This policy has been updated in 2018 in light of the General Data Protection Regulation (GDPR). This policy was last updated in March 2018. It will be reviewed annually, or before if we introduce any changes to our data practices. You should check this page from time to time to ensure that you are happy with any changes.
1. The data controller
The data controller is: Universities UK
Universities UK group includes Council of Deans of Health, Universities Scotland and Universities Wales.
The Director of Operations has responsibility for data protection, and can be contacted by:
Post Woburn House, 20 Tavistock Square, London, WC1H 9HQ
Phone 020 7419 4111 (office hours only)
2. The personal data we are collecting
This privacy notice applies to information we collect about:
- Visitors to our website
- Our members
- Individuals who sign up for mailing lists and bulletins, request information from us or use our services
Personal data we routinely collect includes:
- Postal address
- Email address
- Telephone number
For our employees we will also collect
- Demographic data
- Medical data
- Diversity monitoring data
- Bank account details
- National insurance number
3. How we collect personal data
We collect personal data through:
- Web forms online
- Paper forms
4. How we source data
We will find contact data from several sources, for example on institution websites for individuals, other online resources, Companies House and we will also be given contact details from an individual’s colleagues to add to our mailing lists.
We generally do not buy in data lists from third parties. If we felt this was necessary, we would conduct a data protection impact assessment.
5. The purpose of collecting data
We use the data to keep in touch with individuals interested in the higher education sector. This could include:
- People working in higher education institutions, or organisations connected to higher education
- Political, business, media and policy contacts
- Other interested individuals
For the above groups, we will email news updates relating to their work and the wider higher education sector. For our named members, committee members and their PA’s, we will use data for administrative purposes to manage membership.
6. Your rights as an individual & 7. making a complaint
You can unsubscribe from email communications at any time, using the unsubscribe button, or replying to emails with the instruction to be removed from a mailing list. As a data subject, individuals have a number of rights in relation to their personal data.
Subject access requests
If an individual makes a subject access request, UUK will tell him/her:
- whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
- to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
- for how long his/her personal data is stored (or how that period is decided);
- his/her rights to rectification or erasure of data, or to restrict or object to processing;
- his/her right to complain to the Information Commissioner if he/she thinks UUK has failed to comply with his/her data protection rights; and,
- whether or not UUK carries out automated decision-making and the logic involved in any such decision-making.
- UUK will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise. This will be provided within one month of the request being made to meet GDPR requirements.
To make a subject access request, the individual should send the request to DataProtection@universitiesuk.ac.uk In some cases, UUK may need to ask for proof of identification before the request can be processed. UUK will inform the individual if it needs to verify his/her identity and the documents it requires.
If a subject access request is manifestly unfounded or excessive, UUK is not obliged to comply with it. Alternatively, UUK can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which UUK has already responded. If an individual submits a request that is unfounded or excessive, UUK will notify him/her that this is the case and whether or not it will respond to it.
Individuals have a number of other rights in relation to their personal data.
They can require UUK to:
- rectify inaccurate data;
- stop processing or erase data that is no longer necessary for the purposes of processing;
- stop processing or erase data if the individual’s interests override UUK’s legitimate grounds for processing data (where UUK relies on its legitimate interests as a reason for processing data);
- stop processing or erase data if processing is unlawful; and
- stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override UUK’s legitimate grounds for processing data.
To ask UUK to take any of these steps, the individual should send the request to DataProtection@universitiesuk.ac.uk
8. The legal basis we are relying on
Universities UK will use legitimate interest for contacts and communications for the following groups:
- HE sector and members
- Policy, political, business and media contacts
- Income generation activities – Woburn House Conference Centre and UUK conferences and events.
For these groups the data held will be:
- Full name
- Postal address (business address)
- Contact details including address, telephone number and email (business contact details)
Universities UK believes that:
There is a genuine business reason (the legitimate interest) for processing this data, the purpose of UUK (incorporating Woburn House Conference Centre) is:
- To formulate policies on any matters affecting or relevant to the university sector of higher education in the UK
- To provide information, advice and assistance to universities within the UK, or any of their representatives, on any aspect of educational affairs, including administrative and financial matters relating to or connected with education
- To represent the university sector of higher education in the UK and to conduct dealings and to liaise with the Government, any local, national or other institutions, authorities, agencies, bodies or persons, wheresoever in the world situated
- To promote and provide facilities for discussion and consultation between representatives of university institutions in the UK, on any matters affecting or relevant to the university sector of higher education in the UK.
And has considered the necessity test:
Processing individual’s data for the purposes of communicating with members, HE sector contacts, political, media, business and policy contacts is necessary to effectively service the needs and represent our members’ interests fully.
UUK considers the impact on the individual to be low (the balancing test):
- Only targeting individuals working or having a professional interest in the higher education sector, using business contact details.
- We believe there is value in individuals hearing about developments and opportunities in the sector
- Providing opportunities for networking with peers.
- The individuals have already expressed an interest in our work through signing up for regular newsletter, using the facilities or attending an event.
- Users can opt out of communications
- We are not using any special categories of data
- We will not transfer the data to third parties.
There are safeguards in place:
Opportunity for all contacts to unsubscribe from mailings
- Email (DataProtection@universitiesuk.ac.uk) for individuals to practice their rights (see section 6).
- The amount of data held on individuals is restricted to only what is necessary, and kept no longer than necessary
- Data will not be shared with third parties, without making individuals aware and having a clear data sharing agreement
- Access to data is restricted to only staff who need it for the performance of their roles
- IT systems are secure, with regular security testing programme in place.
- Data protection training is done by all staff as part of their probation.
9. Where our data is stored
Data is stored on premise in offices in London, Edinburgh and Cardiff. Where cloud hosted systems are in use, the data is stored in the EEA.
10. Profiling & 11. our data retention policy
When you visit our website, we may store some information on your computer. This information will be in the form of a ‘cookie’ or similar file and can help us in many ways. For further information please see our cookies policy below.
11. Our data retention policy
UUK has a policy on data and document retention. Retention periods are based on ICSA Guide to Document Retention (3rd Edition). If you have questions on our retention policy, email: DataProtection@universitiesuk.ac.uk
12. Leaving our websites
Links to external websites are not our responsibility and that once a user clicks on a link to an external site it will be subject to that organisation’s privacy policies, not ours.
Our Cookies policy
You do not have to provide any personal information in order to browse this website. We may collect the following information during the newsletter sign-up process:
- Email address
- First and last name
- Your organisation