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Privacy Notice – Equality, Diversity and Inclusion – Disability and Age Team
This Privacy Notice explains how Ulster University (University) collects, uses and processes participants’ personal data as a data controller and explains participants’ rights in relation to the personal data that the University processes when an employee discloses a disability or long term health condition and requires reasonable adjustments.
The University actively seeks to preserve the privacy rights of those individuals that share information with the University. The personal data which you provide to the University will be processed in accordance with UK data protection legislation, specifically UK GDPR and the Data Protection Act 2018.
What is the purpose and legal basis of the processing?
The Disability and Age EDI Team is committed to fostering an accessible, inclusive workplace where everyone can thrive. We work to remove barriers, promote equitable participation, and champion the diverse experiences of disabled individuals and people across all age groups. Through policy development, training, awareness initiatives, and collaboration across the organisation, we help embed inclusive practice into everyday culture. Our team also provides confidential support with employee disability disclosure and offers guidance on accessing reasonable adjustments so everyone can fully participate in the workplace.
The following lawful basis that applies to this processing:
- UK GDPR Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subject - Disability Discrimination Act 1995 and The Health and Safety at Work (Northern Ireland) Order 1978.
For processing special category data, our legal basis for processing is:
- UK GDPR Article 9.2(b) – Employment, social security and social protection law
- UK GDPR Article 9.2(g) – reasons of substantial public interest (with a basis in law).
- Data Protection Act 2018, Schedule 1, Part 1, Paragraph 1 – Employment, social security and social protection.
- Data Protection Act 2018, Schedule 1, Part 2, Paragraph 16 – Support for individuals with a particular disability or medical condition.
How the University collects your personal data
The EDI Disability and Age shall collect the personal data from you in response to an email, online form or telephone request for support from you. All your information is stored securely in accordance with Ulster University Data Protection Policy.
To provide the best support, we may need to share information with other departments to facilitate workplace adjustments or flexible arrangements, address wellbeing or conduct concerns in line with university policy and/or ensure your safety or the safety of others.
Sharing will be proportionate and, on a need-to-know basis, and we will aim to discuss this with you beforehand.
Change of Purpose
The University will only use your personal data for the purposes for which it collected in, unless the University reasonable considers that it needs to use the personal data for another reason and that reason is compatible with the original purpose. If the University needs to use your personal data for an unrelated purpose it shall notify you and explain the legal basis for which allows the University to do so.
How long does the University hold your personal data?
Personal data collected as part of work on employee Reasonable Adjustments will be retained for a period of three years after end of employment.
The University’s Retention and Disposal Schedule includes guidance on retention and disposal periods. A copy of the Schedule is available at Ulster University Retention and disposal schedule
Categories of personal data processed by the University
Personal Data
The University may collect, use, store and transfer the following types of personal data as part of this processing:
- Name
- Job role and location
Special Category Data
“Special Categories” or particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation require higher levels of protection. The following categories of special category data will be processed:
- Health
Who does the University share your data with
The University shares personal data with third parties where necessary for the purposes of the processing and where there is a legal basis to do so. Where information is shared with such third parties, the University will seek to share the minimum amount necessary.
Your personal data will not be shared with third parties as part of this processing.
Personal data and special category data may be shared internally within Ulster University where necessary, appropriate, and lawful, specifically to support disability disclosure, wellbeing, health & safety, or workplace adjustments.
Routine external sharing is not part of this process, except in limited circumstances (e.g., equipment suppliers, Estates contractors, or external support schemes) where needed and lawful.
Internal Sharing -Information may be shared internally only when required to support the employee or fulfil legal/operational duties:
- Line Managers – implement adjustments, understand barriers.
- People & Culture (People Partners) – coordinate adjustments, manage wellbeing, conduct, or contractual matters.
- EDI – Disability & Age – collect disability data, lead adjustment processes.
- Occupational Health – relevant medical or needs‑based information.
- Health, Safety & Wellbeing / Occupational Health – risk assessment, safety decisions, support needs or risk concerns.
- Estates Services – adjustments relating to workspace, accessibility, parking, equipment.
- IT Services – specialist IT equipment or access changes.
All internal sharing is limited, necessary, and confidential.
International Transfers
The University may transfer your personal data to the following countries outside of the United Kingdom:
- European Economic Area
In these circumstances your personal data is being transferred on the basis that the Secretary of State has made an adequacy regulation in respect of said countries. This means that countries are deemed to provide equivalent protection to personal data as provided by the UK data protection regime.
Your rights as a Data Subject
As a University data subject you have the right to:
- Access and obtain a copy of your personal data on request;
- Require the University to change incorrect or incomplete personal data;
- Require the University to delete or remove your personal data, for example where the data is no longer necessary for the purposes of processing. Note, however that the University may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Object to the processing of your personal data where the University is relying on its legitimate interests as a legal ground for processing;
- Where the University is relying upon consent to process your personal data, you may withdraw your consent at any time; and ask the University to stop processing personal data for a period if the personal data is inaccurate or there is a dispute about whether or not your interests override the University’s legitimate grounds for processing the personal data.
Further information and your right to complain
Read further information in respect of the University’s practice in respect of data protection and our Data Protection Policy.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request the University transfer a copy of your personal information to another party, please contact the University’s Data Protection Officer,
Eoin Coyle at:
c/o Ulster University, Room L132
Coleraine
BT52 1SA
02871 675525
If you are not satisfied with how the University is processing your personal data, you can make a complaint to the ICO. Further information about your data privacy rights are available on the ICO’s website.
