GDPR Privacy Statement for Employees

The Royal Northern College of Music (RNCM) is committed to handling and storing personal information in compliance with the terms of the Data Protection Act 1998 and the forthcoming General Data Protection Regulation (GDPR). The RNCM, as your employer, collects and processes personal information, or personal data, to manage the employment relationship. This personal information may be held by the College on paper or in electronic format.

In all instances the RNCM is the data controller; its Data Protection Policy may be viewed here: Data Protection Policy.

This privacy statement applies to all current and former employees.

What information do we collect and/or process?

• Biographical – name, title, previous surname, date of birth, gender
• Contact details – postal address, personal e-mail address, telephone number
• Emergency contact details / next of kin
• Marital status and dependants
• Start and end dates of employment
• Recruitment records, including personal information included in a CV, any application form, cover letter, interview notes, references, copies of proof of right to work in the UK documentation, copies of qualification certificates, copy of driving licence and other background check documentation
• Passport and visa information (if relevant)
• Details of skills, qualifications, experience and work history, both with previous employers and with the College
• Terms and conditions of employment (including job title and working hours), as set out in a job offer letter and contract of employment
• Salary, entitlement to benefits and pension information
• National Insurance (NI) number
• Bank account details, payroll records, tax code and tax status information
• Any disciplinary, grievance and capability records, including investigation reports, collated evidence, minutes of hearings and appeal hearings, warning letters, performance improvement plans and related correspondence
• Records relating to career history such as probationary reviews, training records, performance development review (PDR), performance reviews and ratings, targets and objectives set
• Annual leave and other leave records, including details of the types of and reasons for leave being taken and related correspondence
• Any termination of employment documentation, including resignation letters, dismissal letters, redundancy letters, minutes of meetings, settlement agreements and related correspondence
• information obtained through electronic means, such as access/swipecard or time and attendance system
• information about your use of our IT systems, including usage of telephones, e-mail and the Internet
• Photographs
• Disclosure and Barring Service record

We may also collect, use and process the following special categories of your personal information:

• Your health, including any medical condition, sickness absence records (including details of the reasons for sickness absence being taken), medical reports and related correspondence
• Whether you have a disability in respect of which the College needs to make reasonable adjustments,
• Equality monitoring information such as ethnic origin, sexual orientation, religion or belief
• Trade union membership
• Criminal convictions and offences

How do we collect the information?

Information is collected under the following circumstances:

• During the recruitment process, either directly or, sometimes, from a third party such as an employment agency
• From external third parties, e.g. references from former employers, information from background check providers, information from credit reference agencies, and criminal record checks from the Disclosure and Barring Service (DBS).
• As part of the procedure to commence a contract of employment with the RNCM

Additional personal information is also collected throughout the period of your working relationship with the RNCM. This may be in the course of your work-related activities. Whilst some of the personal information you provide to us is mandatory and/or is a statutory or contractual requirement, some of it you may be asked to provide to us on a voluntary basis. We will inform you whether you are required to provide certain personal information to us or if you have a choice in this.

Why and how do we use your personal information?

Under the terms of the GDPR the lawful bases for processing your personal information are:

• Contractual
  To take steps to enter into or administer an employment contract and to ensure we meet our obligations under that contract.
  For example, to provide you with an employment contract, to pay you in line with your employment contract and to administer benefit and pension entitlements.

• To meet our legal obligations.
  For example, we are required to check an employee’s entitlement to work in the UK, to report salary and tax data to HMRC and to allow employees to take periods of leave.

• With consent

Processing employee data allows the College to:

• Maintain accurate and up-to-date employee records and contact details (including details of whom to contact in the event of an emergency)
• Run recruitment processes and assess your suitability for employment or promotion
• Comply with statutory and/or regulatory requirements and obligations
• Comply with the duty to make reasonable adjustments for disabled employees and workers and with other disability discrimination obligations
• Make decisions about pay reviews
• Ensure compliance with your statutory and contractual rights
• Ensure you are paid correctly and receive the correct benefits and pension entitlements, including liaising with any external benefits or pension providers or insurers
• Ensure compliance with income tax requirements, e.g. deducting income tax and National Insurance contributions where applicable
• Operate and maintain a record of disciplinary, grievance and capability procedures and action taken to ensure acceptable conduct within the workplace
• Operate and maintain a record of performance management systems to plan for career development, and for succession planning and workforce management purposes
• Record and assess your education, training and development activities and needs
• Plan for career development and succession
• Manage, plan and organise work
• Enable effective workforce management
• Operate and maintain a record of annual leave procedures
• Operate and maintain a record of sickness absence procedures
• Ascertain your fitness to work
• Operate and maintain a record of maternity leave, paternity leave, adoption leave, shared parental leave, parental leave and any other type of paid or unpaid leave or time off work to ensure employees receive the benefits to which they are entitled
• Obtain Occupational Health advice, to ensure that the College complies with its duties in relation to individuals with disabilities and to meet our obligations under health and safety laws
• Make decisions about continued employment
• Operate and maintain a record of dismissal procedures
• Provide references on request for current or former employees
• Prevent fraud
• Monitor use of our IT systems to ensure compliance with our IT-related policies
• ensure network and information security and prevent unauthorised access and modifications to systems
• Ensure effective HR, personnel management and business administration
• Ensure adherence to College rules, policies and procedures
• Monitor equal opportunities and to maintain and promote equality in the workplace  Enable us to establish, exercise or defend possible legal claims
• With consent

Please note that we may process your personal information without your consent, in compliance with these rules, where this is required or permitted by law.

Why and how do we use your sensitive personal information?

We will only collect and use your sensitive personal information, which includes special categories of personal information and information about criminal convictions and offences, when the law allows us to and / or with consent.

• Some special categories of personal information, i.e. information about your health or medical conditions, trade union membership, information about criminal convictions and offences, is processed so that we can perform or exercise our obligations or rights under employment law and in line with our Data Protection Policy.
• Information about health or medical conditions may also be processed for the purposes of assessing the working capacity of an employee or medical diagnosis, provided this is done under the responsibility of a medical professional subject to the obligation of professional secrecy, e.g. a doctor, and in line with our Data Protection Policy.
• We may also process these special categories of personal information, and information about any criminal convictions and offences, where we have your explicit written consent. In this case, we will first provide you with full details of the personal information we would like and the reason we need it, so that you can properly consider whether you wish to consent or not. It is entirely your choice whether to consent. Your consent can be withdrawn at any time.
• Where the College processes other special categories of personal information, i.e. racial or ethnic origin, religious or philosophical beliefs and sexual orientation, this is done only for the purpose of equal opportunities monitoring and in line with our Data Protection Policy. Personal information that the College uses for these purposes is either anonymised or is collected with your explicit written consent, which can be withdrawn at any time. It is entirely your choice whether to provide such personal information.

We may use your special categories of personal information, and information about any criminal convictions and offences, where it is needed for the establishment, exercise or defence of legal claims.

Who collects and/or has access to your personal information?

Information is collected by, and on behalf of, the RNCM. Your personal information will be shared by departments within the College including, but not limited to: members of the HR department, Finance (including payroll), your line manager, senior managers and IT & BSDU staff, if access to your personal information is necessary for the performance of their roles. The categories of information shared will depend on the purpose for which it is required.

Access to, and the use of, emergency contact details of employees is restricted to authorised members of the Human Resources Department

Data sharing

The College may also share your personal information with third-party service providers (and their designated agents), including:

• Disclosure and Barring Service (DBS)
• Higher Education Statistics Agency (HESA) to comply with reporting obligations
• Travelers (Liability insurers) AON Protect (Travel insurers)
• Greater Manchester Pension Fund, Teachers Pension Scheme, Universities Superannuation Scheme (pension scheme providers and pension administration)
• Healthwork Ltd. (occupational health providers)
• KPMG and BDO (external and internal auditors)
• Mills and Reeve (legal advisers)
• Capita Surveys and Research (for the delivery of Staff Engagement surveys)
• Greater Manchester Police and other relevant authorities for purposes relating to the prevention and detection of crime, apprehension and prosecution of offenders, collection of a tax or duty, or safeguarding national security

The College may also share your personal information with other third parties in the context of a potential sale or restructuring of some or all of its business. In those circumstances, your personal information will be subject to confidentiality undertakings.

We may also need to share your personal information with a regulator or to otherwise comply with the law.

Where your information is stored

Your information is stored on secure, password protected databases and networks. Access is given to staff only with the appropriate organisation. Data is held mainly in the United Kingdom with some on servers within the European Union.

Where your personal information is shared with third-party service providers, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.

For how long does the College keep your personal information?

Information is retained for as long as necessary for the purposes for which it is required, and in line with the RNCM Retention Schedule.

CCTV & ANPR

The RNCM operates CCTV camera surveillance throughout the building and on the perimeter of the premises. The system is in place for the purposes of safeguarding personal security, to protect property and for the prevention and detection of crime. The images are stored securely and monitored in a controlled space. Images may be shared with Greater Manchester Police if required for the investigation of crime.

The RNCM operates an ANPR system in its car park situated under the Sir Charles Groves Hall of Residence, adjacent to the RNCM building. This system is used for the purpose of granting access to authorised users of the car park and to manage use by visitors.

Transferring personal information outside the European Economic Area

The College will not transfer your personal information to countries outside the European Economic Area without your consent

Automated decision making

Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention.

We do not envisage that any employment decisions will be taken about you based solely on automated decision making, including profiling. However, we will notify you in writing if this position changes.

What if you fail to provide personal information?

If you fail to provide certain personal information when requested or required, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. You have some obligations under your contract of employment to provide the College with data.  For example, you must report absences from work and you may also have to provide the College with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements.

Your rights

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes, e.g. you change your home address, during your working relationship with the College so that our records can be updated. The College cannot be held responsible for any errors in your personal information in this regard unless you have notified the College of the relevant change.

You have the right to request copies of any of your data held by the RNCM

Details of our Subject Access request procedure are available on the website or contact the
Quality Assurance & Enhancement Manager
Royal Northern College of Music, 124 Oxford Road, Manchester, M13 9RD. Tel. 0161 907 5240 [email protected]

You have the right to have your data rectified or erased

If you wish to amend the information we hold about you please contact the Human Resources Department.

Contacts and complaints

If you have any queries or complaints about this policy please contact:
Data Protection Officer (DPO), Royal Northern College of Music. 124 Oxford Road, Manchester M13 9RD or send an email to [email protected].

If you are dissatisfied with the RNCM’s response to your request to access to your data, or handling of your request to rectify or erase your data, you may contact the
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Tel. 0303 123 1113 https://ico.org.uk/concerns/

Issued May 2018

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