Employee Privacy Notice

This Privacy Notice applies to our collection, use, and retention (“processing”) of personal data, including any information transferred outside of the EEA or Switzerland, which identifies, or can be used by us or on our behalf to identify, an individual.

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.
• 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.
• Assessing your eligibility for employment and/or continued employment.
• Provide library, IT, media, and other information services.
• Provide support of our core services, 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 Well-Being Service, etc.).
  • Monitoring of equal opportunities.
  • Safeguarding and promotion of employees’ welfare.
  • Ensuring your safety and security.
  • Managing your accommodations.
  • Managing the use of social media.
  • Managing facilities on campus, including parking.
• Administer finances (i.e., payroll, W-2s, health and other insurance information, etc.).
• Provide other administrative functions, including for:
  • 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, information 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).
  • Preventing and detecting crime.
  • Dealing with grievances and disciplinary actions.
  • Dealing with complaints and inquiries.
  • 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, commemorative clothing providers, photographers, caterers, etc.).
  • Preparing the commencement booklet.
  • Promoting and archiving the ceremony on our website.

We may process your personal data because it 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. 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 the 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 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 promote equality and diversity throughout 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 for compliance with our legal obligations. In this respect, we may use your personal data for the following:

• To meet our compliance and regulatory obligations.
• For the prevention and detection of crime.
• In order to assist with investigations (including criminal investigations) carried out by the police and other responsible authorities.

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 above, we may share your personal data with certain third parties. In some cases you will be asked to opt in to these data sharing arrangements. In those cases, you should carefully consider the possible impact that not opting in 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.

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 work place accommodation.
• Third parties who work with us to provide work related benefits, including medical insurance and pension providers.
• Third parties who work with us to provide support services such as IT, security, and staffing.
• Third parties who are contracted to provide out-of-hours IT services for us.
• Internal and external auditors.
• Those with an interest in tracking employee progress and attendance, including:
  • Current or potential education providers.
  • Future employers (to provide references and to provide details of attendance).
  • Professional and regulatory bodies in relation to the confirmation of qualifications, professional registration and conduct, and the accreditation of courses.
  • Governmental departments and agencies where we have a legal obligation to provide information.
  • Crime prevention or detection agencies.
• Next-of-kin and emergency contacts (where there is a legitimate reason for disclosure).
• Third parties conducting surveys.

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 or for one of our suppliers, or where personal data is processed by one of our suppliers who is based outside the EU, the EEA, Switzerland, or who uses storage facilities outside the EU, the EEA, or Switzerland.

In these circumstances, your personal data will only be transferred on one of the following bases:

• Where you have provided explicit consent for the transfer.
• 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.
• 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.

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 the “How Webster Uses Current, Prospective and former Employee Information” 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 will 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.

Under the EU General Data Protection Regulation (GDPR) and other national (sovereign) data protection regulations you may have the following rights:

• To request access to the personal data that we hold about you.
• To object on grounds relating to your particular situation to our processing activities where you feel they have a disproportionate impact on your interests, rights, and freedoms.
• If you believe that the personal data we possess is, or has become, incorrect or is incomplete, you may request to review, revise, correct, or update any of the personal data we may have 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 have your personal data erased.
• 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 require us not to send you marketing communication.

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 given your consent and you wish to withdraw it, please contact your campus Privacy Manager or the Office of Privacy by phone or email using the contact details provided at the end of this document. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.

If you have any questions about your rights regarding your Personal Data, please simply email or write to us at the postal address provided in our Contact Information below where you may initiate a request to exercise any of the rights described above.

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
Österreichisch Datenschutzbehördede
Wickenburggasse 8
1080 Vienna
Austria / Europe

The Netherlands
Autoritei Persoonsgegevensns
Postbus 93374
250AJAJ DEHAAGAG

Switzerland
Office of the Federal Data Protection and Information Commissioner
Feldeggweg 1
CH - 300Bernene

Greece
Data Protection Authority Offices
Kifissias 1-3,
115 23 Athens,
Greece

Webster takes reasonable and appropriate 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 revisions.

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.

Webster University Global IT GRC Department — 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

 

Webster University Global IT GRC Department — Global GCR and Privacy Operations Manager
Ellie Despotaki
Ipitou Str. No 9, Athens 105 57, Greece
Tel. +30 211 990 5302
despotakie@webster.edu / privacy@webster.edu

Webster Vienna Private University — Privacy Manager
Allison Snowden
Palais Wenkheim Praterstr. 23, 1020 Vienna, Austria
Tel. +43 1 269 9293 4324
allison.snowden@webster.ac.at

Webster Geneva Campus — Privacy Manager
Mr. Michel Pollak
15, Route de Collex, 1293 Bellevue, Switzerland
Tel. +41 22 959 80 03
michelpollak74@webster.edu

Webster University Leiden — Privacy Manager
Chris (Mac) McDonnell
Boommarkt 1, 2311 EA Leiden, The Netherlands
Tel. +31 71 516 8000 x4526
mcdonnell16@webster.edu

Webster University Athens — Privacy Manager
9 Ipitou St., Athens 105 57, Greece
Tel. +30 211 990 5302
privacy@webster.edu

Webster University Georgia — Privacy Manager
Gaga Gvenetadze
82 I. Chavchavadze Avenue, Tbilisi 0612, Georgia
Tel. +995 598 389 037
gagagvenetadze@webster.edu

Webster University Tashkent — Privacy Manager
Shakhnoza Kholmatova
13 Alisher Navoiy Str., Tashkent 100011, Uzbekistan
Tel. +998 55 503 0066
shakhnozakholmatova@webster.edu