Brasenose College GDPR ROPA – Employees, Fellows (Not Employed), Senior Common Room Members & Academic Visitors

Version 1.4 (Reviewed July 2023)

ID	Category of personal data	Source of the data	Why we process it	How long we keep this data	Our lawful basis for processing	Details relating to lawful basis (where applicable)	Special category / public interest / criminal data
1	Recruitment records – contact details, application documents, qualifications, references, requests for special arrangements, selection reports.	Obtained from you, referees and University of Oxford; generated by the College.	To assess applications and maintain records of recruitment activities and immigration compliance.	Unsuccessful applicants – deleted within 12 months (except archive records). Successful recruitment records retained 30 years or permanently for key roles.	Pre-contract steps; legal obligation; legitimate interests.	Interest in recording recruitment history and compliance with employment and immigration law.
2	Recruitment records – passport, visa and right-to-work information.	Obtained from you, Home Office/UKVI and University of Oxford.	To verify right to work and meet immigration requirements.	For employment duration plus two years after College ceases to sponsor visa holder.	Pre-contract steps; legal obligation; legitimate interests.	Compliance with immigration and employment law.
3	Equality monitoring data – health, sexuality, ethnicity or religious beliefs (for diversity monitoring).	Obtained from you.	Equality and diversity monitoring in anonymised form.	Held in perpetuity anonymised for College records and reporting.	Pre-contract steps; legal obligation; legitimate interests.	Compliance with equality law and promotion of equal opportunity.	Substantial public interest under the Data Protection Act 2018 (equality of treatment).
4	Recruitment and appointment records – process documents and records of applicant consideration.	Obtained from you and University of Oxford; generated by the College.	To document appointment decisions and retain records of engagement as employees or office-holders.	Successful applicants – 30 years after end of contract; unsuccessful – deleted within 12 months.	Pre-contract steps; legal obligation; legitimate interests.	Interest in administrative record-keeping and immigration compliance.
5	Recruitment records – medical or disability information used for reasonable adjustments.	Obtained from you or medical professionals.	To make reasonable adjustments during recruitment.	Unsuccessful – deleted within 12 months; successful – 1 year after employment ends.	Pre-contract steps; legal obligation; legitimate interests.	Interest in fair recruitment and management records.	Processing under employment and equality law (authorised by UK law).
6	Appointment records – criminal conviction and DBS information.	Obtained from you and third parties (DBS).	To assess suitability for roles requiring DBS checks and safeguarding compliance.	6 months after appointment or DBS result.	Pre-contract steps; legal obligation; legitimate interests.	Interest in safe recruitment and statutory safeguarding compliance.	Processed under Schedule 1 Parts 1-2 of the Data Protection Act 2018 for employment and safeguarding functions.
7	Appointment records – role details, probation and contract terms (including salary).	Obtained from University of Oxford; generated by College.	To record terms of employment and manage employment obligations.	30 years after employment ends.	Performance of contract; legitimate interests.	Interest in accurate employment records.
8	Employment records – bank account, NI number, salary and tax details, payslips and payments.	Obtained from you or third parties (e.g. HMRC).	To operate payroll and benefits systems and report to HMRC.	6 plus current tax year (PAYE retention requirement).	Performance of contract; legal obligation; legitimate interests.	Compliance with tax law and legitimate operation of payroll functions.
9	Employment records – expenses allowances and claims.	Obtained from you or third parties.	To manage expenses and make necessary payments.	7 years after employment ends.	Performance of contract; legal obligation; legitimate interests.	Compliance with HMRC rules and financial management interests.
10	Employment records – pension membership data and contributions.	Obtained from you or pension providers.	To enrol employees in pension schemes and record contributions.	Up to 30 years after employment ends (then skeleton record retained).	Performance of contract; legal obligation; legitimate interests.	Compliance with pension law and record-keeping requirements.
11	Occupational pension data – death benefit nominations, incapacity benefits, spousal or relationship data, and absence information.	Obtained from you; generated by us; third parties.	To provide information to the occupational pension provider.	Up to 30 years after employment ends (then skeleton record kept).	Performance of contract; legal obligation; legitimate interests.	Required to calculate and report pension benefits and contributions to HMRC.	Employment/social-security law; assessment of working capacity and medical diagnosis.
12	Employee and office-holder benefit scheme membership (e.g. childcare, health, cycle or travel schemes).	Obtained from you; generated by us; third parties.	To administer benefit schemes and process contributions.	30 years after employment or association ends.	Performance of contract; legal obligation; legitimate interests.	Interest in correct calculation and operation of employee benefits.
13	Contact details (names, addresses, phone numbers).	Obtained from you and the University of Oxford.	To contact you in employment/office-holder role and comply with immigration law.	30 years after termination of employment/association.	Performance of contract; legitimate interests.	Necessary communication for administration and lawful compliance.
14	Next-of-kin / emergency contact details.	Obtained from you.	To contact nominated person in case of emergency or concern for welfare.	30 years after termination.	Performance of contract; legitimate interests.	Employee-welfare interest in emergency preparedness.
15	Conflict-of-interest declarations.	Obtained from you.	To identify personal or family interests conflicting with College duties.	30 years after termination; if recorded in minutes, kept permanently.	Legal obligation; legitimate interests.	Required under Bribery Act; interest in transparent governance.
16	Biometric data (fingerprint clock-in for casual workers).	Obtained from you.	To record attendance and working hours accurately.	Deleted when employment/association ends or consent withdrawn.	Performance of contract; legitimate interests.	Accurate recording of hours worked.	Employment-law authorisation for biometric processing.
17	Dietary information.	Obtained from you.	To meet health, religious or philosophical dietary needs.	Deleted within 12 months of contract/association end.	Performance of contract; legal obligation; legitimate interests.	Compliance with food-safety and equality legislation.	Substantial public interest under UK Data Protection Act 2018.
18	Probation-period records – dates, feedback, evaluations and decisions.	Obtained from University of Oxford; generated by us.	To manage and assess probation performance per contract.	30 years after employment/association ends.	Performance of contract.	Interest in documenting employment progression and reviews.
19	Learning and development records – attendance, completions, certifications.	Obtained from you or training providers.	To maintain accurate records of training and development.	30 years after termination.	Performance of contract; legal obligation; legitimate interests.	Required for compliance with mandatory training; interest in workforce planning.
20	Promotion and progression records – applications, references, decisions, awards and long-service recognition.	Obtained from you, University of Oxford, or referees.	To manage promotion processes and maintain archive of advancement.	30 years after termination; items of historic interest kept permanently.	Performance of contract; legitimate interests.	Interest in recording staff development and recognition.
21	Grievances and investigations – records of complaints, findings and appeals.	Obtained from you; generated by us; third parties.	To manage grievance procedures in compliance with employment law.	30 years after termination.	Performance of contract; legal obligation; legitimate interests.	Proper investigation and resolution of employment disputes.
22	Disciplinary or harassment records – investigations, decisions, appeals, dismissals or settlements.	Obtained from you, University of Oxford, or third parties.	To investigate and record disciplinary matters and outcomes.	30 years after termination.	Performance of contract; legal obligation; legitimate interests.	Compliance with employment law; proper management of conduct issues.	Processed under Data Protection Act 2018 Schedule 1 Parts 1–3 for employment rights and legal claims.
23	Appraisal information – objectives, feedback, records of discussions and PDPs.	Obtained from you or others; generated by us.	To monitor and support professional development.	30 years after termination.	Performance of contract; legitimate interests.	Interest in managing staff performance and career progression.
24	Capability procedure records – performance indicators, review meetings, outcomes.	Obtained from you, University of Oxford, or third parties.	To manage under-performance and support development.	30 years after termination.	Performance of contract; legitimate interests.	Interest in managing capability issues fairly.	Employment law and health assessment where relevant.
25	Staff rotas, time sheets, attendance and casual work records.	Obtained from you; generated by us.	For payroll, attendance tracking and workforce planning.	30 years after termination (10 years for casual work forms).	Performance of contract; legal obligation; legitimate interests.	Accurate pay and attendance reporting to HMRC.
26	Sabbatical records – proposals, dates, reports.	Obtained from you; generated by us.	To manage sabbatical entitlements and maintain College archives.	30 years after termination; minutes retained permanently.	Performance of contract; public task; legitimate interests.	Support of teaching (public task) and HR planning (legitimate interest).
27	Leave and buy-out requests.	Obtained from you; generated by us.	To manage requests for teaching remission and record absences.	30 years after termination.	Performance of contract; legitimate interests.	Interest in balancing workloads and wellbeing.
28	Absence records – holiday, maternity/paternity, career breaks etc.	Obtained from you; generated by us.	To record, monitor and plan absences.	30 years after termination.	Performance of contract; legal obligation; legitimate interests.	Employment and equality compliance; workforce planning.	Employment/social-security law; medical diagnosis where relevant.
29	Sickness records and documentation – fit notes, certificates, returns to work.	Obtained from you; generated by us; third parties.	To manage health-related absences and comply with H&S law.	30 years after termination (40 years for certain regulatory records).	Performance of contract; legal obligation; legitimate interests.	Compliance with employment law and H&S planning.	Employment/social-security law; health assessment.
30	Medical questionnaires and occupational health reports.	Obtained from you; medical professionals.	For occupational health and equality compliance.	30 years after termination (40 years for regulatory records).	Performance of contract; legal obligation; legitimate interests (+ consent for specific reports).	Interest in safe working conditions and statutory compliance.	Employment/social-security law; health diagnosis and treatment purposes.
31	Health and Safety assessments.	Obtained from you or third parties.	To adapt work duties and environment for safety and wellbeing.	30 years after termination (40 for asbestos-related records).	Performance of contract; legal obligation; legitimate interests.	Compliance with H&S law and planning for employee welfare.	Employment/social-security law; health assessment.
32	Housing applications and tenancy records – applications, agreements, deposits and fees.	Obtained from you; generated by us.	To manage College-owned housing for employees and office-holders.	7 years after tenancy ends.	Performance of contract; legal obligation.	Required by law for deposit schemes and tenancy records.
33	Residential occupant records – names, ages, disability details, nationality, immigration status.	Obtained from you.	To manage College-owned residences and comply with Right-to-Rent and immigration law.	1 year after tenancy ends (or per Home Office requirements).	Performance of contract; legal obligation; legitimate interests.	Interest in security and compliance with residency law.
34	Joint equity scheme arrangements — title documents, mortgage paperwork and payment records.	Obtained from you; generated by us; third parties.	To document and administer the College joint equity scheme.	Retained for 7 years following release of the College’s charge over the property.	Performance of contract; legitimate interests.	We and you have a legitimate interest in ensuring the scheme is documented and managed correctly.	To the extent special category data is processed it will be done under substantial public interest; criminal conviction data only where relevant for legal advice or proceedings.
35	References provided by or in relation to you.	Obtained from you; generated by us; third parties.	To provide references for employment, volunteering, library access or tenancy.	Records of references kept for 30 years from termination; skeleton note of reference retained permanently.	Legitimate interests.	We and you have an interest in providing and retaining accurate reference records.
36	End of employment records — exit interviews, correspondence, redundancy calculations, termination records.	Obtained from you; generated by us; third parties.	To record reasons for leaving, address queries and preserve appropriate records.	Retained for 6 years from termination (longer where legal proceedings or special circumstances apply).	Performance of contract; legal obligation; legitimate interests.	Records may be retained longer where legal advice, proceedings, or public interest justification exists; consent sought for health specifics.	Where allegations/convictions included, processing may be based on public interest/legal proceedings or consent.
37	Business records: Event & meal bookings — attendee details, payments and outstanding charges.	Obtained from you; generated by us; third parties.	To manage catering and event administration and recover monies owed.	Outstanding payments retained until settled; event records kept for 10 years after academic year.	Performance of contract; legitimate interests.	Legitimate interest in efficient management and debt recovery.
38	Business records: Room bookings for College facilities.	Obtained from you; generated by us.	To administer facility bookings and security of premises.	Retained for 10 years from end of relevant academic year.	Legitimate interests.	Interest in managing facilities, security and usage records.
39	Business records: Computer and email information — logins, IP addresses, equipment allocation, connection logs, internet usage.	Obtained from University of Oxford; generated by us.	To manage IT resources and security.	Destroyed one year after IT account closure.	Performance of contract; legitimate interests.	We have a legitimate interest in proper IT administration and security.
40	Business records: Information security incidents and PC misuse records.	Obtained from University of Oxford; generated by us.	To secure systems, investigate misuse and for potential disciplinary or police action.	Retained for one year from last action regarding the incident.	Performance of contract; legitimate interests.	Legitimate interest in secure systems; processing may be necessary for legal advice or proceedings.	Often necessary for obtaining legal advice; may meet Schedule 1 conditions of DPA 2018.
41	Business records: Email contact information used in ad hoc mailing lists for College events.	Obtained from you; generated by us; third parties.	To allow employees and office-holders to participate in College events.	Email contacts removed within three months of termination.	Performance of contract; legitimate interests.	Legitimate interest that employees are informed of College events.
42	Business records: Allocation of key fobs / access cards.	Generated by us.	To grant access to College facilities while maintaining security.	Retained for one year after termination of employment/association.	Performance of contract.
43	Business records: Records generated for legal or statutory compliance (e.g. data protection, FOI, safeguarding, H&S, counter-terrorism, legal claims, audits).	Generated by us.	To maintain records of compliance and supply information when required by law or auditors.	Typically retained for 7 years from termination unless compelling justification for longer retention.	Legal obligation.	Processing necessary to comply with various legal requirements and statutory duties.	Where special category data processed, done under substantial public interest (DPA 2018 Part 2); meets Schedule 1 conditions where applicable.
44	Business records: Security records — CCTV, access control records, incident and accident reports and H&S records.	Generated by us.	To monitor attendance, maintain safety and investigate incidents on College premises.	CCTV/access logs retained for 6 months; incident and H&S records retained for 6 years (minutes permanent if referenced in Governing Body).	Performance of contract; legitimate interests.	Legitimate interest in restricting access to authorised persons and recording incidents for safety and security.	Processing of special category data where necessary for public interest (DPA 2018) and for legal proceedings where applicable; criminal offence data processed when relevant.
45	Business records: Attendance and participation at College administrative meetings (Governing Body, sub-committees, working groups).	Generated by us.	To keep a formal record of administrative and management matters; records also go to College Archives.	Retained in perpetuity (archival record) where appropriate.	Public task; legitimate interests.	Where relevant to University education or public-funded research, processing is performance of public task; otherwise legitimate interest in documenting governance.
46	Academic records: Research project and funding applications and renewals.	Obtained from University of Oxford; you.	To record research activities and funding associated with employees or office-holders.	Retained for one year from project completion (or one year from unsuccessful application notification).	Performance of contract; legitimate interests.	Legitimate interest in recording research and funding sources to support academic work.
47	Academic records: Teaching schedule information (subjects taught, session size, timing and location).	Generated by us.	For the administration and management of College teaching.	Retained for 10 years from end of relevant academic year.	Performance of contract; public task; legitimate interests.	Students and College have legitimate interest in teaching records for administration and academic purposes.
48	Academic records: Pastoral care records (tutor responsibilities, advisees, interventions and advice).	Obtained from you; generated by us.	To maintain records of pastoral care provided to students and handle any complaints.	Retained for 30 years from date the student left College.	Performance of contract; legitimate interests.	Legitimate interest in creating records of pastoral care to handle future complaints and assess system functioning.
49	Academic records: Opinions and comments made by you on students’ reports or in College meetings (where recorded).	Obtained from you; generated by us.	To maintain College records and minutes concerning teaching, management and administration; archived.	Retained in perpetuity as part of College archives where applicable.	Performance of contract; public task; legal obligation; legitimate interests.	Necessary for education-related records and proper governance; may be required for legal or regulatory compliance.
50	Academic records: Library access and book records, overdue book records, library cards and fines.	Obtained from University of Oxford; generated by us; third parties.	To operate College library facilities.	Retained for one year from library account closure.	Performance of contract; public task.
51	College records: SCR membership files — names, contact details, commencement of membership, terms, CVs.	Obtained from you; generated by us.	To maintain records of Senior Common Room membership arrangements and any post-employment SCR membership.	Retained for 10 years after SCR membership ends; items of historical interest retained in perpetuity in archives.	Legitimate interests.	Proper maintenance of SCR records is in your and our legitimate interests.	Explicit consent may be used for some SCR matters.
52	College records: Formal photographs (visual ID for staff/office-holders).	Generated by us.	For visual identification, security and publication to enable identification by students and colleagues.	Retained permanently as part of skeleton employment record and archives.	Legitimate interests.	Legitimate interest in security and identification; archival interest in keeping visual record.
53	College records: Informal photographs (event, society and College life photographs).	Obtained from University of Oxford; generated by us; third parties.	To create a historical archive of College life and activities.	Retained in perpetuity by College archives where applicable.	Legitimate interests.	Legitimate interest in preserving historical record of College life.
54	College records: Records of cultural life and personal papers donated by members — teams, choirs, clubs, plays, performances and outcomes.	Obtained from University of Oxford; you; third parties; generated by us.	To preserve the cultural life of the College and maintain historical records useful for research and reference.	Retained permanently as part of College archives.	Legitimate interests.	College interest in maintaining and preserving College cultural records; archives used for research and historical reference.	May include special category data that has been manifestly made public; processed under public interest/archiving provisions with safeguards.

Version control: Version 1.4 (Reviewed June 2023)