The University of Birmingham

Data Protection Policy

A. Introduction

During the course of our activities, the University collects and uses data about a wide
range of individuals, for example staff, students, applicants, visitors and people
taking part in our research. Maintaining the security and privacy of their personal data
is essential. Data Protection Law regulates how Personal Data must be processed to
protect privacy and provides individuals with rights in relation to their Personal Data.
This policy has been reviewed in light of the new Data Protection Act 2018 and the
implementation of the EU General Data Protection Regulations 2016 (‘GDPR’).

The University has policies in place, including this Policy, which are designed to
protect the accuracy, integrity and confidentiality of Personal Data and to ensure that
individuals are able to exercise their rights. Appendix 1 provides more information
about these other policies.

All Data Users must comply with this Policy when processing Personal Data on
behalf of the University.

Key words are defined in the Glossary of Terms in Appendix 2.

B. About the Policy

This Policy has been approved by the University’s Executive Board. It sets out the
University’s requirements as Data Controller when processing Personal Data.

It applies to all types of Personal Data, including Special Category Data. We process
data about current, past and prospective students and members of staff and their
family members, people who take part in our research, contractors and suppliers,
donors and supporters of the University, customers and clients of services and
facilities provided by the University and visitors to the University.

The Policy applies to all Personal Data processed by the University (which includes
any activity involving Personal Data, such as collecting, analysing, sharing,
transferring storing or deleting it) in any media or format. This includes electronic
Personal Data, photographic, video or audio Personal Data, Personal Data in the
form of human tissue samples, biometric or genomic data and paper records. It also
applies whether we collect the information from individuals, whether it is provided to
us by those individuals or other people or whether it is collected from other sources.

All staff, students, honorary and associate members of staff and any other University
of Birmingham Data Users must comply with this Policy, and disciplinary action can
be taken against those who do not comply, particularly in cases when there has been
deliberate, wilful or negligent disregard of the Policy and University requirements.

This Policy has the status of a Code of Practice in accordance with University
Regulation Section 9.

1
Revised Data Protection Policy 27.06.2018
 The University has appointed a Data Protection Officer to advise the University on
data protection law, monitor compliance, provide advice to Data Users, and ensure
that guidance, training and resources are available to Data Users. The Data
Protection Officer is the point of contact for individuals wishing to exercise their rights
in relation to their data, and for any contact with the Information Commissioner’s
Office. Contact details for the Data Protection Officer and the Information
Compliance Manager who deals with general queries and Subject Access Requests
are set out in Appendix 3, which also details other sources of information about data
protection.

C. Training

Whilst it is recognised that some staff will receive elements of Data Protection
training as part of their research requirements, all staff must complete the
University’s Baseline Data Protection Training, which is available on Canvas. Most
staff will be required to complete the module every two years, but some staff may be
required to complete it annually because of the nature of their work (eg if they work
with NHS patient data). New members of staff must complete this module as part of
their induction. It is the responsibility of managers to identify which additional Data
Protection Training modules (e.g. for researchers) should be completed by their staff
biennially and/or as part of their induction. Manager will receive notification of those
staff who are yet to complete the training from the academic year 2018/19, so that
they can ensure the training is completed.

It is the responsibility of each Programme Lead and for each supervisor of

Postgraduate Research Students to decide whether students must complete the
University’s Baseline Data Protection Training, or any additional Data Protection
Training modules identified as appropriate, at the outset of their programme or
annually, and for ensuring completion. More generally the module can be made
available to those students undertaking research which involves the use of Personal
Data, as required.

D. Data Protection Principles

When processing any personal data, there are 6 data protection principles which the
University must follow:

1. Lawfulness and fairness:

2. Purpose Limitation:
3. Data minimisation:
4. Accuracy:
5. Storage limitation:
6. Security:

Further information on the 6 Data Protection Principles can be found in Appendix 4.

The GDPR imposes further restrictions on the transfer of Personal Data outside the
European Union, to third countries or international organisations to ensure that the
level of protection of individuals afforded by the GDPR is not undermined.

2
Revised Data Protection Policy 27.06.2018
 The University has practical resources, advice and guidance to explain these
principles and how to apply them in practice. More information about where to find
these is set out in Appendix 3.

E. Lawful basis for processing

In addition, whenever the University processes Personal data there must be a valid
lawful basis for that processing. There are 6 potentially applicable lawful bases for
general processing of Personal data and 10 lawful bases for processing Special
Category Data. If Special Category Data is being processed, both a lawful basis for
general processing and an additional condition for processing this type of data must
be identified. These are listed in full in Appendix 5.

The University has practical resources, advice and guidance to help explain the
bases for processing and how to apply them in practice, and more information about
where to find these is set out in Appendix 3.

In practice, for many of the University’s activities it will rely on the legal basis that the
‘processing is necessary for the performance of a task carried out in the public
interest’ as this covers our work as a University in teaching and research. However
sometimes the University will need to rely on alternative bases.

Particular issues relating to the legal basis for processing Personal Data include:

 ‘Legitimate Interests’
The University can only rely on the ‘legitimate interests’ basis for processing
Personal Data when the University is NOT performing a task carried out in the
public interest. Appendix 6 sets out in Part A those activities which the University
has determined are University tasks and activities which are carried out in the
public interest (or in the exercise of official authority vested in it) and therefore are
not classified as being in the University’s ‘legitimate interests’ but rather as ‘public
tasks’. Appendix 6 Part B sets out those activities which it has determined are
not part of the University’s “public tasks” but which may be within its ‘legitimate
interests’. The Data Protection Officer must be notified before processing any
Personal Data on the basis of the legitimate interests of the University or a third
party in relation to an activity which is not listed in Part B of Appendix 6, to
confirm that ‘legitimate interest’ is the correct legal basis for processing.

• Criminal Offence Data

The requirements for processing Criminal Offence Data have been clarified
under the GDPR and the Data Protection Act 2018. These are set out in
Appendix 7.

The University’s Executive Board may approve additional policies from time to
time relating to the processing of Criminal Offence Data in line with the principles
set out in this Policy.

• ‘Substantial public interest’ condition

When processing Special Category Data in reliance on the ‘substantial public
interest’ basis, the requirements set out in Appendix 8 must be followed. The

3
Revised Data Protection Policy 27.06.2018
 University’s Executive Board may approve additional policies from time to time
relating to the processing of Special Category Data on the basis of ‘substantial
public interest’ in line with the principles set out in this Policy.

• Profiling and Automated Decision Making

When processing Personal Data by Profiling or Automated Decision Making, the
requirements set out in Appendix 9 must be followed.

F. Individuals Rights

In accordance with the GDPR and the Data Protection Act 2018 every Data Subject
has the following rights:

1. The right to be informed about how their Personal Data is to be used;

2. The right of access to their Personal Data held by the University and other
information;
3. The right to rectification if their Personal Data is inaccurate or incomplete;
4. The right to request the deletion or removal of Personal Data where there is no
compelling reason for its continued processing
5. The right to restrict processing in certain circumstances;
6. The right to data portability which allows individuals to obtain and reuse their
Personal Data for their own purposes across different services;
7. The right to object to processing in certain circumstances;
8. Rights in relation to automated decision making and profiling.

More information for Data Subjects wishing to exercise these rights can be found on
the University’s website at www.birmingham.ac.uk/privacy/index.aspx , and in
particular information about Subject Access requests can be found at
www.birmingham.ac.uk/university/governance/policies-regs/data-protection.aspx

The University must respond to any requests from Data Subjects wishing to exercise
these rights within strict time limits. Therefore, all requests from individuals wishing
to exercise rights must be forwarded to the Data Protection Officer immediately.
Similarly, staff must prioritise requests from the Data Protection Officer to assist with
processing a Data Subject request, to ensure compliance with Data Protection Laws.

G. Queries, Concerns and Complaints

Any queries or concerns about the processing of Personal Data by or on behalf of the
University or in relation to the exercise of any Data Subject rights should contact the
Information Compliance Officer in the first instance.

Complaints about the processing of Personal Data should be made to the Data
Protection Officer.

Any person who is not satisfied with the way the University has handled Personal
Data or a request to exercise Data Subject rights may complain to the ICO.

Contact details are set out in Appendix 3.

H. Personal Data Breaches

4
Revised Data Protection Policy 27.06.2018
 It is important that that Personal Data Breaches are identified and reported to the
Data Protection Officer as soon as possible. Some types of Personal Data Breach
must be reported to the Information Commissioner’s Office by the University’s Data
Protection Officer within 72 hours. Staff and students must therefore report Personal
Data Breaches or potential breaches as soon as possible, as the sooner action is
taken, the greater the opportunity to limit any potential damage which might be
caused by the incident. The Data Protection Officer will decide whether it is
necessary to report the Personal Data Breach to either the Information
Commissioner’s Office for the affected Data Subjects, or necessary third parties.

I. Changes to this Policy

This Policy was approved by the University’s Executive Board on [date]. The
University may change this Policy at any time, and where appropriate, we will notify
Data Subjects of those changes.

Appendices:

Appendix 1: University policies

Appendix 2: Glossary of Terms
Appendix 3: Sources of information, guidance and advice
Appendix 4: Data Protection Principles
Appendix 5: Legal bases for processing
Appendix 6: Part A – activities undertaken as a public body
Part B – activities not undertaken as a public body
Appendix 7: Processing Criminal Conviction Data
Appendix 8: Processing Special Category Data in the Substantial Public Interest
Appendix 9: Specific issues relating to Profiling and Automated Decision-Making

5
Revised Data Protection Policy 27.06.2018
 Appendix 1

University Policies

Data Management Policy

Information Security Policy -

https://intranet.birmingham.ac.uk/it/documents/public/Information-Security-Policy.pdf

General Conditions of Use of Computer and Network Facilities -

https://intranet.birmingham.ac.uk/it/documents/public/General-Conditions-of-Use-of-
Computing-and-Network-Facilities.pdf

Other IT policies, standards, guidance and procedures -

https://intranet.birmingham.ac.uk/it/governance/policy/index.aspx

Research Code of Practice

https://www.birmingham.ac.uk/Documents/university/legal/research.pdf

6
Revised Data Protection Policy 27.06.2018
 Appendix 2

Glossary of Terms

Automated Automated decision making is a decision made by

Decision-Making automated means without any human involvement.
Baseline Data Protection 30 minute training module available to all staff through
Training Canvas Virtual learning Environment
Criminal Offence Data Data relating to criminal convictions and offences or
related security measures.
Data Controller An organisation which determines the purposes and
means of processing Personal Data.
Data Processor An organisation or person which is responsible for
processing personal data on behalf of a Data Controller.
Data Protection Laws Any law which relates to the protection of individuals
with regards to the processing of Personal Data
including Regulation (EU) 2016/679 (known as the
General Data Protection Regulation or GDPR), the Data
Protection Act 2018 and all legislation enacted in the UK
in respect of the protection of personal data, and any
code of practice or guidance published by the
Information Commissioner’s Office.
Data Retention Principles Data retention principles are set out in the University’s
privacy notices on the website.
Data Subject An identifiable person who can be identified, directly or
indirectly from Personal Data.
Data Users Staff, students and others who have access to and use
Personal Data on behalf of the University.
Personal Data Any data or information or any combination of data
relating to an identifiable person who can be directly or
indirectly identified in particular by reference to an
identifier. These identifiers can include a name, an
identification number, location data, an online identifier
or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or
social identity of that person.
Personal Data Breach The accidental or unlawful destruction, loss, alteration,
unauthorised disclosure of, or access to, Personal Data,
including those that are the result of both accidental and
deliberate causes.
Profiling Any form of automated processing of Personal Data
consisting of the use of personal data to evaluate certain
personal aspects relating to a person, in particular to
analyse or predict aspects concerning that person’s
performance at work, economic situation, health,
personal preferences, interests, reliability, behaviour,
location or movements.
Special Category Data Personal Data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, or trade
union membership, and the processing of genetic data,
biometric data for the purpose of uniquely identifying a
natural person, data concerning health or data
concerning a natural person’s sex life or sexual
orientation.

7
Revised Data Protection Policy 27.06.2018
 Appendix 3

Sources of Information and Guidance

Data Protection Officer

 Data Protection Officer – Carolyn Pike OBE, Director of Legal Services, The
University of Birmingham, Edgbaston, Birmingham B15 2TT
Tel: 0121 414 3916
Email: [email protected]

General Queries and Data Subject Requests

 The Information Compliance Manager, The University of Birmingham, Edgbaston,

Birmingham B15 2TT
Tel: 0121 414 3916
Email: [email protected]

Data Protection Resources

 ICO resources https://ico.org.uk/for-organisations/guide-to-the-general-data-

protection-regulation-gdpr/whats-new/
 University resources - Legal Services intranet site
https://intranet.birmingham.ac.uk/legal-services/What-we-do/Data-
Protection/index.aspx (login required)
 Canvas data protection GDPR training module
https://intranet.birmingham.ac.uk/legal-services/What-we-do/Data-
Protection/index.aspx

Personal Data Breach Reporting

 Guidance and reporting form https://intranet.birmingham.ac.uk/legal-services/What-

we-do/Data-Protection/index.aspx

University Information Security Resources

 IT Security information and contact details

https://intranet.birmingham.ac.uk/it/security/index.aspx
 IT policies, standards and guidance
https://intranet.birmingham.ac.uk/it/governance/policy/index.aspx
 IT Security online training https://intranet.birmingham.ac.uk/it/security/training.aspx

Information Commissioner’s Office

 Information Commissioner's Office

Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF Tel: 0303 123 1113 (local rate) or 01625 545 745

8
Revised Data Protection Policy 27.06.2018
 Appendix 4

Data Protection Principles

1. Lawfulness and fairness:

Personal Data should be processed lawfully, fairly and in a transparent
manner.
For data to be processed transparently, individuals must be given clear and
adequate information before their Personal Data is collected to enable them
to understand how and why their Personal Data is to be used so they can
take an informed decision about whether or not to provide the data. This is
often done using a Privacy Notice. The University has prepared separate
privacy notices for the different categories of people the University processes
information about, for example, students, staff, alumni, visitors, etc, which are
on the University website.

For data to be processed lawfully, one of the legal bases set out in Data
Protection Law must also apply – see below.

2. Purpose Limitation:
Personal Data should be collected for specified, explicit and legitimate
purposes.
It should not be further used or re-used for new or different purposes (unless
one of the exceptions in Data Protection Law applies).

3. Data minimisation:
Personal Data processed should be adequate, relevant and limited to what is
necessary in relation to the specified purposes for which they are processed.
Whenever possible, Personal Data should be anonymised or pseudonymised
at the earliest opportunity.

4. Accuracy:
Personal Data processed should be accurate and, where necessary, kept up
to date.

5. Storage limitation:
Personal Data should be kept in a form which permits identification of
individuals for no longer than is necessary for the purposes for which the
Personal Data are processed.

When no longer needed for the purpose for which it was collected, and if
there is no lawful basis for continuing to keep it, the Personal Data must be
either fully anonymised or deleted in accordance with the University’s high
level Data Retention Principles and any relevant departmental data retention
schedule.

6. Security:

9
Revised Data Protection Policy 27.06.2018
Personal Data should be processed in a manner that ensures appropriate
security of the Personal Data including protection against unauthorised or
unlawful processing and against accidental loss, destruction or damage,
using appropriate technical or organisational measures.

10
Revised Data Protection Policy 27.06.2018
 Appendix 5

Legal bases for processing

6 legal bases for general processing of Personal Data

Processing shall be lawful only if and to the extent that at least one of the following applies:

(a) the data subject has given consent to the processing of his or her personal data for one or more
specific purposes;

(b) processing is necessary for the performance of a contract to which the data subject is party or in
order to take steps at the request of the data subject prior to entering into a contract;

(c) processing is necessary for compliance with a legal obligation to which the data controller is
subject;

(d) processing is necessary in order to protect the vital interests of the data subject or of another
natural person;

(e) processing is necessary for the performance of a task carried out in the public interest or in the
exercise of official authority vested in the data controller;

(f) processing is necessary for the purposes of the legitimate interests pursued by the data
controller or by a third party, except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection of personal data, in
particular where the data subject is a child. (This does not apply to processing carried out by public
authorities, such as Universities, in the performance of their public tasks).

10 legal bases for processing Special Category Personal Data

(a) the data subject has given explicit consent to the processing of those personal data for one or
more specified purposes;

(b) processing is necessary for the purposes of carrying out the obligations and rights of the data
controller or of the data subject in the field of employment and social security (subject to the Data
Protection Act 2018);

(c) processing is necessary to protect the vital interests of the data subject or of another natural
person where the data subject is physically or legally incapable of giving consent;

(d) processing is carried out in the course of its legitimate activities with appropriate safeguards by a
foundation, association or any other not-for-profit body with a political, philosophical, religious or
trade union aim and on condition that the processing relates solely to the members or to former
members of the body or to persons who have regular contact with it in connection with its purposes
and that the personal data are not disclosed outside that body without the consent of the data
subjects;

11
Revised Data Protection Policy 27.06.2018
(e) processing relates to personal data which are manifestly made public by the data subject;

(f) processing is necessary for the establishment, exercise or defence of legal claims or whenever
courts are acting in their judicial capacity;

(g) processing is necessary for reasons of substantial public interest, on the basis of Union or
Member State law which shall be proportionate to the aim pursued, respect the essence of the right
to data protection and provide for suitable and specific measures to safeguard the fundamental
rights and the interests of the data subject;

(h) processing is necessary for the purposes of preventive or occupational medicine, for the
assessment of the working capacity of the employee, medical diagnosis, the provision of health or
social care or treatment or the management of health or social care systems and services on the
basis of Union or Member State law or pursuant to contract with a health professional and subject
to safeguards;

(i) processing is necessary for reasons of public interest in the area of public health, such as
protecting against serious cross-border threats to health or ensuring high standards of quality and
safety of health care and of medicinal products or medical devices, on the basis of Union or Member
State law which provides for suitable and specific measures to safeguard the rights and freedoms of
the data subject, in particular professional secrecy; L 119/38 EN Official Journal of the European
Union 4.5.2016

(j) processing is necessary for archiving purposes in the public interest, scientific or historical
research purposes or statistical purposes, respect the essence of the right to data protection and
provide for suitable and specific measures to safeguard the fundamental rights and the interests of
the data subject.

12
Revised Data Protection Policy 27.06.2018
 Appendix 6

Tasks which are and which are not performed in the public interest or in the exercise
of official authority vested in the University

Note: The lists below are not exhaustive. Decisions on whether a particular activity
or task is carried out in the public interest or in the exercise of official authority
vested in the University must be taken in consultation with the Data Protection
Officer or her nominee

Part A – Tasks which are performed in the public interest or in the exercise of
official authority vested in the University

 Teaching;
 Research;
 The conferral of awards;
 Museums, galleries, cultural collections.

Part B – Tasks which are not performed in the public interest or in the exercise
of official authority vested in the University, but which may use the legal
basis for processing as within the University’s ‘legitimate interests’.

 Fundraising;
 Alumni relations;
 Provision of hotel and conference facilities;
 Events hosted on University premises which are not organised by or
on behalf of the University;
 Services and facilities provided for the business community, third party
organisations and members of the public.

13
Revised Data Protection Policy 27.06.2018
 Appendix 7

Specific issues relating to processing Criminal Offence Data

This Appendix sets out the University’s requirements in relation to the processing of Criminal
Offence Data for the following purposes.

Processing of Criminal Offence Data to which this Policy Applies

This will include, but is not limited to, the following processing of Personal Data:

a. Criminal Offence Data including DBS checks relating to staff and workers in
connection with their employment or work or application for employment or work with
the University if it is appropriate, given the nature of the role, and when it is
authorised by law and in particular the Rehabilitation of Offenders Act 1974 as
amended. This is processed to comply with employment and other laws, to consider
suitability for employment or continued employment or to consider safeguarding
issues.

b. Criminal Offence Data relating to and disclosed by individuals who apply to the
University for a place on a programme of study which requires a satisfactory
Disclosure & Barring Service (DBS) check to be carried out before the individual can
be accepted on to, or continue with, a programme of study or in connection with a
module or other component comprising part of a programme of study. This is
necessary to protect the interests of patients, clients, children and vulnerable people.

c. Criminal Offence Data relating to and disclosed by individuals who apply to the
University for a place on any other programme of study*.

d. Criminal Offence Data relating to Registered Students who are convicted of a

criminal offence between the date on which they are offered a place on a programme
of study and the date on which they leave the University*;

*Criminal Offence Data referred to in c. and d. above is processed in order to assess

and, if necessary, manage appropriately and proportionately any risks to the Data
Subject, other students, staff, service users or others with whom the Data Subject will
have contact as a member of the University. This is under review and the Policy may
be revised to reflect any agreed changes.

e. Criminal Offence Data in relation to participants in research conducted in the public

interest by the University.

f. Criminal Offence Data in relation to volunteers working on behalf of the University in

regulated activity with children and adults.

Requirements
Before collecting and processing Criminal Offence Data:

14
Revised Data Protection Policy 27.06.2018
  A Data Protection Impact Assessment must be carried out by the relevant School or
Professional Service and approved by the Data Protection Officer (or nominee). This
must be retained and regularly reviewed and revised as necessary for the duration of
the processing;
 Appropriate measures, including technical and organisational measures, are
implemented to ensure appropriate security of the Personal Data, including
protection against unauthorised or unlawful processing and against accidental loss,
destruction or damage. These must be regularly reviewed and revised as necessary
for the duration of the processing, and records of those reviews must be retained;
 Staff who will have access to this data must have completed appropriate data
protection training before processing the data;
 A clear and transparent Privacy Notice has been provided to Data Subjects which
includes a specific indication of how long the Personal Data will be retained for and
when it is likely to be erased. The Data Protection Officer (or nominee) must be
consulted in relation to the Privacy Notice;
 A record is maintained which must include the following information:
(a) the relevant condition for processing in the Data Protection Act 2018 which is
relied on;
(b) the legal basis for processing;
(c) whether the data is retained and erased in accordance with the applicable
Retention Principles and the information set out in the relevant Privacy Notice
relating to retention and erasure and, if it is not, the reasons for not following
those policies.

Advice on compliance with these requirements can be obtained from Legal Services.

15
Revised Data Protection Policy 27.06.2018
 Appendix 8

Policy for Processing Special Category Data based on the ‘Substantial Public Interest’
condition for processing

Before processing Personal Data when relying on the ‘substantial public interest’ condition
for processing:

 A Data Protection Impact Assessment must be carried out and approved by the Data
Protection Officer (or nominee). This must be retained and regularly reviewed and
revised as necessary for the duration of the processing;
 Appropriate measures, including technical and organisational measures, must be
implemented to ensure appropriate security of the Personal Data, including
protection against unauthorised or unlawful processing and against accidental loss,
destruction or damage. These must be regularly reviewed and revised as necessary
for the duration of the processing, and records of those reviews must be retained;
 Those who are to have access to this data must have completed appropriate data
protection training before processing the data;
 A clear and transparent Privacy Notice has been provided to Data Subjects which
includes a clear indication of how long the Personal Data will be retained and when it
is likely to be erased. The Data Protection Officer (or nominee) must be consulted in
relation to the Privacy Notice;
 A record is maintained which must include the following information:
(a) the relevant condition in the Data Protection Act 2018 which is relied on;
(b) the legal basis for processing;
(c) whether the data is retained and erased in accordance with the applicable
Retention Principles and the information set out in the relevant Privacy Notice
relating to retention and erasure and, if it is not, the reasons for not following
those policies.

16
Revised Data Protection Policy 27.06.2018
 Appendix 9

Policy in relation to Profiling and Automated Decision Making

The ICO has produced guidance on Profiling and Automated Decision Making which is
available on its website which should be considered before considering any activity or task
which involves Profiling or Automated Decision Making.

Before starting a task or activity which involves Profiling or Automated Decision Making, the
following steps must be carried out:

1. A Data Protection Impact Assessment (DPIA) must be carried out. The Data
Protection Officer must be informed and consulted as part of that exercise.

2. A Privacy Notice must inform individuals if their data will be used for solely
automated decision-making processes with legal or similarly significant effects. This
must explicitly set out the Data Subject’s rights. The Privacy Notice should be
approved by the Data Protection Officer.

3. The DPIA must be kept under regular review, and records of those reviews must be
retained.

17
Revised Data Protection Policy 27.06.2018