Data Protection and Freedom of Information
Your recording will be information held by the University for the purpose of the UK GDPR / Data Protection Act 2018 and the Freedom of Information Act 2000.
This means that, as part of a formal request, you could be required to share the recording for public release or provide it to attendees or any individuals who are discussed during the recording.
Legal basis for processing personal data
The University retains records of its official meetings in written minutes. The legal basis for any personal data in these records is where it is necessary for performance of a task in the public interest, in the case the governance of the University as set out in our founding Charter.
There may be contractual or legal obligations to retain the records of meetings, usually in written form.
Recording of meetings are usually an additional way of creating a record of a meeting and may not be necessary to meet those legal grounds. The University therefore would need to rely on ‘legitimate’ interests, balanced against the rights of individuals. This requires a range of steps to achieve that balance. It may be that the best way is simply not to make a recording and setting “record” as a default setting is not acceptable.
Letting people know
You should tell your attendees about the recording when:
- you invite them to attend (include it in the calendar invite or on the agenda),
- they arrive at the meeting (this could be a verbal announcement from the chair),
- any latecomers arrive
This should include your plans for
- provision for objecting to recording
- sharing or disseminating the recording
- storing the recording
- how long you will keep it for
If recording is new to your meeting, it is important to remind people regularly. You can make fewer reminders if recording is adopted as regular practice for a meeting, such as a committee, and comes to be accepted and expected by attendees. You can include the fact that your meeting is recorded in your terms of reference.
If an attendee objects
There may be a number of reasons why an attendee could object to recording. If recording is essential, you may wish to give them the option to use the chat and turn their camera off.
Storing the data
Where you store your recording will depend on what it is being used for, and who needs to access it.
Think about whether you want those you share with to have their own copy to take away, or to have access to watch or listen to the recording somewhere you have stored it.
If the content of your meeting is restricted under the University’s Information Classification Guidelines (.pdf) you will need to take extra care when storing and sharing.
Do not forget that restricted items are not just those that involve personal data. It could be any information that would cause upset and distress to people or have a financial, strategic, or reputational impact to the University if it were shared inappropriately.
For further information please contact the Data Protection Officer at: firstname.lastname@example.org