Privacy Notice - Reasonable Adjustments Passport
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 Reasonable Adjustment Passport. This privacy notice will explain how The University of Glasgow will process your personal data.
Why we need it
Completion of the Reasonable Adjustments Passport is optional however where it is completed, we are collecting your basic personal data such as your name along with limited special category data such as relevant health data and details of adjustments (or advised adjustments) in order to allow the ‘passport’ to serve as an optional record of adjustments, and to act as an aid to support you in discussing adjustments with others as you wish (e.g. a new line manager). The passport only collects the data that we need in order to fulfil these aims.
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), particularly in circumstances where they have a new line manager who may be unfamiliar with their working arrangements.
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
- Your line manager should securely store a copy of the form for future reference and may use the information saved to inform future review discussions (to check adjustments remain effective) or, in cases where your manager changes, share information with any new manager to ensure they are aware of agreed adjustments. Line managers can store a copy of the form in the secure Ivanti system (which also contains functionality to alert your manager and yourself of approaching review dates).
- Any personal data you choose to save on the passport may then be uploaded (by yourself) to your PeopleXD (formerly CoreHR) record, only if you wish to do so. This record would be stored on your existing record in the HR Information System. There is no obligation to store the passport in this way and individuals may store or retain their form wherever the deem most appropriate to them.
- If saved within PeopleXD, the form can be accessed in the system by yourself as and when you require to do so. You may choose to share details with relevant contacts (i.e. by sharing a copy outwith the system) as you deem appropriate in order to support the discussion of your adjustments (e.g. with members of your immediate team if appropriate). You line manager may also access the passport document.
- The University will not share the passport or its contents with any other party with the exception of any new/incoming line manager or with stakeholders that are vital to the procurement/installation of any adjustments (e.g. notifying IT Services of recommended software in order to secure further support).
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, data will be securely deleted.
What are your rights?*
You can access the information (i.e. the passport) in your staff record at any time via the staff self-service portal. You may also ask your line manager for a copy of their saved version of the form. If at any point you believe that the information on the passport is incorrect, you can speak to your line manager and update/edit the passport accordingly. You may also delete/remove the document from your record at any time and/or request that your manager deletes or destroys their copy.
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/