Data Protection Privacy Notice for Report and Support Tool
About this Privacy Notice
Note: For the purposes of this Privacy Notice:
“you” or “your” means an individual who is submitting the report
“UCA” (“we”, “us”, “our”) or “University“ means the University for the Creative Arts
“personal data” or “data” means your personal identification information that you have given us or we have collected
“special category data” means specific sensitive data which we give more protection
Please read this Privacy Notice carefully. It describes why and how we collect and use personal data that you have provided in the context of the Report and Support tool and it provides information about your rights.
The University for the Creative Arts takes its obligations with regard to data protection seriously. As such, we are providing this notice in accordance with applicable data protection law, including the General Data Protection Regulation 2016/679 (“GDPR”).
The personal data that is either provided to us by yourself or by third parties will be processed in accordance with the Universities Data Protection Policy and our Student Privacy Notice as well as Staff Privacy Notice, which provide further information on how we protect your privacy. UCA is the data controller with regard to the processing of your personal data. The data controller is the entity that determines how and why personal data is processed.
How is your personal data collected and what personal data are we collecting?
This tool is introduced to encourage members of the UCA community to change their approach to tackling hate, sexual violence, and harassment by providing an easy and quick way to report incidents without fear.
While using this tool you might provide personal data which could include your status, gender, contact details as well as information about the incident you are reporting. This may include special categories of personal data, such as data concerning health, sex life, ethnic origin and data relating to alleged criminal offences. The tool might also collect personal data about other individuals who are witnesses or perpetrators.
There are two different reporting options:
If an anonymous report is made, the Report and Support tool is set up so that we do not know who has made the report. UCA discourages the provision in anonymous reports of names or other information that could be used to identify a third party. However, if any such information is shared, UCA will use that information in order to review and process the report. Please be aware that UCA cannot take action when an anonymous report has been made. We will use the information gathered through anonymous reports only to establish trends to better inform our decision-making
If a named rather than an anonymous report is made, we may collect, use, store and transfer different kinds of personal data about the person making the report. This may include:
- Your name, contact details (email address and Telephone number) and other information about you such as your department (where applicable) or student number (where applicable);
- ‘Special category’ personal data about you (this may include details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health etc.); and
- Detail regarding your experience of bullying, harassment, and sexual misconduct.
We will also process the names and other details about third parties who are involved in the issues reported.
How will your information be used? Why and for what purpose do we process your personal data and what is our lawful basis for doing so?
UCA uses an external company named Culture Shift to provide and store the system that holds the information submitted on the university’s behalf. UCA remains responsible for the information and will ensure it is kept securely.
We will use the information you submit to:
- Help us to identify the best person for you to speak to in relation to your report and support you (where you have provided your contact details).
- Provide the relevant person with your contact details (if you have provided them) and some useful background information that will enable them to understand the nature of your concern or the incident you are reporting.
- Where you have provided your contact details, review your report and take further action if required. For example, an investigation could lead to us carrying out disciplinary action. We will write to you to keep you informed of what we are doing.
- Monitor patterns or trends in data that will be used to inform our proactive and preventative work. When reporting anonymously, we will not ask you for any personal identifiable details, which means that we won’t be able to offer direct advice. We will keep an anonymised record of your report to identify whether there have been/are other similar reports and whether there is a pattern of behaviour or trends that should be addressed through generalised interventions (e.g. training programmes, awareness campaigns, environmental investigations, etc).
When you submit information using this service, you consent to UCA processing your personal data, for the purposes set out in this notice. In addition, we believe that the processing is necessary for the performance of our contractual obligations to students or staff. For special category data we rely either on explicit consent or on a data processing condition in the substantial public interest (e.g. safeguarding, counselling, or the prevention of criminal behaviour).
It may also be necessary to process personal data in order to protect the vital interests of you or another individual (e.g. if a report revealed a situation requiring the involvement of the emergency services or other external authorities) or because it is necessary to comply with legal obligations (e.g. employment or health and safety legislations). We also believe that is it necessary for our legitimate interest to process information relating to incidents affecting the UCA community in order to address these and fulfil our duty of care and to monitor equality and diversity.
Who will your personal data be shared with? To whom will your personal data be disclosed?
In the context of the Report and Support tool we will share your data with third party service providers that help us provide the tool, such as Culture Shift. This enables us to make the Report and Support tool available to you. Please see Culture Shift’s Knowledge Base for further information on the security measures adopted by Culture Shift, which are designed to help keep personal data secure.
Your identity and your other personal data will be disclosed within UCA on a need to know basis only and will not be disclosed to any third parties without your consent unless there are legitimate reasons requiring us to do so. There may be instances where we will have to share information with our Safeguarding Officer or possibly the Police or Social Care Services, or otherwise where we may be required by law. We will not disclose any personal or identifiable information to any other party unless we believe there is a genuine threat to a persons health and safety, in accordance with our statutory duty to protect the welfare of employees or our safeguarding of/duty of care for students.
Security of your personal data
As stated above, UCA takes the protection of your personal data seriously and we have implemented technical, physical and organisational measures to ensure the personal data of UCA students and staff is kept accurate, up to date and protected against unauthorised or accidental destruction, alteration or disclosure, accidental loss, unauthorised access, misuse, unlawful processing and/or damage.
How long will your data be kept for?
UCA will retain your personal data only for such period as is necessary to perform the purpose(s) for which it was collected. In many cases this means that personal data will be retained for the duration of your time as a student/staff with us, and then for a reasonable time thereafter in order to manage our relationship with you, defend any claims, and/or for any other record keeping purposes. This period is typically a period of not less than six years after your last year of enrolment/employment.
You can withdraw your consent at any time by contacting us using any of the contact details provided below.
You have the following rights in respect of your personal data:
1. You can request access to, or copies of, the personal data that we hold about you. If you would like to exercise this right, please contact us using any of the contact details given below.
2. If you believe that any information we have about you is incorrect or incomplete, please contact us using any of the contact details given below as soon as possible. We will take steps to seek to correct or update any information if we are satisfied that the information we hold is inaccurate;
3. You can request that your personal data be deleted, where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such information;
4. If we are processing your personal data to meet our legitimate interests or in the performance of a task carried out in the public interest, you can object to the processing of your personal information by us. If we are unable to demonstrate our legitimate grounds for that processing, we will no longer process your personal information for those purposes;
5. You can withdraw any consent given to processing (this will not affect the lawfulness of processing based on consent before its withdrawal); or,
6. You have an additional right of data portability where the personal data we use is processed automatically based on your consent or for the purposes of performing our contract with you. You can ask us to provide your personal data in a structured, commonly used and machine-readable format to you or to a third party, as instructed by you.
7. You can request that we restrict the processing of your personal data in certain circumstances when required by law; and,
8. In certain circumstances, you have the right to object to our processing of your personal data where the processing is for the purposes of automated decision-making, including profiling.
If you would like to exercise any of your rights as described above (or if you have any questions about this Privacy Notice or concerns about our dealings with your personal data), please contact the Data Protection Officer at:
Telephone Number: 01252 722441
Email address: firstname.lastname@example.org
Address: University for the
We will try to resolve any concerns you may have. However, if you consider that we are in breach of our obligations under data protection laws, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or place of work. In the U.K., you may lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/global/contact-us/).
Updates to this Privacy Notice
UCA may change this Privacy Notice from time to time in order to reflect changes in the law and/or its privacy practices. When this happens and where UCA is required to do so by law, it will provide you with a new and/or updated Privacy Notice detailing how the use of your personal data is changing and, if necessary, obtaining your consent for the further processing, as may be applicable.
Policy last updated: 24 September 2021