A) The Purpose of this Document
The Careers Service and Internship Office at the University of Oxford is committed to respecting and protecting your privacy. This policy describes how we collect and use personal information about you if you use our services, participate in our programmes or visit our website, in accordance with the General Data Protection Regulation (GDPR). Our website contains links to various third party websites. Please note that these websites have their own privacy policies for which we do not accept any responsibility or liability. Please check these policies before you submit any personal data to these websites.
Where we refer in this policy to your ‘personal data’, we mean any recorded information that is about you and from which you can be identified. It does not include data where your identity has been removed (anonymous data).
Where we refer to the ‘processing’ of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure, deletion, and retention.
C) Who is using your data
The Careers Service and Internship Office at the University of Oxford is the “data controller” for the information that we collect when you visit our website or use our services. This means we decide how to use it and are responsible for looking after in accordance with the GDPR.
Access to your personal data within the Careers Service will be provided to those staff who require access as part of their work. It will also be shared with the third parties as described in Section E.
D) Types of data we collect about you
- Technical information, for example, the type of device (and its unique device identifier) you use to access our site, the Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform; and
- Information about your visit to our site including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
The information we hold about you may include the following:
- Personal details such as name, title, address, telephone number, email address, date of birth, sex and gender identity, education and employment, funding and financial support information;
- Your organisation’s sector or details of the career sector/s you are interested in or work in;
- Your feedback on the Careers Service collected through surveys such as (but not limited to) those sent to users of our services;
- Attendance records at the Careers Service, information about your use of our information and communications systems, including your communication preferences and website interaction (cookies and similar technologies);
- Information about your socio-economic background.
We may also process the following ‘special categories’ of more sensitive personal data:
- Information about your health, including any disability and/or medical condition;
- Information about your race or ethnicity.
Special category data will not be available to those assessing your application and will only be used in accordance with section G.
E) How we use your personal data
We will use your personal information in the following circumstances:
- Where we need to fulfil the contract we have entered into with you (to provide you with products and services you have requested).
- To customise the content you see on our website based on any preferences you have set on CareerConnect.
- Where we need to contact you about careers information specific to your interests.
- Where we have a legitimate interest to do so, for example to ensure that we understand who uses our website and services, how our website and services are used, and to improve our website and ensure it is secure.
Where permission is required for our use of your personal data, by ticking the appropriate consent box or otherwise communicating your permission (for example, by email or by providing us with non-mandatory information), you consent to our use of that personal data as set out in this policy. You can always withdraw your permission and we will stop any processing of your personal data with your consent. However, this will not affect the lawfulness of any processing carried out before your withdrawal of consent and you may no longer be able to use the website and services in the same way you did before.
Change of purpose
We will only process your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.
Please note that we may process your data without your knowledge or consent where this is required or permitted by law.
F) Sharing your data with third parties
In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your information with the following types of organisations:
- Group GTI, the providers of the CareerConnect service
- Employers and internship hosts. When you apply for an internship, you will be asked to confirm that you consent to us transferring your application (including your personal data) to a third party, an employer or internship host.
- Consultants. For experiential programmes, we will transfer your application to a contracted consultant who runs these programmes.
- The University of Oxford Alumni Office.
Where information is shared with third parties, we will seek to share the minimum amount necessary. For example, we may in appropriate cases share only your student number and not your name (this is known as pseudonymisation).
All third-party service providers that process data on our behalf are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.
G) Special Category data and Criminal Conviction data
Special category data and criminal conviction data require a higher level of protection than personal data. Listed below are examples of processing activities that we regularly undertake in respect of these types of data. In addition to the activities listed below, it may sometimes be necessary to process this sort of information for exceptional reasons, for example, because it is necessary to protect your vital interests (including in relation to health and safety) or those of another person or for safeguarding purposes.
Health (Including disability)
We may process your health and disability data where necessary to make reasonable adjustments for disability and/or to monitor equal opportunities. We may make reasonable adjustments for the appointments, programmes, and events that we run.
This includes any health disability data you share with us through communication with us via email or any other platform.
Where required to carry out our duties and obligations, we may share data with third parties as identified in section H below.
H) Transfers of Your Data Overseas
There may be occasions when we transfer your data overseas, for example, if we communicate with you using a cloud-based service provider that operates outside the UK, or Internship Office applications where selection takes place overseas, such transfers will only take place if one of the following applies:
- the country receiving the data is considered by the UK to provide an adequate level of data protection;
- the organisation receiving the data is covered by an arrangement recognised by the UK as providing an adequate standard of data protection;
- the transfer is governed by approved contractual clauses;
- the transfer has your consent;
- the transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract;
- the transfer is necessary for the performance of a contract with another person, which is in your interests;
- the transfer is necessary in order to protect your vital interests or of those of other persons, where you or other persons are incapable of giving consent;
- the transfer is necessary for the exercise of legal claims; or
- the transfer is necessary for important reasons of public interest.
I) Retention Period
For students and research staff
We will retain your data only for as long as we need it to meet our purposes, including any relating to legal, accounting, or reporting requirements. Details of the retention periods for different types of data are available on the University's website.
For recruiters and internship hosts
We retain Internship Office placement data indefinitely unless a deletion request is submitted, or when the company informs the Careers Service that a recruiter has left their employment.
We retain data on job opportunities indefinitely unless a deletion request is submitted by the company or when the company informs the Careers Service that a recruiter has left their employment.
How we protect your data
The University of Oxford takes precautions to safeguard your personal information against loss, theft and misuse, unauthorised access, disclosure and destruction through the use of appropriate administrative, physical, and technical security measures.
J) Your Rights
Under certain circumstances, by law you have the right to:
- Request access to your data (commonly known as a 'subject access request’). This enables you to receive a copy of your data and to check that we are lawfully processing it.
- Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate data we hold about you.
- Request erasure of your data. This enables you to ask us to delete or remove your data in certain circumstances, for example, if you consider that there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing (see below).
- Object to processing of your data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your data for direct marketing purposes.
- Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your data to another party.
Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. However, where you have consented to the processing (for example, where you have asked us to send you certain types of communication), you can withdraw your consent at any time, by emailing us at firstname.lastname@example.org. In this event, we will stop processing as soon as we can. If you choose to withdraw consent, it will not invalidate past processing and it may impact our ability to provide particular additional services to you. Further information on your rights is available from the Information Commissioner’s Office (ICO).
If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, please contact the University’s Information Compliance Team at email@example.com. The same address can be used to contact the University’s Data Protection Officer. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
If you remain dissatisfied, you have the right to lodge a complaint with the ICO at https://ico.org.uk/concerns/.
K) Changes to this Policy
If you wish to raise any queries or concerns about this policy, please contact us at:
The Careers Service and Internship Office
56 Banbury Rd
Oxford OX2 6PA