The University of Westminster takes its data protection obligations very seriously. Access to any personal information in recordings made in our Microsoft Office 365 (MSO365) Teams environment are subject to a staff confidentiality agreement. Access to your personal information recorded is limited by permissions controlled by meeting organisers and channel owners to only those who need access to any recording for agreed business purposes or where otherwise allowed by law.
Personal data recorded in our MSO365 Teams environment relates either to directly consenting participants in recorded meetings or to data where the University has an established legal basis for processing or explicit consent has been recorded for the business processing.
The categories of personal information held in relation to business meeting recordings are for the most part personal data relating to participant identity, possibly including contact information, and their personal contributions to required business processes. Where this may relate to special category personal data, please see below.
Use of personal data
The University may record meetings in its MSO365 Teams environment for the following purposes:
- To establish participant identities and further contact details if required
- To have a record and potential transcript of meeting organisers' and participants' personal meeting contributions where agreed
- To record business and academic research, for example focus groups and research interviews, where agreed and where ethical approval has been given
- To record formal University Committee meetings where agreed
- To record academic and business meetings where requested by the meeting organiser to support ongoing dissemination and to create records of discussions, decisions and progress, where agreed
- To support participant accessibility where agreed
- To support specific situations that require a recorded session, for example where mandated for academic accreditation
There are specific situations where the University would not find it acceptable to use Teams recordings, even where they may be included in the general purposes above. Recordings should not be made for formal meetings, for example grievance and disciplinary meetings. Where MS Teams is being used for educational purposes, users should also familiarise themselves with the Policy on Audio or Video Recording for Educational Purposes:
Legal basis for processing and data retention
The legal basis for processing will be related to the topic and data required in any agreed or requested meeting recorded, the most likely being, although not limited to: explicit consent by participants, processing necessary for the performance of a contract to which the data subject is a party, or processing relating to a task carried out in the public interest.
As a general guide, recording files of meetings in Teams should only be kept for up to a year from the date of the meeting and then deleted. Any related transcripts could be kept for up to two years after a meeting date. This may be extended for a longer period depending on the purpose of the transcript, eg to support a research project for which consent for use of MS Teams and/or recordings is in place, and research ethics approval has been received where appropriate.
For more advice contact: [email protected].
For further advice on Teams retention contact: [email protected].
Special category personal data*
In most circumstances the University will not be using recorded meetings to gather or discuss special category personal data. However, where a meeting is organised that covers such topics, this information will only be gathered and used with either the explicit consent of data subjects as participants or the data subject’s previously recorded explicit consent for processing.
Any sensitive personal information we hold in such a way will only be shared where it is essential for the delivery of any agreed service or process.
To withdraw explicit consent for the University to hold and share your sensitive personal data relating to any University processing, including in recorded meetings, please contact the process owner, meeting organiser or make a request to [email protected].
* Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
Data transfers and sharing
None of your personal information is shared by the University with any other third- party organisation, other than where this is necessary for the provision of a service you have agreed to, or where otherwise allowed by UK law.
University MSO365 Teams recordings involve third party processing of your information, and as such are covered by a contract, and details of these services and the MS Teams privacy and security are available at the Microsoft Trust Centre.
If you have any questions relating to your personal information and your information rights, including right of access, rectification and erasure, please see the University’s data protection web pages.
Or contact the University Information Compliance Team [email protected].
You can also contact the Information Commissioners’ Office in relation to any concerns or issue you may have with the processing of your personal information.
Last reviewed and updated August 2020