This User Guide is a summary of tips and things to think about when working with data. The SU has policies on Data Protection, Computer Use, and Social Media that are available to staff, clubs, and societies.
Collecting Personal Data
Common sense will help you with many data protection issues. If you are unsure whether any actions you are taking in the collection, use, storage or release of personal information are inappropriate or could have adverse implications either for an individual or for WSU, stop and seek advice before proceeding.
- Where data can be attributed to a living individual, it is personal data and the rules in the Data Protection Act apply.
- People can be identified from seemingly anonymous data where it is used in conjunction with other information.
- The rules for processing the eight types of sensitive personal data are stricter than for other personal information, and extra caution is required. Always check this if you are in any way unsure!
- Simply having personal information, even if nothing is being done with it at the time, is enough for the rules of Data Protection Act to apply.
- When working in a partnership involving personal information or commissioning a person or organisation to process personal information on behalf of WSU, formal agreements between the parties will normally be required that take account of the requirements of the Data Protection Act. The Chief Executive will normally oversee such agreements.
- When collecting personal information, have you provided a clear and fair processing statement to the data subject (i.e. the person whose information you’re collecting) that covers ‘WHO, WHY, WHAT and for HOW LONG’? Below are some template data collection statements for use when collecting personal data in line the Data Protection Act 1998:
Any personal information you give to us will be processed in accordance with the UK Data Protection Act 1998. The insert club or society namewill use the information to insert purpose for which personal data will be used. If more than one purpose, list these out. Your personal information will be kept securely for insert retention period i.e. for the duration of your membership, until next year’s event etc.and not shared with any third parties without seeking your prior additional permission. If you have any concerns about the use of your personal information, please contact insert email or telephone number with name of contact.
Event Attendee information
Any personal information you give to us will be processed in accordance with the UK Data Protection Act 1998. The insert club or society namewill use the information to insert purpose for which personal data will be used. If more than one purpose, list these out. Your personal information will be kept securely for insert retention period i.e. for the duration of your membership, until next year’s event etc.and not shared with any third parties without seeking your prior additional permission. If you have any concerns about the use of your personal information, please contact insert email or telephone number with name of contact.
The personal information supplied will be used for insert purpose e.g. the purpose of course and event administration, and to compile either a paper delegate list to be distributed to all attendees at the event, or an electronic delegate list.It may be used by the insert club or society name for the purposes of advertising other events. It will not be shared with any third parties without seeking your prior additional permission. If you have any concerns about the use of your personal information, please contact insert email or telephone number with name of contact. If you do not wish to be contacted for further events, please contact insert email or telephone number with name of contact.
- Was the personal information with which you are working originally collected for another reason? If so, please seek advice from the Chief Executive. It is likely that you won’t be able to use it if the SU’s registration with the Information Commissioner’s Office doesn’t cover that specific type of processing.
- Do you intend to process personal information without obtaining the consent of data subjects? If so, please contact the Chief Executive.
- Have you reviewed your intended collection and use of personal information to make sure that only the minimum amount of personal information needed for a task is collected and used?
- Is the personal information for which you are responsible accurate and up-to-date?
- Have you thought about the length of time you need to keep this? Is this documented?
- Is personal data no longer needed? If not, make arrangements for its secure destruction.
- When destroying personal data, have you checked that the destruction has been properly authorised and documented? Refer to Records Retention Policy.
- Is someone asking questions or seeking access to their personal data? If it’s a member of staff, direct them to the HR Directors. If it’s a student or member of the public, contact the Chief Executive as soon as possible for advice on the best way to meet their needs or answer their questions.
- Remember the following practical steps to help minimise the risk to, or loss of, personal information:
- Do not share or disclose passwords.
- Never leave information unattended and lock computers/drawers/offices.
- Always password-protect and, where appropriate, encrypt information on portable devices and media.
- Implement formal agreements with third parties that include requirements in respect of personal information.
- Promptly remove access privileges from former staff or other individuals who should no longer need access.
- Ensure that everyone understands the sensitivity of the information disclosed to them in their duties.
- Report a potential loss or unauthorised access to information (see ‘What to do about a suspected data breach’ below).
- Shred or securely erase information when no longer required.
- Do not write papers or documents which disclose personal information without explicit permission.
- If you are unsure whether it is appropriate to place information onto a memory stick, pause and consider the implications of the data being lost or used against someone or WSU.
- Are you working with an international partner? Please contact the Chief Executive for advice & information on ‘safe harbour’ and model contract information.
Effective Use of Email
- Use of email requires the same care and imposes the same obligations as any other form of communication. Electronic mail is not the casual form of communication that many people believe; equally, it is not a secure form of communication and could easily be seen by someone other than the intended recipient.
- You should be especially careful to make sure that you do not inadvertently alter any contractual provision in an email.
- You should be careful not to write anything in an email that could be construed as harassment, bullying or be in way defamatory. Remember, deleting an email does not mean the email is no longer unrecoverable.
- You must not send emails for commercial purposes unrelated to the Union’s activities or for personal gain.
- If you receive communication marked private and confidential, you should not discuss or disclose this information to anyone outside of the distribution list for that mailing. It is the user’s responsibility to ensure that information is not disclosed without the prior consent of the sender unless you feel that the information breaches the law (see section above and the Computing Facilities Use policy).
- If you send any email to an outside organisation, the email will automatically have the following paragraph added before it leaves the organisation: WARNING - CONFIDENTIALITY NOTICE This e-mail and any files transmitted with it are confidential to Warwick Students' Union and are intended solely for the use of the individual or entity to whom they are addressed. If you have received this e-mail in error, please contact Warwick Students' Union on enquiries@warwicksu.com.
- If you send a personal email, you must start the letter with the following paragraph and mark the email content as personal in the subject box: “This email is personal. It is not authorised by or sent on behalf of the sender’s employer. This email is the personal responsibility of the sender.”
- You are not permitted to send unsolicited bulk email (SPAM) from Students’ Union accounts
- Check your email on each working day or arrange for a duly authorised person to do so on your behalf. For extended periods away from the office such as conferences or holidays, switch on and fill out your ‘Out of Office’ facility which will let the sender know that you are away and when you will be back.
- Do not impersonate any other user when using email or amend messages received or sent.
- Do not create email congestion by sending trivial messages or by copying emails to those who do not need to see them.
- Do not pass on any chain mail which asks you to send to another ‘x’ amount of people. Delete any such email received.
- All staff / student address books and distribution lists are the property of WSU. You may not distribute or use any of the information contained within them outside of the Union without prior approval of the Chief
- Executive or President who will ensure that the disclosure complies with the Data Protection Act.
- We will not set email accounts to automatically forward to external accounts, including University email accounts.
Management of information contained in emails
- Email is not a file store - you should keep your inbox down to a minimum to avoid system problems for all users. It is good practice to keep this to below 50 emails.
- Reply promptly to all emails requiring a reply. When a prompt response is not possible, send a short email acknowledging receipt and giving an estimate of when a detailed response will or should be sent.
- You should generally not send Confidential Data by email unless it is password-protected, particularly if it is being sent outside the organisation where it can be more easily intercepted.
- Always obtain confirmation of receipt for important emails sent.
- Where proof of opening or reading an email is required, use the ‘read receipt’ facility (nb. this may not work for emails sent outside of the organisation).
- Use the ‘delegates’ facility on Outlook to allow a duly authorised person to view your emails in your absence.
- Emails are not archived so that they can be easily recovered. If you need to keep a document or message, consider saving the document onto a backed-up space on your computer or printing the message/document and keeping a paper copy.
Passwords
The use of passwords helps to control the risk of unauthorised access to personal and WSU information. They are REALLY important. However, the use of public/shared computers or internet services presents a threat as usernames and passwords could be stored or shared inappropriately, sometimes without your knowledge.
While nothing can absolutely guarantee the security of passwords, the following advice increases password security and helps minimise this risk.
- You must use passwords/PINs as a first-line security control on ALL devices (e.g. PCs, laptops, smartphones) that are used for processing your and WSU information, and these details must not be shared with anyone.
- The IT Team will never ask for your password and neither should anyone else. If someone asks you for your password, you can legitimately say no.
- You must create passwords adhering to the following minimum password standard for WSU information and systems:
- A password unique for WSU system (i.e. not one which you use for other personal accounts) – this will minimise the risk to you personally if WSU systems or information are compromised.
- Easy to remember (i.e. doesn’t need to be written down) but difficult for others to guess – a ‘passphrase’ may be better than a password.
- Longer than 8 characters – the longer the better!
- Contain one character from the following: numbers, letters in uppercase, letters in lower case, symbols (£$%^&*)
- Changed every 60 days, and this cannot be traced back to an expired password (i.e. one you’ve already used).
- Changed immediately if you suspect someone knows it
For example, you ran a marathon in 1998, you could take the phrase “I ran the London Marathon in 1998”, and, taking just the first letters of each word and the numbers, turn it in to: irtlmi1998
Or simply have the whole phase or most of it without spaces.
Then for extra security, swap in some capital letters and special characters:
1RanTh3londonmarath0nIn1998
Passwords for files or devices
Where devices or files contain or can connect to personal or confidential data, these should be protected by a password or PIN as directed above.
- The password or PIN must not be sent with the file or device. You must communicate the password via another mechanism (e.g. by email, text or phone).
- Passwords for protected email attachments must never be sent in the same email as the attachment.
Security Common Sense
- Always lock your computer screen when you leave your desk (on Windows Ctrl Alt Del then Enter (or WindowskeyL)).
- Be careful entering login details in public places – you don’t know who may see these over your shoulder.
- Always log off computers in public areas such as meeting rooms or training rooms after you have used them. If someone does something to your computer when you’re not there, you will probably never know about it until it’s too late!
- Don’t click on links or respond to emails from unknown people asking for your personal or login details.
- Make sure your computer has acceptable anti-virus and firewall software installed and install regular updates to ensure you and your computer are protected.
- Install software updates quickly. You will be prompted to do this on managed computers, and it is advisable that you set your personal computer up to install updates automatically (or at least prompt you that updates are ready to install).
- Don’t access your WSU email or other important information from a shared computer or over wireless networks you don’t know. It is easy for your details or information to be copied, shared or left behind without your knowledge.
- Don’t allow your internet browser to remember your login details.
- Only install the software you really need and buy direct from reputable companies; never install browser software provided via a website pop-up or email.
- Before you submit any of your personal info online, make sure the website you're on is legitimate and won't use the information for anything that's going to harm you.
- Don't post too much information about yourself publicly, either on social media sites like Facebook, or on websites - once you've put it up online, it's very hard to remove it from the internet thanks to caching. Find out more at http://accidentaloutlaw.knowthenet.org.uk/
- Don't open any attachments or click any links in emails from people you don't know and trust - they could be part of a scam, or could install a virus on your computer.
- It’s really difficult to delete something from the internet. Even if you press ‘delete’, chances are it can still be found, saved and shared. Screen capture allows for material to be preserved that you may believe to be private. Pause before posting and apply a healthy dose of common sense.
- You must not post or use copyrighted material – including, but not limited to, photography, music and video – without the explicit permission of the copyright holder. It is good practice to quote the source for all graphics/images that you use.
- You are, however, encouraged to use creative commons media, provided you attribute sources correctly. Good sources of creative commons media include Compfight and Wikimedia Commons.
Social Media Common Sense
The basics
- Do not post illegal or libellous material.
- Do not post sensitive or confidential information.
- Do not discuss WSU internal operations (such as staffing arrangements, budgets) which have not been communicated to the membership.
- Do not share your passwords.
- If a team member or committee member who has access to your social media profiles leaves, reset your passwords.
- Be open, honest and human.
- Post regularly – you will need to agree how frequently.
- Monitor your accounts and respond to incoming messages.
- Do not use your social media account to abuse members of SU staff, as they have no right-of-reply and this could lead to disciplinary action being taken against you.
Getting the best from social media
- As an Officer, Club, Society or Committee member, you are the ‘public’ face of the student body and you should participate in the same way that you would in person – i.e. professionally and responsibly.
- You should try to add value to the conversation by contributing your knowledge or unique perspective. Only write about things you are familiar with and check your facts before posting.
- You are responsible for the online spaces related to your area of WSU, so please set clear ground rules and monitor their use regularly.
- If your social media account attracts the attention of other media outlets (such as newspapers or television), remember that the WSU President is the main spokesperson for the Students’ Union and you should liaise with them directly before responding.
- Traditional media monitor social media sites for stories. Take advantage of this by posting positive stories about your work or society.
Club and Society Social Media Regulations
As clubs and societies, you not only represent yourselves, but you also represent Warwick Students' Union. As a result, you need to follow the same rules and regulations as the SU and its staff (including Full-Time Officers). Your club/society social media account is yours to manage, to encourage students to join your club/society and to let them know what events you may be running. However, you must follow these regulations to ensure you do not alienate any potential or current members and potentially undermine sponsorship relations. These regulations therefore are used to determine what clubs/societies cannot post on the different social media platforms that they may use, and cover all club/society engagement with this media (including graphics, posts, stories, polls, messages and comments).
These regulations apply to club/society accounts. For individual members' accounts, the University's Social Media Policy takes precedence, unless an individual is indicating or claiming the post is on behalf of the club or society. Clubs or societies who fail to abide by these regulations will face an SU investigation and may, upon investigation by SU staff, face sanctions as in byelaw 5.
SU Regulations regarding society and club social media use:
- The social media page shall use the name they are identified with in their handover pack or constitution.
- A society/club shall not post media, including physical media (e.g. posters), depicting any of the following:
- Libelous material, or anything encouraging or referencing libelous material
- Sensitive or confidential information, including passwords and confidential WSU or sponsorship business
- Content that breaches copyright or contains other people's/organisations' material without permission from the creator
- Posts that are discriminatory or could be considered as harassment, including posts that are racist, sexist, religiously discriminating, homophobic, transphobic, ageist and ableist
- Posts that glorify or reference a recognised terrorist group
- Acts of violence, threatening violence or inciting violence
- Posts that threaten or intimidate individuals, whether a part of the club/society or external to the club/society/University
- Posts that condone, encourage or glamorise anti-social behaviour, or refer to the effects of drunkenness in a favourable manner - including posts that glamorise or encourage drinking games or excessive alcoholic consumption
- Posts that encourage or reference breakage of SU regulations
- Posts that depict serious injury or death
- Nudity or depictions of sexual acts
- Any other illegal activities not covered above
- Posts encouraging illegal activities
- If filming or taking pictures of members, then signs should be up saying that pictures will be taken and/or filming is being performed. If recording is taking place of individuals on their own then individual consent should also be gained. Individuals who do not wish to have themselves filmed or photographed should inform someone as soon as they can.
Those wishing to report a breakage of these regulations should submit an SU complaint via the Complaints Form
The Legal Bit
WSU has to make sure that it complies with all UK legislation regarding computer use and information security. Some of this legislation is related to employment situations, while some is for more general computer usage. You should be aware of the key Acts below to ensure that you don’t behave inappropriately or break the law while using WSU facilities. Ignorance is no defence as far as the law is concerned!
Data Protection Act 1998
The Data Protection Act regulates the use of personal data by organisations. Personal data is defined as information relating to a living, identifiable individual. The Act has eight guiding principles which are covered in the WSU Data Protection Policy.
Individuals can make “subject access requests”. The details of how these are handled are set out in the WSU Data Protection Policy, as well as on the website in the Privacy Policy.
Freedom of Information Act 2000
Freedom of Information Act 2000
The Freedom of Information Act gives individuals a right of access to information held by public bodies, subject to a number of exemptions. It is important to note that, while WSU is not subject to this Act as it is not a public body, we do sometimes still receive requests for information in writing (email, letter or fax). Each request is considered carefully so as not to put our activities or staff at risk by disclosing information inappropriately. The WSU Records Retention Policy provides further information on how FOI are to be handled.
Regulation of Investigatory Powers Act (RIPA) 2000
Regulation of Investigatory Powers Act (RIPA) 2000
RIPA regulates the powers of public bodies to carry out surveillance and investigation and also deals with the interception of communications. The Home Office offers guidance and codes of practice relating to RIPA.
Copyright, Designs and Patents Act 1988
Copyright, Designs and Patents Act 1988
The Copyright, Designs and Patents Act (CDPA) defines and regulates copyright law in the UK. CDPA categorises the different types of works that are protected by copyright, including:
- Literary, dramatic and musical works
- Artistic works
- Sound recordings and films
- Broadcasts
- Cable programmes
- Published editions
For any staff members or students who are facing issues or have questions relating to this Act and their activities, please seek appropriate advice for the relevant Sabbatical Officer (for students) or Line Manager (for staff) before acting, as the penalties can be significant.
Computer Misuse Act 1990
The Computer Misuse Act is intended to deter criminals from using a computer to commit criminal offences or from impairing or hindering access to data stored in a computer.
The Act contains three criminal offences for computer misuse:
- Unauthorised access to computer material
- Unauthorised access with intent to commit or facilitate commission of further offences
- Unauthorised modification of computer material
Human Rights Act 1998
The Human Rights Act puts the rights set out in the 1953 European Convention on Human Rights into UK law. Article 8, relating to privacy, is of most relevance to information security – it provides a right to respect for an individual’s “private and family life, his home and his correspondence”, a right that is also embedded within the Data Protection Act.
Limitation Act 1980
The Limitation Act is a statute of limitations providing legal timescales within which action may be taken for breaches of the law (for example, six years is the period in which an individual has the opportunity to bring an action for breach of contract). These statutory retention periods inform parts of WSU’s Records Retention policy.
Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011
Trolls, Twitter & Tantrums
Ground rules
It can also be useful to set some ground rules on your social media pages, so that followers know what is and isn't acceptable when it comes to engaging with you. Something along the lines of ‘We reserve the right to remove, without notice, any disruptive, offensive or abusive posts, including swearing or libellous statements' should suffice.
Retweets/sharing posts from other users
Sharing posts from other users - e.g. retweeting - is a big part of social media and something you should look to do; however, be careful what and who you share content from. While functions such as retweets do allow you to establish some distance between your account and the original author, you will still be held accountable if you share anything offensive, illegal, libellous or similar.
Censorship
Where possible, do not delete comments or responses from your followers unless they are illegal/libellous/sexist/racist etc - people are entitled to their opinion, even if it is a negative one. A comment that is simply negative or that disagrees with your opinion is not grounds for removal. If you do remove a comment, explain why.
Blog comments - to moderate or not?
A lot of social platforms don't offer you the option to moderate posts from your followers before they appear online, but you usually can delete them if they prove problematic. However, when it comes to blogging, you're often given the choice about whether or not you want to moderate comments before they appear online. You may not think much of this, but it can actually be very important, particularly if a libellous or offensive comment is posted.
If you choose to moderate posts before they appear online, you are seen, legally, as the publisher. This means that if you allow a problematic post online then you are the one slandering/offending/posting libellous content, NOT the comment author.
If you don't moderate comments before they appear online, you are no longer seen as the publisher. However, if a problematic comment is brought to your attention it is then your responsibility to deal with it - which usually means deleting. This is why many newspaper websites will allow you to comment on articles freely, but will also have procedures in place to report problematic content.
We would recommend taking the latter approach and allowing users to comment freely, with the understanding that you will step in and moderate or delete if needed.
What is reputational damage?
It can be very tempting to delete any negative comments posted on your social media channels, all in the name of avoiding reputational damage. While this is usually done with the best intentions, it can often be more harmful than just allowing a comment to stay, as it will seem like you are censoring your followers and denying them their right to express themselves.
Also, you might be surprised at the power of a crowd to defend you: if you hold fire on the delete button when you receive a negative post, there is every chance that some of your other followers will defend you, put out correct information, or just offer an alternative opinion. This can then lead to a stream of healthy debate on your profile, giving you the chance for even more engagement with your following. Don't be afraid to trust the power of your followers.
It is also very important to remember that members/officers being offended by something does not necessarily constitute reputational damage. It is actually far better for your organisation to either let your followers put forward their views or for you to engage and deal with negativity in a human, social manner, rather than pressing delete (which could be interpreted as the digital equivalent of sticking your fingers in your ears and closing your eyes).
Using Your Own Device
- Use secure means to access information (e.g. Virtual Private Network, as set out in the Computing Facilities policy).
- Do not store local copies of Confidential Data.
- Delete your browsing history from shared or personal computers to remove any cached session details.
- Keep devices physically secure and take reasonable measures to reduce the risk of theft or loss (e.g. keeping the device on your person and out of sight, don’t leave unattended in hotel rooms etc.)
- Set devices to automatically lock after a pre-defined period of inactivity (usually no more than a few minutes) and, where appropriate, to lock or wipe data if an incorrect password is entered too many times.
- Ensure sync’ing to cloud-based services (including backup) is explicitly authorised by the WSU Chief Executive and appropriate protection is provided.
- Keep software on mobile devices up to date with the latest version.
- Report theft or loss of mobile devices to your department, IT Team and the police.
- Remove WSU data when you leave the Students’ Union or stop any associated activities.
You must not store WSU or Confidential information on local computer drives (desktops, C or D drives) as these are not backed up and loss/failure of the computer will mean that the information may not be recoverable or available as required to undertake your activities. Mapped network drives are available to staff and these are backed up regularly.
Public cloud storage services such as DropBox and GoogleDocs are not to be used to store WSU or associated personal or confidential information without express prior permission from the Chief Executive.
Remote access to WSU computing facilities or information
You must only use the Virtual Private Network (VPN) provided by the SU through the University to remotely access WSU computing facilities and information, especially when connecting using your personal device or over a public network.
The VPN Service provides a secure method to connect to the University campus network regardless of where you are connecting from (e.g. wireless/internet). The VPN Service is available to all staff and students with a valid University IT Services username. For further information, please visit https://www2.warwick.ac.uk/services/its/servicessupport/networkservices/vpn/