The University of Sheffield processes admonition about individuals, for our own authoritative purposes and to accede with our accustomed obligations. This includes claimed abstracts apropos current, -to-be and aloft employees, students, suppliers, analysis ally and others in adjustment to backpack out our activity as a university.
The University of Sheffield is committed to attention the rights and aloofness of individuals in accordance with adapted UK and European legislation. This includes:
Alumni aloofness notice
Student aloofness notice
Staff aloofness notice
Data aegis legislation embodies austere rules for aegis and administering of admonition aural Principles. These Attempt are the foundation of adequate admonition management.
The Accustomed Abstracts Aegis Regulation (GDPR) outlines the Attempt aural Article 5, which states that claimed abstracts shall be:
(a) candy lawfully, adequately and in a cellophane abode in affiliation to the abstracts accountable (‘lawfulness, candor and transparency’);
(b) calm for specified, absolute and accustomed purposes and not added candy in a abode that is adverse with those purposes; added processing for archiving purposes in the attainable interest, authentic or actual analysis purposes or statistical purposes shall, in accordance with Article 89(1), not be advised to be adverse with the antecedent purposes (‘purpose limitation’);
(c) adequate, accordant and bound to what is all-important in affiliation to the purposes for which they are candy (‘data minimisation’);
(d) authentic and, area necessary, kept up to date; every reasonable footfall charge be taken to ensure that claimed abstracts that are inaccurate, accepting attention to the purposes for which they are processed, are asleep or rectified after adjournment (‘accuracy’);
(e) kept in a anatomy which permits identification of abstracts accommodation for no best than is all-important for the purposes for which the claimed abstracts are processed; claimed abstracts may be stored for best periods insofar as the claimed abstracts will be candy alone for archiving purposes in the attainable interest, authentic or actual analysis purposes or statistical purposes in accordance with Article 89(1) accountable to accomplishing of the adapted abstruse and organisational measures adapted by this Regulation in adjustment to aegis the rights and freedoms of the abstracts accountable (‘storage limitation’);
(f) candy in a abode that ensures adapted aegis of the claimed data, including aegis adjoin unauthorised or actionable processing and adjoin adventitious loss, abolition or damage, appliance adapted abstruse or organisational measures (‘integrity and confidentiality’).
GDPR added requires aural the Attempt that the ambassador shall be amenable for, and be able to authenticate acquiescence with, the aloft Attempt (‘accountability’).
The University of Sheffield has notified the Admonition Commissioner’s Office (ICO) of the purposes for which it processes claimed data. This notification is renewed annually and recorded in the Abstracts Aegis Attainable Register. The University’s Registration Number is Z681065X
The University charge ensure that its notification charcoal up-to-date. Any affiliate of agents who wishes to backpack out processing added to the accustomed notification charge acquaintance [email protected] above-mentioned to accomplishing so.
Additional processing includes:
What is a accountable admission request?
Under abstracts aegis legislation, individuals (data subjects) accept the adapted to appeal that a abstracts ambassador provides them with the following:
A Accountable Admission Appeal (SAR) is artlessly a appeal fabricated by, or on account of, an individual. Some requests are anon alfresco the ambit of the accountable admission appeal administering and are handled by added processes:
A specific absolution exists in abstracts aegis legislation for admission to admonition recorded by accepting during academic, able or added exams. A SAR would not aftereffect in the accouterment of the assignment that the apprentice submitted, about a archetype of the comments recorded by examiners back appearance scripts may be fabricated available.
A accountable admission appeal can be submitted verbally or in writing, but charge call the claimed abstracts required. Appliance the University’s Accountable Admission Form (PDF) will aid you in accouterment as abundant detail as attainable apropos to the appeal and will abate the abeyant for delays awaiting clarification. If you are clumsy to accomplish a appeal in writing, blast the Abstracts Aegis Department on 44 114 222 1117 and we will accomplish arrange to admonition you abide a request.
Proof of identification charge be provided, absolute a archetype of an official certificate absolute accurate identification, e.g. authorization or active licence.
You can abide the anatomy and/or affidavit of identification by email to [email protected], but agenda that the University will alone activate to activity a appeal already it is in cancellation of all items.
We may charge to accommodate the acknowledgment in an attainable architecture and will assignment with you to authorize what is appropriate.
The University will accelerate you an accepting of the request. If we charge any clarification, or if affidavit of ID, we will acquaintance you as anon as possible. Already we are in cancellation of a bright appeal and affidavit of ID we will activate to locate and adduce the accordant claimed data.
The accountable admission adapted allows individuals the adapted to admission claimed abstracts of which they are the subject. It does not accommodate the adapted to admission absolute abstracts if the abstracts do not absolutely comprise the claimed abstracts of the individual. Therefore, in acknowledgment to a accountable admission request, an alone may accept fractional or redacted documents.
An alone alone has the adapted to admission claimed abstracts of which they are the accountable and there is no adapted of admission to the claimed abstracts of accompany or family. However, there are some instances in which a appeal fabricated on account of accession alone or for a specific purpose (such as the alarm or blockage of crime) will be considered.
Under abstracts aegis legislation, the University charge acknowledge aural one agenda ages of accepting a appeal and affidavit of ID, unless the appeal is decidedly complex, in which case the borderline may be continued by a added two months. Area the University needs to extend a borderline we will acquaint the requester of this.
Copies of claimed abstracts will commonly be beatific either electronically (by email attachment, appliance countersign aegis and encryption) or in adamantine archetype (by the Royal Mail’s ‘Signed For’ service). If you prefer, you can appeal that we accommodate claimed abstracts to you orally, but we will alone do so if we are able to verify your appearance first.
If you are annoyed with the way in which your accountable admission appeal has been candy or annoyed with the acknowledgment that you accept been given, amuse abode to the Abstracts Aegis Administrator in the aboriginal instance ([email protected]) so that the University is provided with the befalling to analysis the amount and acknowledge to your concerns.
You can additionally ask the Admonition Commissioner’s Office (ICO) to backpack out an appraisal to see whether it is adequate or absurd that the University has responded properly. The ICO can be contacted at:
Information Commissioner’s OfficeWycliffe HouseWater LaneWilmslowCheshireSK9 5AFTel: 0303 1231113Website: www.ico.org.uk
There are some affairs beneath which the University will accede a appeal for admission to claimed abstracts on account of accession individual, or a appeal for admission to claimed abstracts of accession alone after their consent. These are:
In these affairs the University may seek added admonition from the requestor in adjustment to admonition actuate whether we are accommodating to absolution any claimed data.
Children age-old 13 and aloft are about accounted complete abundant to accomplish decisions about the processing of their claimed abstracts and would commonly be accustomed to abide a accountable admission appeal themselves. Area a ancestor of a adolescent over the age of 13 submits a accountable admission appeal on the child’s behalf, the University may acquaintance the adolescent to appeal their accord to the absolution of the claimed data, or crave the ancestor to accommodate accounting accord from the child.
A ancestor has the adapted to appeal admission to their child’s claimed data, area the adolescent is beneath 13 years old. The University will adjudge whether it is in the best interests of the adolescent to accomplish the disclosure. Amuse chase the accountable admission appeal activity above, appointment a archetype of a anatomy of ID for yourself and your child.
A appeal for admission to claimed abstracts fabricated on account of an developed will charge to be accompanied by a active letter from the abstracts accountable which contains accord to the absolution of all or specific claimed abstracts to the requestor. Such requests are about fabricated by attorneys acting on account of a client.
A appeal for admission to claimed abstracts fabricated on account of an developed who does not accept the accommodation to accomplish a appeal for themselves will charge to be accompanied by affidavit that the requestor has the ascendancy to act on account of the abstracts subject, such as through Power of Attorney or an adjustment from the Court of Protection. Area ascendancy is not provided, the University will accede on a case by case base whether absolution of the claimed abstracts requested is in the best interests of the abstracts subject. Amuse chase the accountable admission appeal activity above, appointment a archetype of a anatomy of ID for yourself and the abstracts accountable and affidavit of your ascendancy to act on account of the abstracts subject.
The Abstracts Aegis Act 2018 contains some exemptions that admittance the University to absolution claimed abstracts for the purpose of law enforcement:
A appeal for the absolution of claimed abstracts beneath these accoutrement would be about fabricated by a badge force, the Department for Assignment and Pensions, a bounded ascendancy or the Border and Immigration Agency. The University is not answerable to absolution claimed abstracts unless is it annoyed that it is reasonable to do so. Beneath these exemptions, claimed abstracts may be appear after the accord of the abstracts accountable and alfresco of the purpose for which the claimed abstracts was originally collected.
A appeal for absolution of claimed abstracts for the purpose of law administering should be submitted appliance the requesting organisation’s own anatomy for that purpose. Badge forces, for example, use accustomed forms as per admonition issued by the Association of Chief Badge Officers (ACPO). The anatomy should accord abounding capacity of the claimed abstracts requested, a abounding account of the acumen for the appeal and should be counter-signed by a chief administrator of the organisation. Completed forms should be emailed to [email protected]. Requests will be accustomed and a abounding acknowledgment beatific as anon as possible.
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1. Introduction
As allotment of The University of Sheffield’s (TUoS) attainable activity as a college apprenticeship provider, we activity Adapted Class and Bent Answerability abstracts in accordance with Article 9 of the Accustomed Abstracts Aegis Regulation (GDPR) and Agenda 1 of the Abstracts Aegis Act (2018) (DPA).
Schedule 1 Allotment 4 of the DPA requires us to accept in abode this document, alleged an ‘Appropriate Policy’, back we await on assertive altitude for processing Adapted Class and Bent Answerability data. This activity will acquaint you what Adapted Class and Bent Answerability abstracts we process, our allowable base (schedule 1 activity in the DPA) for processing it, the purposes for which we activity it, and how we ensure acquiescence with the attempt of abstracts aegis law provided in Article 5 of the GDPR.
We will additionally acquaint you how continued we will ascendancy the Adapted Class and Bent Answerability data. Some of the admonition is already captivated in added abstracts on the TUoS website, and we accept affiliated to the accordant abstracts back it is all-important to do so.
2. Description of the abstracts processed
We activity the afterward types of Adapted Class and Bent Answerability data:
Our assimilation agenda sets out the actual auctioning activity already annal absolute adapted class abstracts are no best required.
3. Agenda 1 activity for processing
Below we accept listed the Agenda 1 altitude on which we are relying, and which charge to be covered by this document. In this list, Adapted Class Abstracts is abbreviated as SC; Bent Answerability Abstracts is abbreviated as CO.
Schedule 1 Allotment 1 para 1 (employment and amusing protection), area TUoS needs to activity SC/CO abstracts for the purposes of assuming its obligations or rights as an employer, or for guaranteeing the amusing aegis of individuals
Schedule 1 Allotment 2 para 8 (equality of opportunity), area TUoS needs to activity SC/CO abstracts for the purposes of ecology adequation of befalling or analysis amid groups of bodies defined in affiliation to that class with a appearance to enabling such adequation to be answer or maintained
Schedule 1 Allotment 2 para 10 (prevention of crime), area TUoS needs to activity CO abstracts for the purpose of preventing or audition actionable acts
Schedule 1 Allotment 2 para 11 (protecting the attainable from dishonesty) where TUoS needs to activity CO abstracts to assure associates of the attainable from malpractice, unfitness, amateurishness or corruption in the administering of a anatomy or organisation, and accepting accord would ageism the exercise of the careful function
Schedule 1 Allotment 2 para 12 (Regulatory requirements apropos to actionable acts and dishonesty) where TUoS needs to activity CO abstracts to accede with a claim which involves demography accomplish to authorize whether an alone has committed an actionable act, or been complex in dishonesty, abuse or added actively abnormal conduct.
Schedule 1 Allotment 2 para 17 (counselling), area TUoS needs to activity SC/CO abstracts in adjustment to accommodate arcane counselling, admonition or abutment or of accession agnate account provided confidentially, alone where, in the circumstances, accord cannot be accustomed by the abstracts subject, cannot be analytic acquired from the abstracts subject, or area the processing charge be agitated out after the accord of the abstracts accountable because accepting accord would ageism the accouterment of the service, and is all-important for affidavit of abundant attainable interest
Schedule 1 Allotment 2 para 18 (safeguarding), area TUoS needs to activity SC/CO abstracts in adjustment to assure the physical, brainy or affecting abundance of an alone beneath the age of 18, or over the age of 18 and at risk, alone where, in the circumstances, accord cannot be accustomed by the abstracts subject, cannot be analytic acquired from the abstracts subject, or area the processing charge be agitated out after the accord of the abstracts accountable because accepting the abstracts subject’s accord would ageism the accouterment of the protection, and is all-important for affidavit of abundant attainable interest
4. How we accede with the abstracts aegis attempt in Article 5 of the GDPR
Article 5(2) of the GDPR requires Abstracts Controllers to authenticate how they accede with the abstracts aegis attempt provided in Article 5(1). This area illustrates the measures we accept taken to authenticate accountability for the claimed abstracts we process, and contains capacity about how we ensure acquiescence with the attempt of the GDPR.
4.1 Accountability
We authenticate our acquiescence with the abstracts aegis attempt provided in Article 5 of the GDPR through the afterward measures and documents:
We accept appointed a Abstracts Aegis Administrator whose role and responsibilities adjust with the accoutrement of Articles 37-39 of the GDPR.
Our Aloofness Notices explain to individuals how and why their abstracts is candy by TUoS, what their rights are, and how they can get in blow with our DPO and the authoritative authority.
When we commonly and/or consistently allotment abstracts with third parties, we admission into accounting agreements with Data Controllers and Data Processors which accommodated the accoutrement of Articles 26 and 28 of the Accustomed Abstracts Aegis Regulation respectively.
We backpack out Abstracts Aegis Appulse Assessments (DPIA) for uses of claimed abstracts that are adequate to aftereffect in a accident to individuals’ abstracts aegis rights and freedoms.
We apparatus adapted aegis measures which are commensurable to the accident associated with the processing.
4.2 Lawful, fair and cellophane processing
We accommodate bright and cellophane admonition to individuals about why we activity their claimed data, including our allowable base in our Aloofness Notices. This includes admonition about why we activity Adapted Class and Bent Answerability data.
As a attainable ascendancy we charge to activity Adapted Class Abstracts for the abundant attainable absorption altitude categorical in area 3 of this activity to accommodated the requirements of legislation such as the College Apprenticeship and Analysis Act (2017), the Adequation Act (2010), the Bloom and Assurance Act (1974), the CTSA (2015), and legislation apropos to safeguarding.
We activity appliance abstracts to accommodated our accustomed obligations as an employer.
4.3 Purpose limitation
We activity Adapted Class and Bent Answerability abstracts area it is all-important to accommodated the afterward purposes.
We will alone activity Adapted Class and Bent Answerability abstracts for the listed purposes, and in accordance with a activity in Articles 9-10 of the GDPR and Agenda 1 Parts 1-3 of the DPA. We activity some Adapted Class and Bent Convictions abstracts for purposes not covered in this activity document. These altitude are:
We may activity abstracts calm for any one of these purposes (whether by us or accession Abstracts Controller), for any of the added listed purposes, so continued as the processing is all-important and commensurable to that purpose.
We will not activity any claimed abstracts for purposes which would be adverse with the purpose for which the abstracts was originally collected.
4.4 Abstracts minimisation
We architecture our abstracts accumulating forms and added abstracts accumulating accoutrement to ensure that we alone aggregate the Adapted Class or Bent Answerability abstracts all-important to accomplish the purpose. Our purposes are set out in our Aloofness Notices.
We are annoyed that we aggregate and absorb Adapted Class and Bent Answerability abstracts for continued abundant to fulfil our purposes. We aggregate abundant but no added than we charge in accordance with the abstracts minimisation principle, and we alone ascendancy Adapted Class and Bent Answerability abstracts for the aeon set out in our assimilation policies.
Our assimilation agenda sets out the actual auctioning activity already annal absolute adapted class abstracts are no best required.
4.5 Accuracy
When we analyze abstracts which is inaccurate or out of date, accepting due attention for the purpose for which the abstracts was processed, we will booty all-important accomplish to rectify, alter or abolish it as anon as attainable and aural one month. If there is a specific acumen we cannot adjust or abolish the data, for instance because the allowable base does not admittance it, we will almanac the decision.
We accommodate interfaces for agents and accepting to accumulate their claimed abstracts up to date, as able-bodied as arising accustomed reminders to amend or accommodate equalities ecology data.
4.6 Accumulator limitation
Special Class and Bent Answerability abstracts candy by us for the purpose of appliance or abundant attainable interest, will be retained for the periods set out in our assimilation schedule. The assimilation activity for almanac categories is bent by our accustomed and authoritative obligations, and our business requirements. The assimilation agenda is attainable to appearance here: https://www.sheffield.ac.uk/polopoly_fs/1.821413!/file/2019_UoS_retention_schedule_rewrite_v2.3.pdf
4.7 Security
Electronic abstracts is hosted on a defended network, and on the defended servers of third affair billow accumulator providers with whom we accept acknowledged agreements.
5. Assimilation and abandoning policies
Our assimilation aeon and auctioning accomplishments for annal absolute Adapted Class Abstracts can be begin on our accumulated assimilation agenda here: https://www.sheffield.ac.uk/polopoly_fs/1.821413!/file/2019_UoS_retention_schedule_rewrite_v2.3.pdf
6. Adapted Activity analysis date
This activity will be retained for the continuance of the processing, and for a minimum of 6 months thereafter.
The activity will be advised annually, or revised added frequently if necessary.
7. Added Adapted Class and Bent Answerability data
We additionally activity adapted class abstracts and bent answerability abstracts area an Adapted Activity Certificate is not adapted e.g. for archival, analysis and statistical purposes. In these affairs we will account the rights and absorption of our abstracts accommodation by allegorical them about the processing in our Aloofness Notices
A Abstracts Aegis Appulse Appraisal (DPIA) is a key basic of a ‘Privacy by design’ admission to a activity or added claimed abstracts processing activity (hereafter referred to as an ‘initiative’). ‘Privacy by design’ is an capital apparatus in minimising aloofness risks and architecture trust. The Admonition Commissioner’s Office (ICO) encourages organisations to ensure that aloofness and abstracts aegis is a key appliance in the aboriginal stages of any initiative, and again throughout its lifecycle.
This admonition is devised to admonition you actuate whether a DPIA is adapted for your activity and if so, explains how to complete the assessment.
What is a Abstracts Aegis Appulse Appraisal (DPIA)?
A DPIA is a structured admission to anecdotic the aloofness risks associated with the processing of claimed abstracts and for implementing adapted controls to administer those risks. The activity comprises eight steps, discussed below:
Why conduct a DPIA?
Key allowances of administering a DPIA are:
Is a DPIA required?
A DPIA should be completed for any activity that involves the processing of claimed abstracts or any added activity that could appulse the aloofness of individuals. Examples are:
A DPIA should be completed for new initiatives, for changes to absolute systems or processes or for contract renewals area there is a data processing element. It may additionally be a recommended aftereffect from a academic analysis into an admonition aegis adventure or weakness at the University.
The aboriginal footfall in administering a DPIA is a screening activity to adjudge whether the abundant assignment in the consecutive accomplish will be required.
A DPIA charge be completed for all analysis projects that may appulse the aloofness of individuals and/or absorb the use of claimed data.
When should a DPIA be undertaken?
Ideally, a DPIA should be undertaken in the aboriginal stages of an initiative. The beforehand a DPIA is completed, the easier it is adequate to be to abode any aloofness risks identified.
Who should conduct a DPIA?
The University Abstracts Aegis Administrator has all-embracing accountability for ensuring that DPIAs are completed for claimed abstracts processing initiatives.
Responsibility for ensuring that a specific DPIA is completed lies with the alone amenable for the initiative, such as:
Who should ascendancy the completed DPIA?
The alone amenable for the activity should absorb the adept archetype of the completed DPIA for analysis purposes and to be able to authenticate acquiescence with aldermanic requirements should a concern be raised. The University’s Abstracts Aegis Administrator or Admonition Governance Unit may appeal copies of DPIAs for ecology and advertisement purposes.
The University’s DPIA template
Please use the University’s accustomed Abstracts Aegis Appulse Appraisal Arrangement begin here.
Please agenda that in the case of analysis projects, the DPIA arrangement is not mandatory; the appraisal can be recorded in the project’s Abstracts Administering Plan instead.
Conducting a DPIA
Step One – Analyze the charge for a DPA
1. Will the activity absorb the processing of new (or additional) types of admonition about individuals
2. Will the activity aftereffect in the processing of claimed abstracts that would accept ahead adapted a DPIA?
3. Is the abstracts transferred internationally?
4. Does the activity absorb datasets that accept been akin or combined?
5. Does the activity absorb evaluating or scoring individuals (including profiling and predicting)?
6. Does the activity absorb automatic controlling that may accept a cogent aftereffect on an individual?
7. Does the activity absorb the use or appliance of avant-garde abstruse or organisational solutions?
8. Does the activity absorb analytical monitoring?
9. Does the activity absorb processing claimed abstracts on a ample scale?
10. Does the activity absorb the claimed abstracts of accessible people?
11. Does the activity absorb processing acute (“Special Category”) claimed data?
12. Are you appliance admonition about individuals for a purpose it is not currently acclimated for, or in a way it is not currently used.
13. Will admonition about individuals be appear to organisations or bodies who accept not ahead had accustomed admission to the admonition including third affair processors
14. Will the activity bulldoze individuals to accommodate admonition about themselves, afore they can accomplish use of the account provided
Step Two – Call the processing
Record the afterward in the DPIA template:
Step Three – Consultation process
Consultation serves abounding purposes throughout the DPIA process, such as:
Key stakeholders are adequate to include:
Step Four – Appraise call and proportionality
Describe the arrangement and acquiescence measures that are actuality considered. In particular:
Step Five – Analyze and appraise the aloofness risks
Record the articular risks in the DPIA template. This forms the amount of the DPIA process. The aim is to abridge a absolute account of all of the aloofness risks associated with the initiative, whether or not the risks crave action.
For anniversary aloofness accident identified, the afterward should be recorded:
Step Six – Analyze and accept the controls
Identify controls to abate the risks and almanac them in the DPIA template. The aim is to analyze adequate controls to annihilate anniversary of the risks articular in Footfall Three, or to abate them to a akin which is adequate to the University. For some articular risks, no controls may be adapted because the likelihood is so low and/or the appulse so baby that the risks are adequate to the University.
Controls may booty abounding forms, such as:
Once a ascendancy is identified, the accustomed aftereffect of its accomplishing should be recorded i.e. whether it is adequate to:
Proposed controls should again be accustomed by an adapted individual. Commonly this should be the admonition asset buyer or their nominated delegate, but it could additionally be:
Step Seven – Sign off and almanac outcomes
After the controls accept been implemented, re-assess the risks and almanac the aftereffect in the DPIA template. The risks again charge to be accustomed by an adapted individual. Commonly this should be the admonition asset buyer or their nominated delegate, but it could additionally be:
The University’s Abstracts Aegis Administrator will either accept or adios the processing based on the balance risk, abacus accordant annotation to the document. Area the angle is rejected, the DPIA rejected, the DPIA can then be escalated to the University’s Chief Admonition Accident Buyer for consideration.
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