Processing personal data
Under the General Data Protection Regulation (GDPR), the University has to identify a legal basis for processing personal data and, where appropriate, an additional condition for processing special category data.
In line with our charter which states that we advance learning and knowledge by teaching and research, the University processes personal data for research purposes under Article 6 (1)(e) of the GDPR:
Processing is necessary for the performance of a task carried out in the public interest
Special category data is processed under Article 9 (2) (j):
Processing is necessary for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes
Research will only be undertaken where ethical approval has been obtained, where there is a clear public interest and where appropriate safeguards have been put in place to protect data.
In line with ethical expectations and in order to comply with common law duty of confidentiality, we will seek your consent to participate where appropriate. This consent will not, however, be our legal basis for processing your data under the GDPR.
Protecting and storing personal data
Information that research participants provide will be treated confidentially and shared on a need-to-know basis only. The University is committed to the principle of data protection by design and default and will collect the minimum amount of data necessary for the project. In addition we will anonymise or pseudonymise data wherever possible.
We will put in place appropriate technical and organisational measures to protect your personal data and/or special category data (for example, data may be stored in secure filing cabinets and/or on a password protected computer).
Sharing of data
The default position is that personal data will only be accessible to members of the project team. In some cases, however, the research may be of a collaborative nature and hence the data will be made accessible to others from outside the University. Information specific to the project will include details of when this is the case, who the 3rd parties are, and what they will do with the data. It is possible that personal data may be shared anonymously with others for secondary research and/or teaching purposes.
Transfer of data internationally
The default position is that data will be stored on University devices and held within the European Economic Area in full compliance with data protection legislation.
However, data may be transferred to the project partners based outside the European Economic Area. Any international transfer will be undertaken in full compliance with the GDPR.
The University has access to cloud storage provided by Google which means that data can be located at any of Google’s globally spread data centres. The University has data protection compliant arrangements in place with this provider. For further information see,
Your rights in relation to your data
Under the GDPR, you have a general right of access to your data, a right to rectification, erasure, restriction, objection or portability. You also have a right to withdrawal. Please note, not all rights apply where data is processed purely for research purposes. For information see, https://www.york.ac.uk/records-management/dp/individualsrights/
Right to complain
If you are unhappy with the way in which your personal data has been handled, you have a right to complain to the Information Commissioner’s Office. For information on reporting a concern to the Information Commissioner’s Office, see www.ico.org.uk/concerns