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)
