General Employee Privacy Notice Information
This Privacy Notice describes how we collect and use your personal data prior to, during and after your employment with Webster. It applies to all prospective, current, and former employees of the University, including adjunct faculty, temporary staff (including students working for the University) contractors, and interns. It is important that you read this Privacy Notice, together with any other privacy notices we may provide for specific circumstances when we are collecting or processing information about you.
This Privacy Notice is effective from November 2024. We may update this Privacy Notice at any time.
This privacy notice contains important information regarding our privacy practices and the choices we offer you with regard to your rights and our obligations over the processing of your personal data and we encourage you to revisit this Notice from time to time to stay informed of changes.
If you have any questions regarding this Privacy Notice or any of our related privacy policies, please do not hesitate to contact your campus Privacy Manager or the GRC by phone or email using the contact details provided at the end of this document.
Information about how we use the personal data of students and alumni is covered in separate documents i.e., Webster Student Privacy Notice and Webster Alumni and Friends Privacy Notice. Other non-EU Webster international campuses may also have their own privacy notices reflecting national legislation.
At Webster, we may collect personal data from or about you in a number of ways, for example:
- From the information you voluntarily provide to us when you first express an interest in employment at Webster.
- When you voluntarily apply for employment at Webster and complete hiring/application forms through our hiring process and as you complete other hiring related processes and procedures.
- When you voluntarily communicate with us in person, by telephone, email, via other University-approved means of communication or via our website.
- As you interact with us during your time as an employee at Webster for the various purposes set out in this Privacy Notice.
- From third-party entities, such as your previous or current employer, business and personal references, educational references, criminal and credit background checking service providers, as well as other third-party individuals or entities that may provide information about you.
- Information collected through disciplinary and grievance procedures.
- Information collected through surveys and feedback mechanisms.
We may collect the following types of personal data about you:
- Your name and contact information, such as your address, email address, and telephone number, as well as your date of birth, national insurance number (or other tax identification/social security numbers), passport number, visa or national identity card details, country of domicile, and nationality.
- Information relating to your education and employment history, such as your previous or current school(s), previous or current high school(s) or equivalent, and other colleges or universities you have attended, and the places where you have worked, (i.e., Your CV, qualifications and references).
- Records related to your use of our facilities and services.
- Photographs from events and CCTV footage.
- Sensitive (Special category) personal data, including:
- Information about criminal convictions and offences.
- Information about your health and medical conditions (e.g., disability accommodation and dietary needs).
- Information about your racial or national origin, religious or similar beliefs or sexual orientation.
We may use personal data (including including special category personal data) we collect from and about where this is necessary for the administration of your employment or for managing our employees, including to:
- Recruit and/or hire you as an employee at Webster.
- Maintain employment records.
- Assess your eligibility for employment and/or continued employment.
- Provide library, and other information services.
- Manage IT Infrastructure, access to operational systems, software, IT devices, telephony and communications technology used for work purposes, including the provision of IT security organizational and technical security measures and the deployment of monitoring tools to protect the University and your personal data.
- Provide support of our core employment administration and management of employees’
activities, including:
- Providing employee support services located at Webster University Human Resources webpages (e.g., retirement benefits, tuition remission, etc.).
- Providing ancillary health and other services (i.e., disability support, health and safety and physical security, etc.).
- Monitoring of equal opportunities, diversity, discrimination and inclusion.
- Safeguarding and promotion of employees’ welfare.
- Managing accommodation (special needs).
- Managing the use of social media.
- Managing facilities on campus, including parking.
- Administration of finances (i.e., payroll, taxes, expenses, budgeting, W-2s, health and other insurance information, etc.)
- Administration of employment, including HR services, such as recruitment, new employee onboarding, employee vetting, employment contracts, benefits and rewards, performance management (appraisals), absence, disciplinary and grievance procedures, employee termination, retirement and pensions, education and training and funded training reimbursement.
- Provide other administrative functions, including for:
- Management of business travel.
- Monitoring of acceptable use of the University’s communications and IT systems.
- Incident management and investigations, compliance and the prevention and detection of crime.
- Carrying out research and statistical analysis.
- Carrying out audits (i.e., to ensure compliance with our regulatory and legal obligations).
- Providing operational information (i.e., providing IT support and internal communications about building closures or access restrictions on campus, or safety advice).
- Promoting our services (e.g., providing information about events happening on and off campus).
- Dealing with complaints and enquiries.
- Dealing with legal proceedings and/or litigation in which the University may be involved.
- Archiving and statistical purposes.
- Hold the annual commencement ceremony including for:
- Passing such information to third parties to facilitate the ceremony (e.g., local newspapers, graduation caps and gowns providers, photographers, caterers, etc.).
- Preparing and publishing and/or printing the commencement program.
- Promoting and archiving the ceremony on Webster’s websites and social media.
For the purposes referred to in this Privacy Notice and relying on the lawful bases for processing as set out below, we may share your personal data with third parties. In some cases, such as employee surveys or use of identifiable voice, video or image recordings and similar initiatives such as training videos, testimonials and social media content designed to promote the University, you may be asked to opt into (provide consent) for these data sharing arrangements. In these cases, you should carefully consider the possible impact that opting in or opting out will have.
Where Webster shares your personal data with third-party organizations or entities that help us to run our services, those third parties are subject to stringent evaluation and contractual obligations to ensure your rights to privacy and security are protected.
We are not responsible for the privacy practices of third parties with whom we do not partner, nor can we endorse or take any responsibility for all the privacy practices or policies of our relationship partners. You are advised to check the privacy practices and policies of each third party with whom you independently choose to share your personal data.
Third-party recipients may include:
- Our affiliates and contractors where there is a legitimate reason for their receiving
the information, including third parties who work with us to:
- Provide workplace accommodation.
- Provide work-related benefits, including medical insurance and pension providers.
- Supply and operate IT infrastructure, technical security services, communications technology, data services and operating software on our behalf.
- Deliver out-of-hours IT support services for us.
- Provide internal and external auditors and consultants.
- Provide current or potential education providers.
- Provide references and to provide details of attendance for future employees.
- Provide confirmation of qualifications, professional registration and conduct, and the accreditation of courses (such as professional and regulatory bodies).
- Provide information including for financial reporting, taxation, right to work, visa and immigration, crime prevention and detection where we have a legal obligation (i.e., governmental departments and agencies).
- Provide next-of-kin and emergency contacts (where there is a legitimate reason for disclosure).
- Conduct surveys.
We do not sell or rent your personal data or share it for any other purposes unless required to do so by law.
We may process your personal data because it is necessary for the execution of a contract of employment with you, or to take steps at your request prior to entering into a contract. In this respect, we may use your personal data to:
- Interact with you before you are employed at Webster University, as part of the hiring process (e.g., to send you information or answer your inquiries about vacant positions).
- Provide you with the services as set out in any of our staff/faculty policies located at Webster University Human Resources webpages once you are employed at Webster University.
- Address any concerns or feedback you may have.
- Facilitate any other contractual purpose for which you provide us with your personal data.
We may rely upon a legal obligation to process employee personal data where required to do so by a legal or regulatory requirement, including:
- Employment law.
- Anti-fraud/anti money laundering.
- Working time directives.
- To manage Webster’s legal obligations in relation to whistleblowing, please refer to the Whistleblowing Compliance Reporting Hotline webpage.
We also may process your personal data because it is necessary for our legitimate interests. In this respect, we may use your personal data for any of the following:
- To monitor and evaluate the performance and effectiveness of the University, including by training and monitoring staff performance.
- To maintain and improve the academic, corporate, financial, and human resource management of the University.
- To seek advice on our legal rights and obligations and to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, students or faculty or other employees, visitors to the University, or anyone else who could be harmed by such activities.
- To perform our duties in carrying out our mission, vision, and values, Webster University´s Strategic Plan and our policies and community expectations.
We also may process your personal data where:
- It is necessary for emergency medical purposes.
- It is necessary to protect your or another person’s vital interests.
- We have your specific or, where necessary, explicit consent to do so.
For the purposes referred to in this Privacy Notice and relying on the lawful bases for processing as set out below, we may share your personal data with third parties. In some cases, such as employee surveys or use of identifiable voice, video or image recordings and similar initiatives such as training videos, testimonials and social media content designed to promote the University, you may be asked to opt into (provide consent) for these data sharing arrangements. In these cases, you should carefully consider the possible impact that opting in or opting out will have.
Where Webster shares your personal data with third-party organizations or entities that help us to run our services, those third parties are subject to stringent evaluation and contractual obligations to ensure your rights to privacy and security are protected.
We are not responsible for the privacy practices of third parties with whom we do not partner, nor can we endorse or take any responsibility for all the privacy practices or policies of our relationship partners. You are advised to check the privacy practices and policies of each third party with whom you independently choose to share your personal data.
Third-party recipients may include:
- Our affiliates and contractors where there is a legitimate reason for their receiving
the information, including third parties who work with us to:
- Provide workplace accommodation.
- Provide work-related benefits, including medical insurance and pension providers.
- Supply and operate IT infrastructure, technical security services, communications technology, data services and operating software on our behalf.
- Deliver out-of-hours IT support services for us.
- Provide internal and external auditors and consultants.
- Provide current or potential education providers.
- Provide references and to provide details of attendance for future employees.
- Provide confirmation of qualifications, professional registration and conduct, and the accreditation of courses (such as professional and regulatory bodies).
- Provide information including for financial reporting, taxation, right to work, visa and immigration, crime prevention and detection where we have a legal obligation (i.e., governmental departments and agencies).
- Provide next-of-kin and emergency contacts (where there is a legitimate reason for disclosure).
- Conduct surveys.
We do not sell or rent your personal data or share it for any other purposes unless required to do so by law.
As a global University, some of the personal data we process about you will be transferred to, and stored at, a destination outside the European Union (EU), the European Economic Area (EEA), and Switzerland, or a country not considered to be adequate according to the GDPR and other privacy laws. This happens, for example, where it is processed by employees operating outside the EU, the EEA or Switzerland who work for us at another campus or for one of our third-party vendors, which may be based outside of, or uses data storage facilities outside of the EU, the EEA or Switzerland.
In these circumstances, your personal data will only be transferred on one of the following bases:
- Where the transfer is occasional and necessary in relation to a contract or a legal claim.
- Where the transfer is made on the basis of an adequacy decision.
- Where the transfer is subject to one or more appropriate safeguards for international transfers prescribed by applicable law such as Webster’s Group Data Transfer Agreement and other data sharing agreements that incorporate EU standard contractual clauses to protect your rights and your data.
- Where the transfer is necessary for the execution of a contract with you or in order to take steps at your request prior to entering into a contract.
- Where you have provided explicit consent for the transfer.
Please tell us promptly about any changes to the personal data you have voluntarily provided to us. This is particularly important with respect to your contact details.
We will retain your personal data for as long as needed to meet the uses described in compliance with legal document retention obligations. Even where you have exercised one of the rights listed below with respect to your personal data, we may have the right to retain your personal data for compliance with a legal obligation, for the performance of a task carried out in the public interest, for archiving purposes in the public interest, for scientific or historical research purposes, for statistical purposes, or for the establishment, exercise, or defense of legal claims.
Where the EU General Data Protection Regulation (GDPR) applies to the processing of your personal data, you have the following rights:
- To be informed about our processing of your personal data (this Notice).
- A general right to have your personal data processed securely.
- To obtain access to the personal data that we hold about you.
- To object to processing on grounds relating to your personal data where you feel processing by us has a disproportionate impact on your interests, rights, and freedoms.
- If you believe that your personal data is, or has become, incorrect or is incomplete, you may request to review, revise, correct, or update any of the personal data we may hold about you free of charge.
- To restrict the processing activities related to your personal data (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal).
- To request that we erase your personal data.
- To have personal data, which you have voluntarily provided to us, produced in a structured, commonly used, and machine-readable format, including for the purpose of transmitting it to another party.
- To lodge a formal complaint to your national EU Data Protection Supervisory Authority if you believe we have not fulfilled your rights and to seek judicial remedy for harm or distress arising from such a breach.
- To require us to obtain your consent to send you marketing communications and to withdraw your consent for such communications at any time without constraint
Please Note:
- That the individual rights described are not absolute, and we may be entitled to refuse requests where certain exceptions apply.
If you have any questions about your rights regarding your personal data or wish to exercise any of the rights granted to you, please let us know by contacting your campus Privacy Manager or GRC by phone or email using the contact details provided at the end of this document.
This Privacy Notice is not directed to children under the age of eighteen (18), and we do not intentionally seek, nor do we knowingly process, personal data from children or minors as defined by the Children’s Online Privacy Protection Act (COPPA) and equivalent legislation to protect children’s data in any jurisdiction in which we operate, without the consent of a parent or legal guardian.
Webster takes reasonable and appropriate organizational and technical security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal data.
Webster reserves the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of our policies and this Privacy Notice at any time, consistent with the requirements of applicable law. When we do, we will post the revision(s) on our website. If we change the Privacy Notice in a material way, we will provide appropriate notice to you. The ‘Effective Date’ at the top of this Privacy Notice reflects the date of the most recent revision.
Webster University is committed to answering your questions, resolving complaints about your privacy and our processing of your personal data. If you have an inquiry or complaint regarding this Privacy Notice, you should first contact privacy@webster.edu. In the event that a resolution cannot be reached, you may also contact your local data protection authority which may investigate your complaint further.
Austria
Österreichische Datenschutzbehörde
Wickenburggasse 8
1080 Vienna
Greece
Data Protection Authority Offices
Kifissias 1-3,
115 23 Athens
Switzerland
Office of the Federal Data Protection and Information Commissioner
Feldeggweg 1
CH - 3003 Berne
The Netherlands
Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ DEN HAAG
If you have questions about our University Privacy Statement, this Privacy Notice, our privacy practices or any other aspect of your privacy and the security of your Personal Information, please contact your Privacy Manager or our Office of Privacy by phone or email using the contact details provided below.
Director Global Technology, Risk, Compliance and Privacy
Edna Schick-Bodrič
Palais Wenkheim Praterstr. 23, 1020 Vienna, Austria
Tel. +43 12 699 293 4334
edna.schick-bodric@webster.ac.at/privacy@webster.edu
Global GCR and Privacy Operations Manager
Ellie Despotaki
9 Ipitou St., Athens 105 57, Greece
Tel. +30 211 990 5302
despotakie@webster.edu/privacy@webster.edu
Vasilis Botopoulos
9 Ipitou St., Athens 105 57, Greece
Tel. +30 211 990 5300
privacy@webster.edu
Christian Aduamoah
15, Route de Collex, 1293 Bellevue, Switzerland
Tel. +41 22 959 80 00
caduamoah18@webster.edu
Gaga Gvenetadze
82 I. Chavchavadze Avenue, Tbilisi 0612, Georgia
Tel. +995 598 389 037
gagagvenetadze@webster.edu
Chris (Mac) McDonnell
Boommarkt 1, 2311 EA Leiden, The Netherlands
Tel. +31 71 516 8000 x4526
mcdonnell16@webster.edu
Shakhnoza Kholmatova
13 Alisher Navoiy Str., Tashkent 100011, Uzbekistan
Tel. +998 55 503 0066
shakhnozakholmatova@webster.edu
Isabella Weber
Palais Wenkheim Praterstr. 23, 1020 Vienna, Austria
Tel. +43 1 269 9293 4333
isabella.weber@webster.ac.at