LSI

Staff Privacy Policy

Policy Statement

Protecting staff privacy is essential to fostering trust, safeguarding individuals, minimising risks, and upholding security.

The School is committed to processing personal data, ensuring fairness, transparency, and security while meeting legal and contractual responsibilities, in compliance with Data Protection laws and guided by Information Commissioner’s Office (ICO) standards, operating within the School’s Information Governance framework.

This policy sets out the School’s approach to safeguarding staff privacy and ensuring confidentiality through responsible data management.

Principles

  • Confidentiality: Guaranteeing that personal information is kept confidential and secure at all times.
  • Transparency: Being transparent about the collection, use, and sharing of staff data.
  • Consent: Using consent only where it is the appropriate lawful basis under the UK GDPR and where consent can be freely given, specific, informed, and capable of withdrawal. Where consent is not appropriate, the School relies on other lawful bases such as contractual necessity, legal obligation, or legitimate interests and explains these transparently.
  • Legality: Ensuring all data processing activities comply with legal requirements.
  • Necessity: Collecting only data that is necessary for legitimate educational and operational purposes.
  • Access: Providing staff with access to their personal data and the right to update or correct it.
  • Protection: Implementing stringent measures to protect against data breaches and misuse.
  • Minimal Retention: Keeping personal data for no longer than is needed for its intended purposes.
  • Responsibility: Making clear the roles and responsibilities in data protection and privacy matters.
  • Training: Offering ongoing training to staff managing personal data to ensure compliance with this policy.
  • Rights: Upholding the rights of individuals in line with the General Data Protection Regulation (GDPR) and other applicable laws.
  • Review: Continually reviewing and updating the policy to reflect changes in data protection laws.

Regulatory Context

This Policy has been developed in line with the applicable laws, regulations, regulatory advice, and sector best practices, including the following:

Authority Name Url
UK Government Data Protection Act 2018
Legislation aimed at controlling the processing of personal data, laying down principles with respect to the processing of personal data, and the rights of data subjects
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Information Commissioner's Office (ICO) Guide for higher education institutions
Provides guidance for higher education providers on their obligations under data protection law.
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What Information Does the School Collect

During employment, the School collects, stores, and processes personal data about you, including special category personal data where necessary, such as information relating to health, disability, equality monitoring, or safeguarding, and, where lawful and appropriate, information relating to criminal convictions. Special category and criminal convictions data are processed only where a lawful condition applies and with appropriate safeguards in accordance with the School’s Data Protection Policy.

The School collects personal data to comply with legal obligations, ensure staff and student safety, and provide necessary support and services. Special categories of data are collected for equal opportunities monitoring and fulfilling statutory requirements. Criminal conviction information is used to ensure a safe environment by restricting access to services where necessary.

Why Do We Collect Your Data

We collect your personal information to support our operations and enhance services and facilities. This data may be collected in various ways:

  • From information provided when you engage with us before and upon joining.
  • Through communication by phone, email, or our website.
  • During interactions with us throughout your employment.
  • From third-party sources.

Collecting personal information enables us to perform our duties effectively, respond to enquiries or concerns, and continually improve our services and facilities. Third-party data helps ensure we have accurate and relevant information for these purposes.

The School processes staff personal data under one or more lawful bases under the UK GDPR depending on the purpose of processing. These typically include:

  • contractual necessity for managing employment and associated benefits;
  • legal obligation for tax, payroll, safeguarding, right-to-work, and regulatory reporting;
  • legitimate interests for operating, improving, and securing School services and systems;
  • vital interests in emergency situations; and
  • consent only where appropriate, such as optional initiatives or specific uses of images or communications.

Special category and criminal convictions data are processed only where an additional lawful condition applies and appropriate safeguards are in place.

These describe the lawful bases for processing staff data, 

If you wish to exercise your data protection rights, including making a Data Subject Access Request, requesting rectification, or raising concerns about how your personal data is handled, you may contact the Internal Data Protection Lead at dataprotection@lsi-ac.uk.

Requests are logged and managed through the School’s governed process, including identity verification, retrieval from systems-of-record (as defined in the Information Governance Policy), and response within statutory timescales.

Who has Access to the Data

The School may share your personal information with external organisations to fulfil legal duties, manage operations, or upon your request. These organisations may include:

  • Government departments (e.g., Home Office, Department of Education).
  • Higher Education Statistics Agency (HESA) - please see Collection notices and Staff Collection Notice.
  • Public bodies and agencies (e.g., HMRC, Health and Safety Executive).
  • Office for Students (OFS) and Office of the Independent Adjudicator (OIA).
  • Programme-accrediting organisations (e.g., BCS).
  • Local Authorities for Council Tax and electoral registration.
  • Police, law enforcement, and safeguarding agencies.
  • Insurers, auditors, and providers of external training placements.
  • Current or prospective employers for references.
  • Third-party support services and IT providers.
  • Crime prevention or detection agencies.
  • Banks and employers upon your request.

We share personal information where we have a lawful basis to do so, including where necessary for the performance of your employment contract, to comply with legal obligations, to protect vital interests in an emergency, or where we have legitimate interests that are not overridden by your rights and interests. Where consent is the appropriate lawful basis for a specific disclosure, we will seek consent.. Anonymised or aggregated data may be shared for purposes like equality benchmarking.

Sharing personal information with external organisations ensures the School meets legal obligations, supports its operations, and provides requested services. Sharing data with agencies like police or health authorities may be required for safety, crime prevention, or compliance. Anonymised data helps improve equality and diversity initiatives through benchmarking.

How Do We Use Your Information

The School securely collects, stores, and processes your personal information in both paper and electronic formats, including databases accessible to academic and professional departments. Access is restricted to authorised staff, contractors, or agents with a legitimate business need within their contractual duties. Personal information is used for:

  • Managing finances and related funding.
  • Administering facility use and event participation (e.g., building access, libraries, health services).
  • Handling complaints, investigations, and disciplinary matters, including academic misconduct.
  • Fulfilling statutory reporting and monitoring equality legislation compliance.
  • Ensuring health, safety, and wellbeing, including safeguarding and crime prevention.
  • Monitoring compliance with School regulations.
  • Conducting management reporting, research, and statistical analysis.
  • Checking right-to-work status and visa compliance.
  • Communicating work-related information and updates.
  • Inviting participation in research to improve services.

Some data may be ‘special categories’ (e.g., race, ethnicity, medical information) for specific purposes like equality monitoring or providing necessary support. Access to such data is strictly controlled under the School’s Data Protection Policy. Accountability for processing sits with the relevant Data Owners for their domains, with privacy operations coordinated by the Internal Data Protection Lead and information security and systems controls operated by the Director of Technology in their role as Senior Information Risk Owner, in line with the Information Governance Policy.

Secure handling of personal data ensures the School meets its academic, legal, and operational responsibilities while safeguarding individual privacy. Controlling access to sensitive information through a robust data protection policy protects against misuse and supports compliance with legal requirements.

How Your Data is Held

Your personal data is stored only within the School’s designated systems-of-record and approved repositories used for human resources, payroll, safeguarding, and operational administration. Access is controlled through role-based access controls so that staff and approved contractors access only the information necessary for their role. Records must not be stored in unmanaged local files or informal systems that bypass governance, auditability, or retention controls.

Authorised staff access your personal data to manage academic, administrative, and operational activities effectively, ensuring the smooth functioning of School services.

How Long Do We Keep Your Data

We retain personal data only for as long as necessary for the purposes for which it was collected and in accordance with legal, regulatory, contractual, and operational requirements. Retention periods for staff records are defined and managed through the School’s Data Retention Schedule and Policy, which specifies minimum retention periods, accountable Data Owners, systems-of-record, and secure disposal expectations for each category of record. Where legal claims, investigations, safeguarding matters, audits, or statutory obligations apply, retention may be extended under a documented legal hold. When records are no longer required, they are securely deleted or disposed of using approved methods. The School does not use automated decision-making or profiling that produces legal or similarly significant effects without appropriate safeguards and transparency.

Retaining data allows us to confirm your association with the School and provide references when needed. Avoiding automated decision-making ensures decisions about you are made fairly and accurately, without reliance on algorithms that could impact you without human oversight.

Changes to this Privacy Notice

We regularly review our privacy notices to ensure they remain accurate and up to date.

Regular reviews of privacy notices ensure compliance with legal requirements and reflect any changes in how we manage personal data.

Other Privacy Notices

We prioritise protecting your privacy. Please note that other privacy notices cover data related to staff, enquiries, applications, current students, alumni, and website use. These notices are available on our website.

Different activities within the School require specific privacy notices to ensure all personal data is managed appropriately and transparently. Providing access to these notices ensures you are informed about how your data is handled across different contexts.

The following metrics will be measured and regularly reviewed as key performance indicators for the School to ensure the effectiveness of this policy and associated operations.

Metrics and KPIs

Data Protection Training Completion Rate

Data Protection Training Completion Rate

Ensure 100% of new staff complete mandatory data protection training within 30 days of joining, and all staff complete annual refresher training.
Regular training reinforces awareness and compliance with data protection laws, reducing the risk of data mishandling.

Data Retention Compliance Rate

Data Retention Compliance Rate

Ensure 100% compliance with the School’s data retention policy by conducting bi-annual reviews of staff data held across all systems.
Ensures data is not held longer than necessary, reducing risks of breaches and ensuring legal compliance.

Review of Data Protection Procedures

Review of Data Protection Procedures

Conduct a comprehensive review of data protection procedures and practices annually, implementing any necessary improvements.
Regular reviews help identify areas for improvement and ensure procedures remain effective and up-to-date.