accurate and kept up to date.
  • Not be kept for longer than is necessary for that purpose.
  • Be processed in accordance with the data subject's rights.
  • Be kept secure from unauthorised access, accidental loss or destruction.
  • Not be transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data.

The University and all its staff who process or use personal information must ensure that they follow these principles at all times. In order to ensure that this happens, the University has developed this Data Protection Policy.

Status of the Policy

This policy has been approved by the University Council and any breach will be taken seriously and may result in more formal action.

Any member of staff or student who considers that the policy has not been followed in respect of personal data about themselves should raise the matter with their Head of Department or the University Data Protection Officer, Kevan Ryan, in the first instance.

Notification of Data Held and Processed

  • All staff, students and other users are entitled to
  • Ask what information the University holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed what the University is doing to comply with its obligations under the 1998 Data Protection Act.

Responsibilities of Staff and Students

All staff and students are responsible for:

  • Checking that any personal data that they provide to the University is accurate and up to date.
  • Informing the University of any changes to information which they have provided, e.g. changes of address.
  • Checking any information that the University may send out from time to time, giving details of information that is being kept and processed.

If, as part of their responsibilities, staff collect information about other people (e.g. about students course work or personal circumstances, or about members of staff in their department or research group), they must comply with the Policy and with the Data Protection Guidance Notes.

Students who use the University computer facilities may, from time to time, process personal data. If they do so they must notify the University Data Controller.

Data Security

The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. All staff are responsible for ensuring that:

  • Any personal data which they hold is kept securely
  • Personal information is not disclosed either orally or in writing or otherwise to any unauthorised third party.

Detailed advice on data security is contained in the Data Protection Guidance Notes.

Rights to Access Information

Staff and students and other users of the University have the right to access any personal data that is being kept about them on computer and also have access to paper-based data held in certain manual filing systems. Any person who wishes to exercise this right should make the request in writing to the University's Data Protection Officer, using the standard Data Protection Enquiry/Subject Access Request Form. The University will make a charge on each occasion that access is requested.

The University aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of a completed form unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.

Publication of University Information

Information that is already in the public domain is exempt from the 1998 Act. This would include, for example, information on staff contained within externally circulated publications such as the University Calendar. Any individual who has good reason for wishing details in such publications to remain confidential should contact the University Data Protection Officer.

Subject Consent

The need to process data for normal purposes has been communicated to all staff, and to students at registration. In some cases, if the data is sensitive, for example information about health, race or gender, express consent to process the data must be obtained. Processing may be necessary to operate University policies, such as health and safety and equal opportunities.

Retention of Data

The University will keep some forms of information for longer than others. The University has a Records Retention Schedule, which can be obtained via the web at http://www.liverpool.ac.uk/csd/records-management/retention-schedule/

The University's Designated Data Controller

The University is the data controller under the Act and is therefore ultimately responsible for implementation. However, day to day matters will be dealt with by the University Data Protection Officer, Kevan Ryan, Legal & Compliance, Ext. 42110.  Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the University Data Controller.