Right to Removal

The key question for this archive is whether the item has ‘enduring value’: that is, is it important that it becomes part of this archive. This is particularly important with historic items as they may shed light on a subject about which little is known.

For the archive to develop we need to better understand users, therefore personal search history and personal characteristics are retained. As the University is the archive holder, it retains a special right in GDPR to retain information for its public purpose as a centre to advance public understanding. We may therefore retain information and assets about Users and Contributors who have publicly deleted their accounts.

In certain circumstances the public have a right for their information to be removed from the archive, even if they are not the owner. This is in accordance with the Data Protection Act 2018 and is covered by our User Privacy Notice. It may be that a person visible in an asset may have legitimate reasons for needing the asset to be removed. This might be, for example, that the person is banned from social media by a court order, or that a person is in an abusive relationship and does not want their location to be online. These are reasons that means the asset may be removed but were reasons that could not have been anticipated in the first instance. We will deal with any matter on a case by case basis as quickly as possible and seek advice from Coventry University’s Information Governance Unit, via Ben Kyneswood.

However, the right to be forgotten is not an absolute one and there may be occasions where we are unable to comply with a request to exercise the right to be forgotten. The public must have good reason for the asset to be removed, which on balance outweighs the interest in us keeping it (i.e. processing necessary for archiving purpuses, which is in the public interest for the purposes of academic research).  The public who are concerned, or wish to exercise their right to be forgotten, pursuant to the Data Protection Act 2018 and as set out within the User Privacy Notice., should contact the University by contacting the Information Governance Unit at Coventry University, via email to DSAR@coventry.ac.uk or via post to Information Governance Unit, Legal Services, Portal House, 163 Union Street, Coventry, CV1 2PL.