Canterbury Christ Church University Data Protection Collecting Personal Data: Suggested Wording One condition for processing is the data subject has given consent. It is necessary to make clear to the person (data subject) the purposes, uses and disclosures of the data, together with any other recipients of the data and what their use will be. Those collecting data should ensure that at the point of collection the following information is provided to the data subject: the purpose for which the data is collected the recipients or classes of recipients to whom the data may be disclosed an indication of the period for which the data will be kept (e.g. "while we process your application", "for the duration of your studies" etc. rather than a specific period.) and any other information that may be required to ensure that the processing is 'fair' Anonymous statistical data is exempt, provided a data subject could is not capable of being identified indirectly, for instance by a student code. Those collecting personal information, by paper, electronically, telephone calls, surveys and on-line applications on the web, must ensure an appropriate Data Protection Act statement is included. The fact the data subject must “signify” agreement means there must be some active communication between the parties. A data subject may “signify” agreement other than in writing. However, it is not possible to infer consent from non-response, for example from a student’s failure to return or respond to a communication. Where a data subject does not signify agreement to personal data being processed, but is given an opportunity to object to such processing, although this does not amount to consent for the purposes of the Act, it may provide the basis to rely on for example, the legitimate interests condition. This would be provided the data subjects have been given the right to object before the data are obtained. The following are examples of statements for adaptation for particular collections of personal data. An example of a form of words for internal data collection might be Data Protection Act 1998 The data collected on this form will only be used for the purpose of IT user account administration within the University and will not be disclosed to any external sources without your express written consent. Both electronic and paper records will be deleted/shredded when the account is closed. An example of a form of words for potential students enquiring about courses might be: Collecting Personal Data: Suggested Wording June 2010 Page 1 Data Protection Act 1998 The data collected on this form may be used for the purposes of marketing courses and promoting the University. The data will not be disclosed to any organization not associated with the University. Please tick the box if you do not wish to hear from us again [ ] An example of a form of words for short course applicants might be Data Protection Act 1998 Personal data collected on this form will only be used for the purpose of student and University course administration, but may be disclosed to appropriate bodies/organizations associated with such courses and to other course attendees. An example for conference delegates The Data Protection Act 1998 The information supplied on this form will be retained by XXXX on a database and will be used to compile either a paper delegate list to be distributed at the event, or an electronic delegate list on the web. The information may be used for marketing purposes; you may be contacted by letter, fax, telephone or e-mail with details of future events, and courses organised or promoted by XXXX that might be of interest to you. Top of Form If you do not wish to receive such further information, please tick this box Bottom of Form A example for enrolment / re-enrolment forms: Data Protection Act 1998 I am aware that: the University will create and maintain computer and paper records on me, both during my course and after I leave the University; these records will be processed in compliance with the Data Protection Act 1998. I consent that the information in the records may be used for reports both internally within the University and to external bodies working with the University in student administration; including information required for grant, loan and other bursary administration. The legislation provides for data subjects being able to 'opt out' of having their data used and therefore must be given the opportunity to tick an OPT OUT BOX for future mail shots etc. should this be appropriate to the type of form they are completing, for example:Top of Form Collecting Personal Data: Suggested Wording June 2010 Page 2 Data Protection Act 1998 TICK this box if you do not wish to receive future mailings Bottom of Form NOTE: - Explicit consent ('opting in') may be required where sensitive personal is concerned. Collecting Personal Data: Suggested Wording June 2010 Page 3