Privacy Notice - Support for Disabled & Neurodivergent Colleagues
Your Personal Data
The University of Glasgow will be what’s known as the ‘Data Controller’ of your personal data processed in relation to the Disability Support (Considering Adjustments) Process. This privacy notice will explain how The University of Glasgow will process your personal data.
Why we need it
The University has a legal duty under the Equality Act to consider reasonable adjustments. Without any process controls, there are increased risks of disabled colleagues not receiving the support they require, thus implementing light automation we can provide line managers and colleagues with helpful prompts to guide the process of considering reasonable adjustments as and when required.
Legal basis for processing your data
We must have a legal basis for processing all personal data. In this instance, the legal basis is ‘Legitimate interests’ whereby the capture and use of this data will help improve the working environment for disabled colleagues with regards to implementing the best practice management (and review) of reasonable adjustments whilst empowering colleagues to discuss their adjustments with others (as they so wish).
For special category data (i.e. health) our legal basis for processing is:
Article 9(2)(b): processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or the data subject in the field of employment
Article 9 (2)(g): processing is necessary for reasons of substantial public interest on the basis of Union or Member State law e.g. the Equality Act
What we do with it and who we share it with
- The process is offered as an additional and optional benefit to colleagues who tick the ‘request support discussion’ box in the PeopleXD system when updating their disability information.
- When this box is ticked, a ‘yes’ value is sent to the Ivanti system along with the employee name to start a workflow which sends automated and time-based prompts to line managers and colleagues as required to encourage and support constructive dialogue around reasonable adjustments. No medical or disability information is passed across.
- An HR colleague is assigned to each record for oversight purposes (i.e. to offer advice if no progress is apparent).
- The Ivanti system records the date that the request was made and issues a prompt to the relevant line manager (signposting them to online resources) and advising that a support conversation must take place to consider adjustments. Line managers must update the record to confirm dialogue has taken place otherwise an automated reminder will be sent after 2 weeks.
- Other fields are available for managers to track if adjustments have been agreed or are not required.
- If a Reasonable Adjustment Passport has been used, this may also be saved to the record for future reference.
- A review date can be added manually (agreed between line manager and colleague) to prompt future reminders to review the effectiveness of adjustments.
- The above information is all stored securely in the existing Ivanti system accessed only by line managers, the colleague themselves and Human Resources for oversight purposes.
- Human Resources may also run periodic internal reports on overall volume/number of records for the purposes of reviewing policy/process effectiveness.
How long do we keep it for
Your data will be retained by the University for as long as you require reasonable adjustments. After this time, the record will be automatically closed.
What are your rights?*
You can request to access the information in your staff record at any time (via your line manager in the first instance). If at any point you believe that the information on the record is incorrect, you can speak to your line manager and update/edit the record accordingly. You may also request that the record be deleted at any time (via your manager in the first instance).
You may also have the right to object to the processing of data and the right to data portability.
*Please note that the ability to exercise these rights will vary and depend on the legal basis on which the processing is being carried out.
If you wish to raise a complaint on how we have handled your personal data, you can contact the University Data Protection Officer who will investigate the matter.
Our Data Protection Officer can be contacted at firstname.lastname@example.org
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO) https://ico.org.uk/