EU General Data Protection Regulation and Right to Erasure Policy

Policy Number: 19.02
Category: Human Resources


Effective Date: 04/17/2018
Owner: Sr. VP for Administration and Finance
Policy Applicable for: Faculty, Staff, Employment Applicants
Responsible Office: Human Resources

Background

The purpose of this policy is to operationalize Human Resource’s response to a European Union (EU) data subject’s request to exercise their Right to Erasure under the EU’s General Data Protection Regulation (GDPR).

Under GDPR, a data controller may have an obligation to erase a data subject’s personal data. However, the obligation to erase is not applicable if the personal data is necessary in relation to the purposes for which it was collected or processed.

Additionally, the Right to Erasure is not applicable if processing of the data is necessary for establishment, exercise or defense of legal claims.

The retention of Human Resource records is necessary to maintain compliance with legal obligations. Therefore, a Human Resource record will not be destroyed prior to the date prescribed by the University’s General Records Retention Schedule.

Policy

UC applicant and employee records are maintained according to UC’s General Records Retention Schedule. The schedule is designed to maintain compliance with legal obligations. Applicant and employee data is not released from the University unless directed by the applicant or legally required.

Procedure

Talent Network

Those who join UC’s talent community may unsubscribe at any time and will no longer receive email notifications from UC. Once unsubscribed, any information supplied by you is removed from the notification system.

Employment Application

Data submitted by individuals as part of the application process is retained in accordance with the University General Records Retention Schedule for three years if not hired.

Employment Records

Employment records are retained in accordance with the University’s General Records Retention Schedule directing records be maintained during active employment plus an additional 6 years.

Phone Contact

Human Resources: 513-556-6381