SCS Declaration of Paid Outside Employment Privacy Notice
Published 9 October 2024
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 UK General Data Protection Regulation (UK GDPR).
Your data
Purpose
The purposes for which we are processing your personal data are:
- to collect information about staff outside interests to ensure that these are managed and any potential or perceived conflicts of interest are identified and addressed
- to publish details of all paid or remunerated secondary employment for Senior Civil Servants (SCS) to meet government transparency objectives.
This will involve publishing details of all SCS who hold outside employment which is paid or otherwise remunerated (and has been approved in line with the requirements of 4.3.4 of the Civil Service Management Code) in the Annual Report and Accounts (ARA).
The data
We will process the following personal data:
- Your name (first name and surname);
- Your role in the department (job title & grade); and
- details of the outside employment.
We will publish the minimum information about your secondary employment required to provide transparency. This might include for example the job title of your secondary employment and the name of your employer. Where the publication of details may disclose intrusive personal data, we will provide the general type of employment rather than full details.
Legal basis of processing
The legal basis for collecting your personal data is that it is necessary for the performance of a contract to which you are a party. In this case that is your conditions of employment and our need to identify and manage conflicts of interest.
The legal basis for publishing your personal data is that 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. In this case the processing is necessary to meet government transparency commitments.
Recipients
The data that we will publish (as outlined above) will be shared by us with the public via publication in the Annual Report and Accounts (ARA).
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.
Retention
Your personal data will be kept by us for 3 years, in line with the Conflict of Interest Policy.
Data that is published will be reviewed annually and those details which are no longer relevant will be removed. Please be aware that once personal data is published on the internet we will no longer have full control over it. While we will remove out of date information on platforms we control, it may continue to be held on the internet outside our control.
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.
You have the right to request that any inaccuracies in your personal data are rectified without delay.
You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement.
You have the right to request that your personal data are erased if there is no longer a justification for them to be processed.
You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.
In relation to the publication of your personal data for government transparency purposes:
You have the right to object to the processing of your personal data.
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 UK. Where that is the case it will be subject to equivalent legal protection through an adequacy decision, a UK International Data Transfer Agreement, or reliance on Standard Contractual Clauses.
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
or 0303 123 1113, or icocasework@ico.org.uk.
Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.
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
or 0207 276 1234, or publiccorrespondence@cabinetoffice.gov.uk.
The contact details for the data controller’s Data Protection Officer are: dpo@cabinetoffice.gov.uk.
The Data Protection Officer provides independent advice and monitoring of Cabinet Office’s use of personal information.