Privacy Notice - How we use your information
Our privacy notices explain what to expect when Brent Council collects your personal information. In this notice Brent Council, Brent Civic Centre, Engineers Way, Wembley HA9 0FJ is the data controller as defined by Data Protection legislation.
The Council’s Data Protection Officer:
Name: Rajesh Seedher
Phone: 020 8937 1402
Why we collect and use your personal data
Personal information is collected to enable the Council to provide a range of services to local people and businesses as required to fulfil our duties under UK legislation, statutory or contractual requirement or obligation. This includes:
- maintaining our own accounts and records
- supporting and managing our employees
- promoting the services we provide
- marketing our local tourism
- carrying out health and public awareness campaigns
- managing our property
- providing leisure and cultural services
- provision of education
- carrying out surveys
- administering the assessment and collection of taxes and other revenue including benefits and grants
- licensing and regulatory activities
- local fraud initiatives
- the provision of social services
- crime prevention and prosecution of offenders including the use of CCTV
- corporate administration and all activities we are required to carry out as a data controller and public authority
- undertaking research
- the provision of all commercial services including the administration and enforcement of parking regulations and restrictions
- the provision of all non-commercial activities including refuse collections from residential properties,
- internal financial support and corporate functions
- managing archived records for historical and research reasons
- data matching under local and national fraud initiatives
The council is required to maintain a record of its processing activities, covering areas such as processing purposes, data sharing and retention;. A copy can be obtained from our Data Protection Officer via firstname.lastname@example.org.
The lawful basis for using your information
We collect and use information under one or more of the following legal bases.
- Legal obligation – we need to process your information to comply with the law
- Public task – we need to process your information to provide you with council services
- Contract – we need to process your information as part of a contract such as contract of employment.
- Vital interest – we need to process you information to protect someone’s life in an emergency.
- Consent – we need your permission to use your information
Where we require consent to use your information we will make it clear when we ask for consent and explain how to go about withdrawing your consent.
The categories of personal data we collect:
The types of information we process include:
- personal details
- family details
- lifestyle and social circumstances
- goods and services
- financial details
- employment and education details
- housing needs
- visual images, personal appearance and behaviour
- licenses or permits held
- student and pupil records
- business activities
- case file information
We also process ‘special’ categories of information that may include:
- ethnic origin;
- trade union membership;
- biometrics (where used for ID purposes);
- sex life; or
- sexual orientation.
The GDPR rules for ‘special’ categories of information do not apply to information about criminal allegations, proceedings or convictions. Instead, there are separate safeguards for personal data relating to criminal convictions and offences.
We process personal information about:
- employees, persons contracted to provide a service
- complainants, enquirers or their representatives
- professional advisers and consultants
- children and parents
- students and pupils
- carers or representatives
- recipients of benefits
- offenders and suspected offenders
- licence and permit holders
- traders and others subject to inspection
- people captured by CCTV images
- representatives of other organisations
Who we share your information with:
Where necessary or required we share information with:
- customers, service users and employees
- representatives of customers, service users and employees
- legal representatives
- trade unions
- current past and prospective employers
- healthcare, social and welfare organisations
- educators and examining bodies
- providers of goods and services
- data processors
- local and central government
- ombudsman and regulatory bodies
- financial organisations
- debt collection and tracing agencies
- credit reference agencies
- press and the media
- law enforcement and prosecuting authorities
- international law enforcement agencies and bodies
- courts and tribunals
- housing associations, landlords and tenants panels
- charitable, religious and voluntary organisations
- political organisations
- elected members including members of parliament
- survey and research organisations
Once your information has been collected by the council, it may be used by other council departments, where necessary, to provide a complete service to you. It is for this reason that we link your information together, for example, to save you providing your information more than once.
Where in the world is your information stored?
Brent Council does not process your information with third countries outside of the UK or EU zone without the safeguards being in place that are equivalent to the UK Data Protection legislation or the General Data Protection Regulations (GDPR).
If you fail to provide the personal data, the Council may not be able to deliver accurate services to you and may also take action if it is required to do so by law.
How long do we keep your information?
There’s often a legal and/or business reason for keeping your information for a set period of time, we try to include all of these in our retention schedule. A copy can be obtained from our Data Protection Officer.
Brent Council shall process your information in adherence to your individual rights under the Data Protection legislation.
The right to be informed
This is your right know about how your data is being processed, who it is given to, for what purpose and anything else that guarantees your rights. This web page provides a summary, the Record of Processing Activities gives further details. When you provide information the Council will ensure that you have a Privacy Notice.
The right of access
You have a right to access your personal data and relevant supplementary information. This is known as a Subject Access Request. Further information can be found at www.ico.org.uk. You can make a request by emailing the Data Protection Officer at email@example.com, or in writing to the Data Protection Officer, Brent Council, Civic Centre, Engineers Way HA9 0FJ. You should receive a response within 30 days, unless a different period applies as described under the ICO’s SARs code of practice.
The right to rectification
You have the right to have your personal data rectified if it is inaccurate or incomplete. You can do this by contacting the service area that you are concerned about directly. Otherwise you can make a request by emailing the Data Protection Officer at firstname.lastname@example.org, or in writing to the Data Protection Officer, Brent Council, Civic Centre, Engineers Way HA9 0FJ
The right to erasure
This is also known as “the right to be forgotten”. Please note that there are circumstances when your information cannot be erased. This includes situations whereby the council is required to retain information for statutory purposes in accordance with its data retentions policy. You can make a request by emailing the Data Protection Officer at email@example.com, or in writing to the Data Protection Officer, Brent Council, Civic Centre, Engineers Way HA9 0FJ . You should receive a response with 30 days.
The right to restrict processing
You have a right to request the council to ‘block’ or supress processing of your personal data. Please note that this may not apply for most of the council’s processes because there is usually a legal duty to process information.
The right to data portability
You have the right to obtain and reuse your personal data for your own purposes. You can make a request by emailing the Data Protection Officer at firstname.lastname@example.org, or in writing to the Data Protection Officer, Brent Council, Civic Centre, Engineers Way HA9 0FJ.
The right to object to processing
You have the right to object to processing for certain circumstances as listed by the ICO at www.ico.org.uk. You can make a request by emailing the Data Protection Officer at email@example.com, or in writing to the Data Protection Officer, Brent Council, Civic Centre, Engineers Way HA9 0FJ
Rights related to automated decision making including profiling
There are restrictions on automated decisions based solely on automated means without any human involvement. Also there are restrictions on profiling. You can make a an enquiry by emailing the Data Protection Officer at firstname.lastname@example.org, or in writing to the Data Protection Officer, Brent Council, Civic Centre, Engineers Way HA9 0FJ
Brent Council is required by law to protect the public funds it administers. We may use any of the information you provide to us for the prevention and detection of crime. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Public Sector Audit Appointments Ltd, National Audit Office, Financial Reporting Council, Cabinet Office, the Department for Work and Pensions, and other local authorities, HM Revenue and Customs, and the Police.
In addition to undertaking our own data matching to identify errors and potential frauds we are required to take part in national data matching exercises undertaken by the National Fraud Initiative. The use of data by the National Fraud Initiative in a data matching exercise is carried out under its powers in Part 2A of the Audit Commission Act 1998. It does not require the consent of the individuals concerned.
Concerns about data protection
If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with the council’s Data Protection Officer in the first instance. Alternatively, you can contact the Information Commissioner’s Office.
You can raise your concern by emailing the Data Protection Officer at email@example.com, or in writing to the Data Protection Officer, Brent Council, Civic Centre, Engineers Way HA9 0FJ.
Code of Data Matching Practice
This authority is required by law to protect the public funds it administers. It may share information provided to it with other bodies responsible for auditing or administering public funds, in order to prevent and detect fraud.
The Audit Commission appoints the auditor to audit the accounts of this authority. It is also responsible for carrying out data matching exercises, although this authority may also participate in exercises carried out by other agencies.
Data matching involves comparing computer records held by one body against other computer records held by the same or another body. This is usually personal information. Computerised data matching allows potentially fraudulent claims and
payments to be identified. Where a match is found it indicates that there is an inconsistency which requires further investigation.
No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.
The Audit Commission currently requires us to participate in a data matching exercise to assist in the prevention and detection of fraud. We are required to provide particular sets of data to the Audit Commission for matching for each exercise, and these are set out in the Audit Commission's handbooks, which can be found at www.audit-commission.gov.uk/nfi
The use of data by the Audit Commission in a data matching exercise is carried out with statutory authority under its powers in Part 2A of the Audit Commission Act 1998. It does not require the consent of the individuals concerned under the Data Protection Act 1998.
Data matching by the Audit Commission is subject to a Code of Practice.