Introduction
This Privacy Notice explains what Midlands Partnership University NHS Foundation Trust (hereinafter referred to as "the Trust") does with information in relation to our employees/ workforce who are engaged in one form or another under a formal contract, registration document, Memorandum of Understanding or framework agreement with the organisation, including substantive staff members, volunteers, bank workers, contractors, agency staff and students on placement etc. who hold a legitimate relationship with the Trust.
We are committed to safeguarding the privacy and security of information concerning our prospective, current and former employees/workers. The term "employees" and "workforce" for these purposes covers the different types of contracts held within the Trust, as detailed above and including Honorary Contract Holders and others who hold a legitimate relationship with the Trust.
Who we are
Midlands Partnership University NHS Foundation Trust (MPFT)
Our Trust is registered with the Information Commissioner's Office (ICO) to process personal and special categories of information under the Data Protection Act 2018, and our registration number is ZA523971.
Data Protection Officer
If you have any questions or concerns regarding how your data is being processed, please contact:
Data Protection Officer
Information Governance Team
Email: infogov@mpft.nhs.uk
Why we collect personal information about you
The Trust collects, stores and processes personal information about prospective, current and former staff to ensure compliance with legal or industry requirements.
What information do we collect about you?
In the main, personal information about you will be collected directly from you during your recruitment and employment or engagement lifecycle (e.g. where appropriate, through your application form, pre-employment checks, starter form for payroll processing, etc.).
Personal information may also be collected from healthcare professionals in certain circumstances, through national checks such as the Disclosure and Barring Service (DBS), professional bodies, etc.
In order to carry out our activities and obligations as an employer we handle personal and special category data, including:
Personal and Employment Information
- Contact details such as title, names, addresses, personal email, telephone numbers and emergency contact(s)
- Passport details
- Driving licence details
- Next of kin details
- Recruitment information and employment records
- Professional memberships
- References
- Proof of eligibility to work in the UK
- Security checks
- Training and revalidation information
- Bank details
- Pension details
- Employment tribunal applications
- Complaints
- Email communications
- Personal data recorded as a normal part of your work activity
Health and Equality Information
- Occupational health information
- Physical or mental health conditions
- Details of absences including sickness absence and statutory parental leave
- Information relating to health and safety
- Trade union membership
- Personal demographics including:
- Gender
- Race
- Ethnicity
- Sexual orientation
- Religion
Criminal Offence Information
- Offences (including alleged offences)
- Criminal proceedings
- Outcomes and sentences
Security Information
- CCTV footage
- ID badge information
- ANPR information
- Swipe card records
- Body Worn Camera recordings
Incident and Investigation Information
- Accident records
- Incident details
This personal information can be held in a variety of formats, including paper records, electronic systems and audio recordings (for example meetings and investigation interviews).
What is the purpose of processing data?
Your personal information is processed for the following purposes:
Workforce administration
- Staff administration and management (including payroll and performance)
- Complying with the employment contract
- Pensions administration
- Equal opportunities monitoring
- Workforce planning and analytics
- Education, training and development requirements
- Health administration and services
- Information and databank administration
- Business management and planning, including accounting and auditing
- Conducting performance reviews
- Managing performance and determining performance requirements
- Complying with health and safety obligations
- Your image for security purposes and ID badges
Additional processing activities
The personal information we collect about you may also be used:
- For the processing of HR Casework and investigations and our own internal processes
- To monitor your use of information and communication systems
- For crime prevention and prosecution of offenders
- For national fraud initiatives
- When dealing with legal disputes involving employees, workers or contractors, including accidents at work
As a Trust, we are required to keep and process information about you for employment purposes. The information we hold and process will be used for our management and administrative use only.
We will keep and use it to enable us to run the service and manage our relationship with you effectively, lawfully and appropriately.
The Trust will only process your personal information where we are able to do so by law under the Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR).
This processing may occur:
- During the onboarding process
- While you are working/engaged by us
- At the time your employment ends
- After you have left the Trust
This includes using information to enable us to:
- Comply with the employment contract, registration document, commercial contract, framework agreement or Memorandum of Understanding
- Comply with legal requirements
- Pursue the legitimate interests of the Trust
- Protect our legal position in the event of legal proceedings
- Fulfil employment rights and obligations
Personal Data and Special Category Data
Personal Data
"Personal Data" means any information that relates to an identified or identifiable individual.
Special Category Data
"Special Category Data" means more sensitive personal information requiring additional protection under data protection legislation, including:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Physical or mental health
- Sexual life
- Criminal offences or alleged offences
- Criminal proceedings and outcomes
- Genetic data
- Biometric data used to uniquely identify an individual
Where we process Special Category Data, we will ensure this is done only where:
- Processing is necessary for employment, social security and social protection obligations; or
- Processing is necessary for occupational medicine, assessment of working capacity, or provision of health or social care.
The Trust does not require explicit consent of employees to process their personal data where processing falls within the lawful bases outlined above.
Who do we share your information with?
We may disclose personal and sensitive information where:
- There is a legal obligation to share
- It is necessary for the performance of your employment contract
- You have consented to the sharing
Any disclosures of personal data are made on a case-by-case basis using the minimum personal data necessary and appropriate security controls.
Examples include:
- Professional bodies (e.g. NMC, GMC)
- Court orders
- NHS Counter Fraud requirements
- Police and law enforcement agencies
- NHS Business Services Authority
- HMRC
- Department for Work and Pensions
- Courts and Child Maintenance Service
- Local Authorities
- Other NHS Trusts
- Occupational Health systems
- Recruitment management systems
- Health Roster systems
- NHS National Staff Survey provider
- Salary sacrifice providers
Where possible, we will anonymise or pseudonymise information and only share the minimum necessary information.
We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.
Who and where do we obtain your information from?
Information may be obtained:
Directly from you
- Recruitment application forms
- Employment documentation
- Face-to-face discussions
- Telephone calls
- Emails
From other organisations
- Healthcare professionals
- Disclosure and Barring Service (DBS)
- Professional bodies
- Other organisations legally required to share information
Trust Systems
- Electronic Staff Record (ESR)
- Health Roster
- Trac Recruitment Management System
Conflicts of Interest Declaration
All staff who are required to, or have completed the declaration will have their conflicts of interest disclosed on the Trust website.
All data is processed in line with GDPR Article 6(1)(e):
"Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller."
What rights do I have in relation to my information?
You have the right to:
- Access your personal data
- Request correction of inaccurate information
- Request deletion where applicable
- Request restriction of processing
- Withdraw consent where consent has been relied upon
- Challenge automated decision-making
We have procedures in place to manage and report any personal data breaches where legally required.
How do I request my information?
You have a right to request access to information held about you.
Subject Access Requests are normally processed within one month, although this may be extended by a further two months where requests are complex.
Request Portal: https://mpft.ams-sar.com/
You will be required to provide proof of identity.
How long is my information kept for?
Information is retained in accordance with the NHS Records Management Code of Practice 2023.
The Trust has a duty to:
- Maintain records in accordance with retention schedules
- Keep records secure and confidential
- Provide information in accessible formats
Personal information will only be kept for as long as necessary and will then be securely destroyed.
Your duty to inform us of any changes
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during your working relationship with us.
More information
For further information, please contact:
Data Protection Officer
Email: infogov@mpft.nhs.uk
You also have the right to complain directly to the Information Commissioner's Office (ICO):
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice at any time. We will publish a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Last Reviewed: 26 October 2026