WA needs to hold and use information about you for the purposes of your employment. Much of this information is “personal data” and “sensitive personal data”, as these terms are defined in the Data Protection Act 1998 (the “DPA”). Accordingly, we are obliged to comply with the requirements of the DPA. This policy provides you with information regarding those requirements.
WA also holds, uses and otherwise processes a great deal of information about other individuals, much of which is sensitive and confidential. In addition to your general obligations to WA regarding confidential information, you should be aware that where this information constitutes personal data relating to a living individual, we are obliged to comply with the requirements of the DPA.
Data Protection Principles
Under the DPA, WA is required to ensure that it your personal data is:-
- processed fairly and lawfully;
- processed only for specific purposes;
- adequate, relevant and not excessive;
- accurate and kept up to date;
- kept for no longer than is necessary;
- kept in accordance with your rights; and
- kept securely.
As your employer, WA will hold, use and otherwise process personal data relating to you for any purposes which reasonably arise out of and/or in connection with, your employment, including without limitation, for the following purposes:
- considering your suitability for employment;
- administration of the payroll;
- provision of employee benefits;
- compliance with legal requirements;
- performance monitoring;
- absence management;
- effective management of the work we carry out;
- in connection with disciplinary matters;
- to establish your training and/or development requirements;
- to establish a contact point in an emergency.
We will ensure that all your personal data is up to date and held securely.
Sensitive Personal Data
In addition, WA may hold, use and otherwise process sensitive personal data which relate to you for any purposes which reasonably arise out of and/or in connection with your employment with WA.
Sensitive personal data is, according to the DPA, personal data which consists of the following:-
- your racial or ethnic origin;
- your political opinions;
- your religious or similar beliefs;
- your membership or otherwise of a trade union;
- your physical or mental health or condition;
- your sexual life;
- your commission or alleged commission of any offence; or
- proceedings relating to such an offence.
We envisage processing sensitive personal data in the following circumstances:-
- information relating to your physical or mental health or condition for health monitoring purposes, assessing your suitability for work and for equal opportunities monitoring;
- information relating to your racial or ethnic origin where relevant to any application for a work permit and for equal opportunities monitoring;
- information relating to your membership or otherwise of a trade union for the purpose of undertaking consultations with employees where we are required to by law;
- information relating to your commission or alleged commission of any offence and proceedings relating to such an office where appropriate for determining your suitability for employment initially and on an ongoing basis.
Obligations relating to your Personal Data
In signing and agreeing to your terms and conditions of employment with WA, you have explicitly consented to WA holding, using and otherwise processing personal data and sensitive personal data relating to you for all purposes reasonably arising out of your employment with WA including the purposes specified above.
Personal data and sensitive personal data will be held by WA both manually and on computer. Such data shall only be kept for as long as we deem necessary, in accordance with the attached guidelines. The Head of Administration will have access to your personal data when required to fulfil the purposes specified above.
We are required to ensure that all personal data and sensitive personal data which we hold is accurate and, where necessary, kept up to date. In order to enable us to comply with this obligation, you are required to immediately notify Head of Administration of any changes to your personal details including, without limitation, any changes to your name, address, emergency contacts and bank details.
Obligations relating to the Personal Data of Others
In the course of your duties, you may be required to process personal data which relates to other individuals. You are required to comply with the data protection principles set out above and with any specific instructions given to you regarding such personal data.
In particular, you must not, save in the proper performance of your duties during your employment, make use of, divulge or communicate to any person (including any person working for or with WA) or any organisation, company and/or firm, any personal data or sensitive personal data relating to any third parties, including without limitation the following:-
- applicants for employment with WA (successful and unsuccessful);
- employees and former employees of the WA;
- other individuals who are doing work or have done work for WA;
- current and former colleagues, directors, athletes, officials, committee members and volunteers
Breach of this requirement will be treated very seriously and will result in disciplinary action taken against you. You should also be aware that in certain circumstances by making an unauthorised disclosure of personal data you will be committing a criminal offence.
The DPA gives employees certain rights in connection with personal and sensitive personal data which relate to them. In particular you are entitled to make a subject access request and (subject to certain legal exemptions) to receive copies of your personal data which we hold.
If you wish to exercise this right, you must make a request in writing to the Chief Executive Officer.
Revision of Policy
This policy is not intended to be contractually binding. The WA reserves the right to amend and/or withdraw this policy from time to time for any reason, including without limitation, to take account of changes in the law, best practice and/or operational requirements.