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.

Collecting Personal Data: Suggested Wording

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An example of a form of words for potential students enquiring about courses
might be:

Collecting Personal Data: Suggested Wording

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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

Collecting Personal Data: Suggested Wording

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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

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

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