Guidance

Privacy Notice for the collection of 360 feedback for Senior Civil Servants

Updated 25 January 2021

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).

1. Your Data

1.1 Purpose

The purpose(s) for which we are processing your personal data is:

Data is collected for 360 feedback for Senior Civil Servants (SCS). This is part of the cross-civil service mandated process set out under the Performance Management Arrangements for the Senior Civil Service (April 2020).

Departments are required under the policy to enable their SCS to collect this data, but they are not forced to use the service provided by CSHR if they have an alternative provider. Approximately 4000 SCS use this tool, as outlined in minimum order contract provisions with YSC.

1.2 The data

The personal data gathered is:

  • name
  • email address
  • cohort name (department)
  • pay grade
  • subject ID (created for this process only)
  • respondent ID (created for this process only)
  • relationship (to the subject, for example, self, line manager, peer)

We will also ask those providing feedback to disclose their demographic data. This will be used only by our analysts, and there will be the option to prefer not to say. The demographic data gathered is:

  • length of time in organisation
  • age
  • gender
  • ethnicity
  • sexual orientation
  • profession
  • number of departments worked in
  • years in other government sectors
  • years in other non-government sectors
  • years in private sector

In addition, the following fields are gathered. These are the feedback questions that are the opinions of others (who are anonymised) but when assigned to an individual may be considered their personal data.

  • demonstrating their pride in and passion for the Civil Service
  • communicating the purpose and direction of the department/organisation with clarity and enthusiasm
  • valuing professional excellence and expertise in others
  • encouraging innovation and rewarding initiative
  • learning from what hasn’t worked as well as what has
  • please use this opportunity to provide further detail in relation to any of the ratings you have provided above
  • being straightforward, truthful and candid, including to those in power
  • surfacing tensions and resolving ambiguities
  • giving clear and honest feedback to help staff succeed
  • addressing performance concerns resolutely, fairly and promptly
  • being a team player and working collaboratively
  • encouraging others to take managed risks and learn from their mistakes
  • building credibility and influence to strengthen relationships with ministers and external stakeholders
  • developing and maintaining positive, productive relationships with junior staff
  • please use this opportunity to provide further detail in relation to any of the ratings you have provided above
  • giving others the space and authority to deliver
  • being visible and approachable at all times
  • demonstrating receptiveness to being challenged, however uncomfortable
  • championing difference, recognising the value it brings
  • demonstrating commercial awareness in decision making
  • embedding flexible and responsive ways of working including digital where possible
  • investing time in and showing commitment to their own development
  • nurturing talent and investing in the development of others to be effective now and in the future
  • please use this opportunity to provide further detail in relation to any of the ratings you have provided above
  • taking responsibility for delivery of the Government’s programme and Ministers’ priorities
  • developing strategies that focus on delivering results that have a long term impact
  • showing resilience in making tough strategic decisions
  • prioritising a consistently high quality customer outcome
  • maintaining real focus on delivering efficiency and value for money
  • please use this opportunity to provide further detail in relation to any of the ratings you have provided above
  • what are their main strengths as a leader and why? Please include up to three examples
  • what are their main areas to develop as a leader? Please include up to three examples
  • overall, please state if you feel they provide a good role model as a Civil Service Leader and how they demonstrate this?

We will also ask those providing feedback to disclose their demographic data. This will be used only by our analysts, and there will be the option to prefer not to say.

Processing your personal data is necessary for the performance of a contract to which you are a party - the provision of 360 feedback.

Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller, such as the exercise of a function of the Crown, a Minister of the Crown, or a government department; the exercise of a function conferred on a person by an enactment; the exercise of a function of either House of Parliament; or the administration of justice. In this case it is necessary to ensure that senior leaders within the civil service have a proper level of scrutiny and feedback, and that this is monitored centralled.

Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

The legal basis for processing your sensitive personal data is:

Processing is of a specific category of personal data and it is necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people specified (in paragraph 8(2) of Part 2 of Schedule 1 to the Data Protection Act 2018) in relation to that category with a view to enabling such equality to be promoted or maintained; and it is not carried out for the purposes of measures or decisions with respect to a particular data subject; and the data subject has not declined consent; and the data subject has not given notice that they do not wish their data to be processed for these purposes; and the processing is not likely to cause substantial damage or substantial distress to an individual. In this case it is to assess whether specific factors of an individual’s personal life may be leading to skewed results from the survey.

1.4 Recipients

Your personal data will be shared with:

  • YSC, whom CO have a contract with
  • the internal Cabinet Office Analysis and Insight team
  • HR contacts in departments
  • the HR Function Board once an aggregated (anonymised) set is created.
  • the Behavioural Insights Team for analysis to help us to eliminate bias in feedback

As your personal data will be stored on our IT infrastructure it will also be shared with our data processors who provide email, and document management and storage services.

1.5 Retention

Personal data will be held for three years and then deleted securely.

2. Your rights

You have the right to:

  • request information about how your personal data are processed, and to request a copy of that personal data
  • request that any inaccuracies in your personal data are rectified without delay
  • request that any incomplete personal data are completed, including by means of a supplementary statement
  • request that your personal data are erased if there is no longer a justification for them to be processed
  • in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted
  • object to the processing of your personal data where it is processed for direct marketing purposes
  • object to the processing of your personal data
  • request a copy of any personal data you have provided, and for this to be provided in a structured, commonly used and machine-readable format

3. International transfers

As your personal data is stored on our IT infrastructure, and shared with our data processors, it may be transferred and stored securely outside the European Union. Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses.

4. Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

5. Contact details

The data controller for your personal data is the Cabinet Office. The contact details for the data controller are:

Cabinet Office
70 Whitehall
London
SW1A 2AS

Telephone: 0207 276 1234

Email: publiccorrespondence@cabinetoffice.gov.uk

The contact details for the data controller’s Data Protection Officer are:

Stephen Jones
Data Protection Officer
Cabinet Office
70 Whitehall
London
SW1A 2AS

Email: dpo@cabinetoffice.gov.uk

The Data Protection Officer provides independent advice and monitoring of Cabinet Office’s use of personal information.