The National Centre for Atmospheric Science (NCAS) is a distributed centre and does not directly employ its staff. Human Resources (HR) departments at each NCAS site collect and monitor data for their staff, but for understandable reasons (including data protection) the data is not shared with NCAS and this is likely to remain the situation in the future.
The NCAS Equality, Diversity and Inclusion Committee (NEDI) and NCAS Management Board have recognised the need to collect staff data, on a voluntary basis, so that the NCAS staff profile can be assessed and monitored in terms of the nine protected characteristics defined in the Equality Act 2010: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation.
A number of additional characteristics have also been identified that are not formally part of the Equality Act, but are nevertheless pertinent. The list is not exhaustive and may need adding to depending on NCAS’ Equality Diversity and Inclusion (EDI) policies. The collection, storage and analysis of this personal data is covered by the General Data Protection Regulations (GDPR), to maintain an individual’s rights to confidentiality.
This EDI data policy sets out the procedures agreed by the NCAS Management Board for all aspects of EDI data collection, storage and analysis.
- All provision of staff data relating to protected characteristics is voluntary; no member of staff will be required to provide the data, and they will not be treated differently if they choose not to provide it.
- Data will be collected through a questionnaire on a secure web-interface via the NCAS website.
- All data requested through the questionnaire must be approved by the NCAS Management Board.
- Entries will be stored in a secure database on a server controlled by NCAS.
- Any material changes to the questionnaire or storage must be approved by the NCAS Management Board, and sufficient notice be given to staff members (at least two weeks) so that if they wish, staff may delete their entries before any further analysis of the data is performed.
- All data entries will be pseudonymised; pseudonymisation takes the most easily identifying fields within a database and replaces them with artificial identifiers, or pseudonyms. For example a name is replaced with a unique number).
- Entries may only be amended by the staff member in question.
- Staff members may log in and update their personal entries at any time.
- Staff members may remove their personal data at any time; and every data item will have a ‘prefer not to say’ option that can replace previous entries.
- Entries will be deleted when a staff member leaves NCAS.
- In addition to the collection of data relating to protected characteristics, the NCAS People team will be adding and analysing additional information on the NCAS People Database such as pay grades, promotions, access to learning and development, skills, and publications. This information will be accessible by all staff members.
- Staff entries relating to protected characteristics will be viewable only by the Head of EDI and the IT staff member responsible for maintaining and developing the database.
- Access to the database by the identified responsible IT staff is permitted solely for the purposes of maintaining and/or updating the database.
- Access to the database by the People team is permitted solely for the purposes of maintaining/updating the database.
- IT staff are forbidden to grant access to, or provide information from, the database to any person either within or outside of NCAS without the written agreement of the NCAS Management Board.
- Pre-specified analysis options will be developed and agreed in advance by the NCAS Management Board, with agreed safeguards to prevent identification-discovery e.g. for protected characteristics where there are likely to be categories with only a few staff entries, data analysis will only be reported across the whole of the NCAS staff.
- The analysis will be performed by one (or more if necessary) agreed member of NCAS staff from the IT/People teams.
- All analysis will be performed on pseudonymised data.
- Analysis that drills deeper e.g. to the level of NCAS science themes or sites will not be reported publicly if the population of the result falls below a level that allows the possibility of identification-discovery.
- Where appropriate, results for small sized categories will be reported as an aggregate, to avoid the possibility of identification-discovery.
- In-built analysis tools will prevent any selection of groups that involve 10 or fewer staff, to avoid identification.