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Information Security at Staffordshire University

Information Polices and guides

Data Protection

This Privacy Policy explains how we will treat your personal information. By using our website you consent to the collection and use of your information in accordance with this policy. The processing of personal information is regulated in the UK by the Data Protection Act 1998. You have a right to ask for a copy of the information we hold on you and to have information corrected if it is inaccurate.

You can find out more and download the Subject Access Request form here There is a statutory fee of £10 payable upon request.

Data Protection Policy

Introduction

Staffordshire University needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the University’s data protection standards — and to comply with the law under the Data Protection Act 1998.

This data protection policy ensures Staffordshire University

  • Complies with data protection law and follows good practice
  • Protects the rights of staff, customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Why this policy exists

This data protection policy ensures Staffordshire University

  • Complies with data protection law and follows good practice
  • Protects the rights of staff, customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations — including Staffordshire University must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to all staff and all contractors, suppliers and other people working on behalf of Staffordshire University.

It applies to all data that the University holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals

Data protection risks

This policy helps to protect Staffordshire University from data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the University uses data relating to them.
  • Reputational damage. For instance, the University could suffer if hackers successfully gained access to sensitive data or sensitive data is lost.

Responsibilities

Everyone who works for or with Staffordshire University has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
  • Staffordshire University will provide training to all employees to help them understand their responsibilities when handling data.
  • Everyone processing personal information understands that they are contractually responsible for following good data protection practice.

  • Everyone processing personal information is appropriately supervised.

  • Anybody wanting to make enquiries about handling personal information knows what to do.

  • Everyone deals promptly and courteously with any enquiries about handling personal information.

  • Staffordshire University will regularly review and audit the ways it holds, manages and uses personal information.

  • All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them

  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
    • In particular, strong passwords must be used and they should never be shared.
    • Personal data should not be disclosed to unauthorised people, either within the University or externally.
    • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
    • Employees should request help from their line manager, departmental coordinator or member of staff with cross University responsibility (usually the Data Controller) if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Personal or confidential data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
  • Personal data should never be saved directly to laptops, USB drives (unless encrypted) or other mobile devices like tablets or smart phones.

Data use

Personal data is of no value to Staffordshire University unless it can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally.
  • Personal data must be encrypted before being transferred electronically outside of the University. The member of staff with cross University responsibility (usually the Data Controller) can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires Staffordshire University to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Staffordshire University should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

Subject access requests

All individuals who are the subject of personal data held by Staffordshire University 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 how the University is meeting its data protection obligations.

If an individual contacts the University requesting this information, this is called a subject access request.

Information about subject access requests is available from the University website http://www.staffs.ac.uk/legal/request_information/

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Staffordshire University will disclose requested data where the request is legitimate.

In addition Staffordshire University will ensure that:

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.

In case of any queries or questions in relation to this policy please contact the Data Controller: foi@staffs.ac.uk .

Further information can be found on the University Legal Website:

 

How to make a Subject Acesses Request

You have the right to get a copy of the information that is held about you. This is known as a subject access request. This right of subject access means that you can make a request under the Data Protection Act to the university. How do I make a request?

Under the Data Protection Act 1998 an individual has the right, subject to certain exemptions, to access the personal information that an organisation holds about them. Accessing personal data in this way is known as making a Subject Access Request. 

If you wish to make a subject access request to the University, your request must be:

made in writing accompanied by a fee of £10

  • Before we can act on your request, we must:
  • be sure of your identity
  • be supplied with information from you in order to locate the information you seek.

You are entitled:

  • to be informed whether your personal data are being processed by Staffordshire University
  • to have the information constituting the personal data communicated to you in a permanent form (usually, this means paper copies) 

You may apply to access your data in writing in any way you choose. A Subject Access Request Form is made available for your convenience. The form sets out where you should send your request as well as the various ways (check with Helen Holt re ways of payment) in which you may pay the fee and provide us with proof of your identity.

On receipt of your completed request, payment of the fee, verification of your identity, and sufficient information to enable us to locate the information, the University is obliged to respond within 40 calendar days. The information will be supplied subject to any applicable exemptions. The data will be provided as of the date of receipt of your request.

Please return your form to the Information Protection & Security Manager at the address shown.

The organisation has to reply within 40 days, starting from the day they receive both the fee and the information they need to identify you and the information you need. A credit reference agency must reply within seven days to a request for a credit file.

If an organisation reasonably needs more information to help them find your information or identify you, they have to ask you for the information they need. They can then wait until they have all the necessary information as well as the fee before dealing with your request.

The organisation should give you the information in writing but they need not do this if it is not possible, if it takes ‘disproportionate effort’ or if you agree to some other form, such as seeing it on screen. The Act does not define what disproportionate effort means but we think the following should be taken into account:

  • the cost of giving you the information;
  • the length of time it will take;
  • how difficult it will be;
  • the size of the organisation; and
  • the effect on you of not having the information in permanent form.

Can the organisation withhold any information?

Yes. There are some circumstances where the information you have asked for contains information that relates to another person. Unless the other person gives their permission, or it is reasonable in all the circumstances to provide the information without permission, the organisation is entitled to withhold this information.