Prevent personal data processing privacy notice
If you are offered support through the H&F and RBKC Channel Panel, the Prevent team operating in the London Borough of Hammersmith and Fulham and the Royal Borough of Kensington and Chelsea will collect and process personal information about you. Under the General Data Protection Regulation which applies across the European Union, we have certain responsibilities as a controller and processor of your personal data, and you have certain rights as a data subject. This notice is to inform you of your rights and our responsibilities.
What personal information about you we collect and process:
- Date of birth
- Phone numbers and email addresses
- Police information
- Criminal History
- Council tax and benefit information (if relevant)
- Medical information (if relevant)
- Religious beliefs (if relevant)
- Political beliefs (if relevant)
- Information about engagement with social care or charity services (if relevant)
- Details of family members and associates (if relevant)
Why we collect personal information about you and how will this data be used
The H&F/RBKC Prevent team needs to collect some personal information in order to provide tailored support to those individuals identified as being potentially vulnerable to radicalisation.
How information about you will be used
Your data will be used to discuss the given circumstances and concerns with relevant services and make recommendations for support.
Your personal information is only used for a specified purpose but if we intend to use it for any other new purposes we will normally ask you first. For instance, in some cases, the council may wish to use your information for another purpose such as related to improving and developing services, or to prevent or detect fraud. In any event our processing will always have a demonstrable lawful basis. Where practicable and reasonable we will always seek to inform you of any significant proposed changes to how we process or intend to process your personal data, in order to ensure full transparency over how we handle your information.
How we collect personal information about you
We collect information about you through information sharing with other services. We might also collect information from you directly, such as contact details, for example, phone numbers and email addresses.
Why we can collect personal information about you
The H&F and RBKC Prevent team collects and processes your personal data on the legal basis that ‘the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’ (Article 6(1)(e) of the General Data Protection Regulation 2018).
The official authority refers to legislation. For the H&F and RBKC Prevent team, the authorising legislation is The Counter-Terrorism and Security Act 2015. It is for the purpose of carrying out our duties as defined by this legislation that we need to process your personal information.
We may also collect and process personal data which falls into the ‘special category’ of data (medical information, religious beliefs and political beliefs). To do this, we need an additional lawful basis under Article 9 of the GDPR. The lawful basis on which we collect this data is that ‘the processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject’ (Article 9(g) of the General Data Protection Regulation 2018).
The General Data Protection Regulation and the Data Protection Act 2018 affords you rights which you can access free of charge.
You have the right to:
- Know how we are using your information and why.
- Request a copy of the information we hold about you.
- Ask us to correct mistakes in the information we hold about you.
- Object to your data being used for direct marketing
- Make a complaint to the Information Commissioners Office if you think we are handling your information inappropriately
Under certain circumstances you may also be entitled to:
- Ask us to delete information we hold about you.
- Have your information transferred electronically to yourself or to another organisation.
- Object to decisions made on the basis of that data which significantly affect you.
- Object to how we are using your information.
- Restrict how we use your information.
We will endeavour to comply with your request, however do note that there are some exceptions to the above rights. In some cases, we may need to keep hold of your information to comply with other legal duties. Note that any request for us to restrict or cease processing of your data may affect service delivery to you.
Who will your data be shared with
Your data will only be shared with relevant professionals as part of the Channel process. These can include: the police, the NHS, Children’s Services, Adult Social Services, relevant local schools and other educational institutions, relevant charities and commissioned services. The information will be shared securely and only when it is necessary to do so.
We will share personal information with law enforcement or other authorities if required to do so by applicable law.
Your data will not be shared outside of the United Kingdom.
How your data will be stored and for how long
Your data will be stored in electronic form on a secure local authority computer database for six years in accordance with the London Borough of Hammersmith and Fulham and the Royal Borough of Kensington and Chelsea’s corporate retention policy. After this period the information will be reviewed and only kept if there is an ongoing requirement to do so.
We have appropriate security measures in place to prevent your personal information from being lost, used or accessed by other parties. We limit access to your information only to those who have a genuine business need to access it. Anyone processing your information is required to do so in a secure way and is bound by a duty of confidentiality.
Information relating to an individual referred to Channel is recorded on the Channel Case Management and Information System (CMIS) by the local Prevent police teams for the purpose of administering the programme. This information is kept separate from other police databases, and can only be accessed by individuals directly involved in the Channel programme. It is not consulted as part of a DBS or an Enhanced DBS check.
The data on CMIS is subject to the Code of Practice on the Management of Police Information (MOPI); records are held for a minimum of seven years from the date of the last data entry. After seven years police are required to assess whether it is necessary to retain the information. If it is necessary, the information may be held for a further year (unless there are specific circumstances in which it needs to be held for longer).
Who to contact to make a complaint or ask further questions about the way we use your personal data
If you have any further questions about what information we hold about you and how we use it, you may contact the Hammersmith and Fulham In Touch team at email@example.com or the Prevent team at firstname.lastname@example.org
You may also contact the H&F Data Protection Officer at DPO@lbhf.gov.uk
If you are unhappy with how your data is being processed, you can lodge a complaint with the Hammersmith and Fulham In Touch team at email@example.com
If you wish to exercise your rights under the General Data Protection Regulation, you may contact the Hammersmith and Fulham In Touch team at firstname.lastname@example.org or the Prevent team at email@example.com
If you are not satisfied with Hammersmith and Fulham’s response, you have a right to complain to the Information Commissioner’s Office or by calling the helpline at 0303 123 1113.
Find out more about your rights under the General Data Protection Regulation on the Information Commissioner’s website.
Changes in your circumstances
You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.