What service is being provided?
The Blue Badge scheme is designed to allow people, over two years of age, with severe walking difficulties, to access goods and services by parking close to places they wish to visit. The Blue Badge can be used by the badge holder in any vehicle in which they travel as a driver (where applicable) or a passenger.
London Borough of Hammersmith & Fulham’s Accessible Transport Service administers the Blue Badge scheme on behalf of eligible borough residents. Valtech Limited administer the database for the production and dispatch of the Blue Badge.
Under data protection legislation, we must ensure that we have an adequate reason or legal grounds to support the use of your personal information. The legal grounds we use to determine that the processing of personal information is necessary, is to enable us to fulfil a ‘legal obligation’ to which the controller is subject. We also rely on the following legal grounds:
- Under the Chronically Sick and Disabled Act 1970, the London Borough of Hammersmith & Fulham has a statutory obligation to maintain a register showing the holders of badges issued by the authority. We are responsible for determining and implementing administrative, assessment and enforcement procedures in accordance with the governing legislation (Disabled Persons (Badges for Motor Vehicles) (England) Regulations 2000 as amended.
- The processing of sensitive data is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
- the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject for this purpose, the Council is registered with the Information Commissioner’s Office for the purposes of processing personal data.
The information you provide
The personal information we hold is provided by you when you register to become a Blue Badge holder and through your continued use of the Blue Badge scheme. The information you provide will be held and used in accordance with the requirements of UK and European data protection law for a period of 6 years, when it will be securely destroyed.
When you contact Hammersmith & Fulham by telephone we will record the call for quality and training purposes. Telephone recordings are kept for a period of 6 months, at which point they are then deleted.
When you make an appointment to visit our service Hammersmith & Fulham will keep the appointment details for a period of 6 months, at which point they are then deleted.
What data do we collect?
The following information is collected as part of the Blue Badge application and assessment process:
- Name (including surname at birth (or adoption)
- Permanent address (including previous address if you have moved within the last 12 months)
- Contact details
- Town and country of birth
- Date of birth and age
- Gender
- National Insurance Number (optional)
- Driver or passenger
- Vehicle registration number (if applicable)
- Previous Blue Badge details (if applicable)
- Proof of identity (e.g. driving licence, passport)
- Proof of address (e.g. council tax bill, utility bill)
- Details of any person with legal responsibility for you.
- Any other personal information that you may supply in your supporting documentation.
We collect the following special category data
- Photograph
- Details about your disability, health or long-term condition, pain medication and assessment of your walking ability.
- Evidence to support your eligibility for a Blue Badge (e.g. Certificate of Visual Impairment, evidence of entitlement to benefits or allowances you receive relating to your mobility)
- Payment details may be taken if you pay by card or cheque.
Information is collected by submission of a completed application form and supporting evidence which is used to assess and review your identity and eligibility for the Blue Badge, and through your continued use of the Blue Badge scheme.
Following assessment of your application for a Blue Badge, you may be asked to attend a mobility assessment where further information may also be gathered. We will ask you to agree to attend a mobility assessment. You are not required to do so but it may affect the outcome of your application if you do not attend.
Further details about the Blue Badge scheme
Who will be using your personal data?
To enable us to provide services to you, it may be necessary for us to obtain relevant information and to share your personal information with others. The law requires us to provide Blue Badge services to you. This is detailed in legislation and guidance including the Chronically Sick and Disabled Persons Act 1970
Hammersmith & Fulham will collect your information, or it will be collected by your use of the self-service online application option through the GOV.UK website, and uploaded onto the Manage Blue Badges system (MBB). MBB is a national database owned by the Department for Transport (DfT) and managed by Valtech Limited on behalf of the DfT.
Who else might we share your data with?
- Hammersmith & Fulham’s parking services team – this includes routine sharing of information on lost and stolen badges.
- Hammersmith & Fulham’s Blue Badge Fraud Investigation team.
- Other local authorities who administer or enforce the Blue Badge service if you use the Blue Badge in their area
- If you move address to another local authority, your Blue Badge Registration record may be transferred if requested by the new local authority
- Your name, address, date of birth, contact information and Blue Badge details will be shared where we are legally required to do so e.g. the Police for the prevention and detection of crime.
- With the Cabinet Office for data matching processes in respect of The National Fraud Initiative.
IT Software Providers - IT Software providers such as Conduent Parking Enforcement Solutions Ltd who are contracted by Hammersmith & Fulham to host and manage our data.
Prevention and Detection of Fraud - Hammersmith & Fulham may share and compare your information with other council services and other organisations to make sure the information is accurate, to protect public funds, recover debt and/or prevent or detect fraud. These other organisations include government departments, other local authorities, the police, and private sector organisations such as banks or organisations that lend money.
Legal Requirements - Hammersmith & Fulham will use all information held by us for the purposes of law enforcement, regulation and licensing, criminal prosecutions, and court proceedings.
Corporate Business Intelligence – Hammersmith & Fulham may share the information you give us (only as relevant) with other council services for research and analysis purposes, to help us design and improve the services we provide, and to identify and contact residents who may benefit from them.
Developing and testing business applications – Hammersmith & Fulham may use the information you give us (only as relevant) to maintain and improve the services which we deliver, this includes developing and upgrading the systems which we use to process your information.
Statistical purposes – Hammersmith & Fulham (only as relevant) may use your information for statistical purposes in order monitor and manage the Blue Badge scheme.
Authorised representatives – Hammersmith & Fulham may share your information (only as relevant) with representatives who are legally responsible for you or with representatives such as, but not limited to, Members of Parliament or councillors who you have authorised to make enquiries on your behalf.
What is your personal information used for?
The information you provide will be used for the following purposes:
- To assess and review your eligibility for the Blue Badge scheme in accordance with governing legislation.
- To facilitate mobility assessments for applicants who do not meet the automatic eligibility criteria.
- To facilitate and process any credit/debit card payment.
- To allow commissioned providers of the service to produce and dispatch Blue Badges on completion of a successful application.
- For the purposes of Blue Badge parking enforcement including the detection and prevention of Blue Badge misuse / fraud.
- For the administration of the Blue Badge scheme.
- To provide limited information to support your application for a borough Resident Visitor Parking Permit.
The Data Controller is London Borough of Hammersmith and Fulham
The Data Protection Officer for London Borough of Hammersmith and Fulham can be contacted at dpo@lbhf.gov.uk
The Data Processors supporting this purpose are the IT Software provider who hosts and manages our data and the service provider who produces the Blue Badge.
How do I know the information about me is kept safely?
All the information we collect is stored securely on our IT systems and manual filing systems. We have strict procedures for the way this is done. Any and all information about you is treated as confidential and with respect. There are also clear rules and guidance about storing, recording, and sharing information which staff receive training on.
We take information sharing very seriously. Any member of staff who is found to be breaking the rules will be dealt with through appropriate disciplinary procedures.
The information we hold will not be stored in or accessible from countries with non- UK-equivalent Privacy Law protections
Marketing
Hammersmith & Fulham do not process your personal information for marketing purposes
Profiling and automated-decision making
Hammersmith & Fulham do not process your personal information using profiling or automated decision-making processes.
Our use of your data will be subject to the following legal rights
- Your right to be Informed
- Your right to access your personal data
- Your right for us to rectify your personal data
You have the right of access to the personal data we process about you, and in this instance, the right for us to rectify your personal data. How to make a request
As we have a statutory basis for collecting your personal data, we do not need to ask for your permission to share it; however, we will only ever share your data on a basis of need, in line with legislation and will work transparently with you at all times.
If you do not provide your data, we will not be able to process your Blue Badge application and you will not be able to use the service.
Visit the following links for more information about privacy law, our obligations, and your rights
- The ICO Guide to the General Data Protection Regulation 2016
- The General Data Protection Regulation 2016
If you have concerns
If you have concerns over the way we are asking for or using your personal data, please raise the matter with our H&F In Touch Team by the following means:
H&F In Touch Team, London Borough of Hammersmith and Fulham Hammersmith, London W6 9JU
020 8748 2456
If you still have concerns following our response you have the right to raise the matter with the Information Commissioner's Office.