The IWGB and UCL UCU have written jointly to Sodexo and UCL in protest at their plans to introduce biometric testing for cleaners at UCL – full letter below!

We are writing in response to the announcement by Sodexo that the company plans to introduce a Time Management System using biometric technology for cleaners employed on the UCL contract.

Both we and the affected workers (many of whom are members of the IWGB union) believe that this proposal is ill-considered, discriminatory and likely to be in breach of the Biometrics Institute’s2017 Biometric Privacy Guidelines, as well as the UK’s 2018 General Data Protection Regulation (GDPR) with regard to the principle of proportionality.

These workers are already the most heavily scrutinised in the University. They have passes in order to clock in and out, as well as a signing in book, and their supervisors control their entry to and exit from work. The introduction of additional monitoring systems is out of step with contemporary practice in relation to cleaning jobs in buildings of this type, and therefore excessive.

We are therefore calling on Sodexo and UCL to halt the implementation process immediately, and to provide answers to the following questions:

1)      Why is this system being introduced for cleaners, but not for any other group of staff working at UCL?

2)      Why is it being introduced at UCL and not at other comparable institutions (indeed, plans for a similar system at Birkbeck were recently abandoned)?

3)      Given the disproportionate number of BAME staff working on the cleaning contract, has an Equality Impact Assessment been conducted to ensure that these plans are not in breach of the Equalities Act 2010?

4)      Can Sodexo please provide references to their own policies to show that they have addressed the following guidelines as laid out in the 2017 Biometric Privacy Guidelines?

i)        Principle 1 Respect for Individuals/Data Subject Privacy

ii)       Principle 2 Proportionality

iii)     Principle 3 Informed Consent

iv)     Principle 4 Truth and Accuracy in Business Operations

v)      Principle 5 Protection of Biometric Data Collected

vi)     Principle 6 Complaints and Enquiries

vii)   Principle 7 Purpose

viii)  Principle 8 Non Discrimination

ix)     Principle 9 Accountability

x)      Principle 10 Sharing of Biometric Data

xi)     Principle 11 Provision of Advance Warnings of Surveillance

xii)   Principle 12 Transmission of Biometric Data Beyond National Boundaries

xiii)  Principle 13 Employee Biometric Data Must be Protected

xiv) Principle 14 Limit the Extent of Personal Data Exchanged and Retained

xv)   Principle 15 Maintain a Strong Privacy Environment

xvi) Principle 16 Maintain Privacy Logs

5)      If the Biometrics Institute Privacy Guidelines have not been incorporated into the policy, could  Sodexo please send a copy of the relevant Privacy Impact Assessment that has been carried out in relation to the proposed implementation?

The IWGB and UCU are extremely concerned both at these plans and at the way they are being implemented with little consultation or consideration for the privacy rights of our colleagues. If this is not halted then we will be passing the matter to our respective legal departments and considering a representation to the Information Commissioner., especially in relation to any areas of GDPR-related non-compliance.

A failure on the part of Sodexo to address our concerns within 10 working days will leave us no option but to alert all UCL staff and students to this inconsiderate and disproportionate approach to the privacy rights of the most vulnerable and low-paid of our colleagues on campus.

Yours sincerely

Maritza Castillo Calle (President UoL IWGB)
Danny Millum (Branch Secretary UoL IWGB)
Sean Wallis (President UCL UCU)
Saladin Meckled-Garcia (Vice President UCL UCU)
Tony Brown (Branch Secretary UCL UCU)

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