Support for those planning to change or who have changed their legal gender
Uppsala University has no technical or administrative barriers to changing personal data regarding gender transition.
The following information clarifies the process for those who need to change their personal data as a result of gender transition.
Starting points
An individual registered at Uppsala University who has changed their legal gender has the right to request an update of their registered personal data. The University will promptly replace previous personal data, ensuring that the individual can be identified and identify themselves using their new personal data.
An active or former registered individual at Uppsala University who has changed their legal gender has the right to request updates of the personal data on diploma supplements, employment contracts, work certificates, or other official documents issued by the University that pertains to them.
An "active registered individual" refers to an employee, student, doctoral student, or intern at Uppsala University. A "former registered individual" refers to someone who has previously been employed, a student, a doctoral student, or an intern at the University.
The basis for the University’s handling of personal data in connection with a gender transition is that the applicant must submit a valid population registration certificate issued to the applicant by the Swedish Tax Agency.
Information regarding gender transition is confidential and must be protected. This protection applies to documents that confirm the gender transition as well as documents containing previous personal data.
Public records must be registered and preserved. Only non-public records may be deleted.
Uppsala University updates personal data on diploma supplements, employment contracts, or other official documents issued by Uppsala University. This does not apply to documents issued by Gotland University College prior to its merger or by other higher education institutions.
Referral
The information below applies to employees and interns at Uppsala University. Corresponding information regarding students will be published on the Student Gateway.
Anyone who needs information about procedures for handling personal data in connection with gender transition can contact or be referred to the local HR staff (VHR) at their department/division/equivalent.
Anyone who needs to change their personal data in connection with a gender transition can contact or be referred to local HR staff (VHR) at their department/division/equivalent.
Anyone who needs to update an existing or previous employment contract/employment certificate or other decision documents issued by the University in connection with gender transition can contact or be referred to the HR Division.
Changing Personal Data
Personal data about employees registered in the University's payroll and personnel administration system, PRIMULA, is edited by the HR Division.
Personal data in the University's catalogue and authorisation system, AKKA, is edited by the catalogue administrator at the relevant department/division/equivalent, except for user identities. They are changed by the University IT Services if necessary.
Personal data in the University's general management information system, GLIS, is edited by the Planning Division.
If a new user identity is needed, the administrator at the relevant department/division/equivalent contacts Service Desk and requests a meeting with the administrator at the University IT Services. No personal data or documents about the gender transition should be attached in the message to the Service Desk, only that the matter concerns a gender transition.
Updating Access Card
After changing the personal data in PRIMULA and AKKA the University access card will work as usual. However, the information on the card will not automatically be updated. Anyone who needs to update the information on their card (personal identification number and name) can contact or be referred to the administration at their campus.
Updating Employment contract/Certificate/Decision
Updating personal data in existing or previous employment contracts, employment certificates or other decisions issued by the University is done by the HR Division. The processing needs to be done in a case in W3D3 diary.
Important to note
The University's processing and archiving of a case must be traceable and be able to be verified afterwards according to the law. There is no legal ground for backdating an updated employment contract/employment certificate/decision document that has previously been issued by the University. Nor is it possible to specify any decision-maker other than the one who decides on the new employment contract/certificate/decision document. The updated employment contract/employment certificate/decision must state that this changes and replaces the previously issued employment contract/employment certificate/decision document. It is also important to state when the previous contract/certificate/equivalent was issued, otherwise, it will be difficult to know which employment contract/certificate or other decision that is replaced by the new one. Given this, there is no need to return the previous contract/certificate/equivalent, whether it is in paper or digital.
The new employment contract/certificate/decision does not state why the information has been changed. This is important to consider, given that information about a gender transition may not be disclosed, while official decisions are not subject to confidentiality.
Archiving and confidentiality
In cases where an individual has changed their legal gender, the University must consider the individual's integrity and right to privacy and comply with applicable regulations for handling public documents.
Confidentiality applies to information relating to an individual's health or sexual life. For example, information about gender transition and if it can be assumed that the individual or someone close to them will suffer significant harm if the information is disclosed (Public Access to Information and Secrecy Act, Chapter 21, Section 1).
Please note that confidentiality does not apply to information in official decisions. For this reason, it may not be stated that the reason for issuing a new diploma, certificate or other decision document is due to a gender transition.
Provisions on archiving can be found in the Archives Act, the Swedish National Archives regulations on the thinning of documents regarding payroll and personnel administrative activities, and in the Public Access of Information and Secrecy Act.
As far as public documents are concerned, there is no legal basis for the deletion/erasure of documents with the previous personal identity number, which means that public records relating to the previous gender identity need to be preserved even if this goes against the wishes of the individual who has changed their legal gender.
Labelling public documents as confidential in the diary system W3D3 and IT systems
Public documents can be found in the University's diary system W3D3 and in several other IT systems. In order to comply with Chapter 21, Section 1 of the Public Access of Information and Secrecy Act and to take into account the individual's right to live in their new identity as much as possible, existing public documents in W3D3 and other IT systems need to be reviewed and labeled as confidential. A link or reference to the diary number/case in the W3D3 diary where the personal identity number change has been processed also needs to be made. This is to secure that the confidentiality label is clear if a request for a public document is made.
Note that a confidentiality labell is only a notice that confidentiality may exist. An assessment needs to be made for each individual disclosure of the documents. If necessary, the Office of the Registrar in the Legal Affairs Division can help with advice if documents are requested.
Confidentiality label of public documents in analogue archive records
Staff files on paper are archived in the Central Archive. These files are sorted by the personal identity number.
If the individual's old documents, such as employment certificates or diplomas, are in paper form in the register, the new documents are added to the same file. A handwritten note is made on the old documents stating that they have been made void.
On the file, the new personal identity number is noted below the old one. It is also noted that the file may be confidential in accordance with Chapter 21, Section 1 of the Public Access to Information and Secrecy Act, and a reference to the diary number in the W3D3 diary where the change of personal identity number is processed.
Public documents that are kept organised in other forms
According to Chapter 5, Section 1 of the Public Access to Information and Secrecy Act, documents that are not confidential do not need to be registered, provided they are organised in a way that makes it easy to determine whether they have been received or created. However, documents considered confidential must be registered.
documents that are not confidential do not need to be registered, provided they are organised in a way that makes it easy to determine whether they have been received or created. However, confidential documents must be registered.
A review needs to be carried out of what documents are on individual web pages, shared workspaces, in folders and binders, etc.
The University has a procedure for requesting register extracts that has functionality for searching for personal data and can therefore be used to help search for where the person's data exists. The Legal Affairs Division or the Data Protection Officer can be contacted if necessary.
As regards documents with the former personal identity number that are public (and ‘kept organised in other ways" than registration in the W3D3 diary or other IT systems), need to be registered as they are subject to confidentiality.
In this case, a collective case can be created in the W3D3 diary where these documents are placed, and the case/documents are labelled confidential. Thereafter, a link or reference is made to the diary number/case in the W3D3 diary where the personal identity number change was processed. This is to ensure that the confidentiality labelling is comprehensible if a request for a public document becomes relevant.
Non-public documents
For non-public documents, all documents with the old personal identity number should be deleted (digital documents) or discarded (paper documents). This is to minimise data and thus minimise the risk of the person's former identity being revealed to unauthorised persons.
The Legal Affairs Division and/or the Office of the Registrar can advise if there is any uncertainty as to which documents are public or should be deleted/discarded, etc.