Somerville College – security and monitoring relating to staff, students and visitors privacy notice
Privacy notice – data processing activities undertaken by Somerville College for security and monitoring relating to staff, students and visitors to Somerville College premises
A summary of what this notice explains
Somerville College is committed to protecting the privacy and security of personal data.
This notice applies anyone who interacts with Somerville College security, including the College Lodge and CCTV systems operated by Somerville College – including staff, students and visitors. There are separate privacy notices covering the other aspects of processing of staff, student and others’ data, including users of the College website, which are available on the public website on the Policies page.
This notice explains what personal data Somerville College holds about you, how we use it internally, how we share it, how long we keep it and what your legal rights are in relation to it.
For the parts of your personal data that you supply to us to us, this notice also explains the basis on which you are required or requested to provide the information. For the parts of your personal data that we generate about you, or that we receive from others, it explains the source of the data.
What is your personal data and how does the law regulate our use of it?
“Personal data” is information relating to you as a living, identifiable individual. We refer to this as “your data”. “Processing” your data includes various operations that may be carried out on your data, including collecting, recording, organising, using, disclosing, storing and deleting it. Data protection law requires us:
To process your data in a lawful, fair and transparent way;
- To only collect your data for explicit and legitimate purposes;
- To only collect data that is relevant, and limited to the purpose(s) we have told you about;
- To ensure that your data is accurate and up to date;
- To ensure that your data is only kept as long as necessary for the purpose(s) we have told you about;
- To ensure that appropriate security measures are used to protect your data.
Somerville College’s Contact Details
If you need to contact us about your data, please contact: firstname.lastname@example.org
Data that you provide to us and the possible consequences of you not providing it
In most cases the data you provide will be a necessary requirement of entering or living on Somerville College premises. If you do not provide such data you may not be able to enter Somerville College premises, and depending on circumstances this may become a disciplinary matter that could lead to the termination of your contract with us whether you are an employee, or a student.
Other sources of your data
Apart from the data that you provide to us, we may also generate data about you, for example if you use a fob or swipe card to access premises, the Somerville College access control system will generate a log of your attendance.
The lawful basis on which we process your data
The law requires that we provide you with information about the lawful basis on which we process your personal data, and for what purposes. Most commonly, we will process your data on the following lawful grounds:
- 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 necessary to comply with a legal obligation;
We may also use your data, typically in an emergency, where this is necessary to protect your vital interests, or someone else’s vital interests.
How we apply further protection in the case of “Special Categories” of personal data
“Special categories” of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.
The Special Categories of personal data consist of data revealing:
- racial or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- trade union membership.
They also consist of the processing of:
- genetic data;
- biometric data for the purpose of uniquely identifying someone;
- data concerning health;
- data concerning someone’s sex life or sexual orientation.
We may process special categories of personal data in the following circumstances:
- With your explicit written consent; or
- Where it is necessary in the substantial public interest, in particular:
- is necessary for the purposes of the prevention or detection of an unlawful act, must be carried out without the consent of the data subject so as not to prejudice those purposes; or
- for equal opportunities monitoring;
- Where the processing is necessary for archiving purposes in the public interest, or for scientific or historical research purposes, or statistical purposes, subject to further safeguards for your fundamental rights and interests specified in law.
We have in place an appropriate policy document and/or other safeguards which we are required by law to maintain when processing such data.
Less commonly, we may process this type of data 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 data public.
Criminal convictions and allegations of criminal activity
Further legal controls apply to data relating to criminal convictions and allegations of criminal activity. We may process such data on the same grounds as those identified for “special categories” referred to above.
Details of our processing activities, including our lawful basis for processing
We have prepared a detailed table setting out the processing activities that we undertake, the source of the data, the reasons why we process it, how long we keep it and the lawful basis we rely on.
The table includes detailed information about how and why we process various categories of data, and the related lawful basis. It includes:
- CCTV monitoring that Somerville College undertakes to help provide safety and security on College premises, and to assist with the prevention of crime and other unlawful activity. Somerville College may take disciplinary action if a safety or security incident involves a breach of staff or student disciplinary policies, and/or report safety/security incidents to the police if the incident involves an apparent criminal offence. Monitoring for such purposes may only be carried out in accordance with Somerville College’s CCTV policy which includes safeguards to ensure that individual privacy is respected appropriately. The lawful basis for such processing is that the Somerville College has a legitimate interest in ensuring that staff comply with their legal obligations as employees.
- Movement records of staff, students and visitors to Somerville College premises, for example of timing of access to buildings or offices, whether through electronic access systems or manual records. The lawful basis for such processing is that the College, its members and visitors have a legitimate interest in implementing such measures to help maintain College safety and security.
- Occasional monitoring that may occur of staff where Somerville has reasons to believe the individual concerned may be guilty of misconduct. Monitoring for such purposes may only be carried out in accordance with Somerville’s CCTV policy which includes safeguards to ensure that individual privacy is respected appropriately. The lawful basis for such processing is that the College has a legitimate interest in ensuring that staff comply with their legal obligations as employees.
How we share your data
We will not sell your data to third parties. We will only share it with third parties if we are allowed or required to do so by law. This includes for example where we decide to report alleged criminal misconduct to the police. All our third party service providers are required to take appropriate security measures to protect your personal information in line with our policies, and are only permitted to process your personal data for specific purposes in accordance with our instructions. We do not allow our third party providers to use your personal data for their own purposes.
Sharing your data outside the European Union
The law provides various further safeguards where data is transferred outside of the EU.
When you are resident outside the EU in a country where there is no “adequacy decision” by the European Commission, and an alternative safeguard is not available, we may still transfer data to you which is necessary for performance of your contract with us (if you are a staff member or student).
Otherwise, we may transfer your data outside the European Union, but only for lawful purposes and provided either:
- There is a decision of the European Commission that the level of protection of personal data in the recipient country is adequate; or
- Appropriate safeguards are in place to ensure that your data is treated in accordance with UK data protection law, for example through the use of standard contractual clauses; or
- There is an applicable derogation in law which permits the transfer in the absence of an adequacy decision or an appropriate safeguard.
We do not envisage that any decisions will be taken about you based solely on automated means, however we will notify you in writing if this position changes.
How long we keep your data
The detailed table of processing activities explains how long we will keep your data.
Please note that we may keep anonymised statistical data indefinitely, but you cannot be identified from such data. If there are legal proceedings, a regulatory, disciplinary or criminal investigation, suspected criminal activity, or relevant requests under data protection or freedom of information legislation, it may be necessary for us to suspend the deletion of data until the proceedings, investigation or request have been fully disposed of.
Your legal rights over your data
Subject to certain conditions set out in UK data protection law, you have:
- The right to request access to a copy of your data, as well as to be informed of various information about how your data is being used;
- The right to have any inaccuracies in your data corrected, which may include the right to have any incomplete data completed;
- The right to have your personal data erased in certain circumstances;
- The right to have the processing of your data suspended, for example if you want us to establish the accuracy of the data we are processing.
- The right to receive a copy of data you have provided to us, and have that transmitted to another data controller (for example, another University or College).
- The right to object to any direct marketing (for example, email marketing or phone calls) by us, and to require us to stop such marketing.
- The right to object to the processing of your information if we are relying on a “legitimate interest” for the processing or where the processing is necessary for the performance of a task carried out in the public interest. The lawful basis for any particular processing activity we carry out is set out in our detailed table of processing activities.
- The right to object to any automated decision-making about you which produces legal effects or otherwise significantly affects you.
- Where the lawful basis for processing your data is consent, you have the right to withdraw your consent at any time. When you tell us you wish to exercise your right, we will stop further processing of such data. This will not affect the validity of any lawful processing of your data up until the time when you withdrew your consent. You may withdraw your consent by contacting the PPH’s Data Protection Officer
Further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/). You may also wish to contact the Somerville College’s Data Protection Officer on email@example.com if you are considering how or whether to exercise your rights. You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office if you believe that your data has been processed unlawfully.
Future changes to this privacy notice, and previous versions
We may need to update this notice from time to time, for example if the law or regulatory requirements change, if technology changes, if the Somerville College or University makes changes to its procedures, or to make Somerville College’s operations and procedures more efficient. If the change is material, we will give you not less than two months’ notice of the change so that you can decide whether to exercise your rights, if appropriate, before the change comes into effect. We will notify you of the change through updates to the College’s public website.