Privacy Statement and Notice
Armed Forces Veterans Privacy Notice
This notice provides advice for customers about how the Council will use the personal information provided by them and their rights. The full policy can be found on the Council’s website.
The information is provided to comply with the General Data Protection Regulation 2016 (GDPR). This is a Europe-wide law that replaces the Data Protection Act 1998 in the UK.
This information leaflet gives general information about your rights and our obligations. It refers particularly to how we will process the information you have agreed to provide as part of our survey of armed forces personnel who live in North Warwickshire.
Data Protection Rights
North Warwickshire Borough Council is fully committed to compliance with the requirements of the Data Protection Act 1998 (“the Act”) and the changes arising from the General Data Protection Regulation (GDPR) and in the Data Protection Act 2018.
With regard to the information you provide the Council is the data controller.
All of our employees, Councillors and others working on our behalf, who have access to or process any personal information held by us, or on our behalf, are made aware of their duties and responsibilities under the Act and the new requirements specified in the GDPR and the Data Protection Act 2018.
The GDPR applies to personal data, which means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
It is the Council’s stated intention to ensure that information provided by its customers is:
- Processed fairly, lawfully and in a transparent manner in relation to the data subject
- Collected for specified, explicit and legitimate purposes and not further processed for other purposes incompatible with those purposes
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- Accurate and, where necessary kept up to date
- Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Processed in a way that ensures appropriate security of the personal data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
Our employees are aware that all personal information must be handled and dealt with properly no matter how it is collected, recorded and used and whether it is held on paper, in computer records or recorded by any other means. There are safeguards in the Act which ensure this.
We will, therefore, make certain that we treat all personal information that we hold in a lawful and correct manner and in accordance with the Act. We will also comply with the Data Protection Principles set out in the Act.
The information that we hold and use is provided with consent. In some circumstances we will not be able to provide the service or support you are requesting unless we have certain information however we understand that the consent you give will not be valid unless:
- there is a genuine choice;
- it has been explicitly and freely given and is an informed choice
- the consent was given through a statement made by you or by a clear affirmative action undertaken by you
- the Council can demonstrate that you have been fully informed about the data processing to which they have consented and is able to prove that it has obtained valid consent lawfully;
- a mechanism is provided for you to withdraw your consent and you are able to do this easily
How we obtain your personal data
Personal data will only be collected, created or otherwise obtained for specific, explicit and legitimate purposes.
We are asking you to provide personal data to allow us improve the services we are delivering locally for armed forces veterans.
The information we obtain is subject to it being for legitimate purposes and, in some circumstances, to your consent. It includes your name, address, contact details (telephone number and/ or e-mail address), your service identification number and the service area in which you were employed (Example: Army, Navy, Air Force)
How we use your personal data
We are going to use the personal data we receive to help us understand where ex-service personnel are living so that we can adapt and improve our services locally.
With your consent, if you require support services to assist you, we will share specific personal information with the relevant agency as part of an agreed referral.
The Council will ensure that it does not retain personal data for any longer than is necessary for the purposes for which they were collected and will apply appropriate measures at the end of data’s useful life such as erasure or anonymising.
We will retain the information that you have provided whilst we are working to improve our services for forces personnel. We will keep records for 12 months from receipt.
We will keep the information you have provided confidential.
We will only share the information you have provided with your consent and to enable us to map where service personnel live so that we can design our services accordingly.
There may be times when we need to share personal information with third parties for the purposes set out in this notice or where we are legally required to do so. Examples are when we have to assist with fraud protection or to protect the vital interests of an individual.
The Council recognises the legal rights of those whose data it is processing or intends to process and will ensure that appropriate information is provided to them advising them of their rights, and that policies and procedures are maintained to ensure that the organisation is able to recognise information rights requests and handle them appropriately when they are exercised. These rights include:
- Right to information about data processing operations
- Right of access to personal data
- Right to portability of personal data (which is the right to have personal data transmitted to another data controller)
- Right of rectification of personal data (if it is inaccurate)
- Right of erasure of personal data
- Right to restriction of processing
- Right to object to direct marketing
- Right to object to data processing operations under some circumstances
- Right not to be subject to decisions made by automated processing under some circumstances
- Right of complaint about the organisation’s processing of personal data and the right to a judicial remedy and compensation
Protection of Data
The Council will maintain a Data Breach Reporting Procedure and will ensure that all employees and those with access to personal data are aware of it.
All employees and individuals with access to personal data for which the organisation is either data controller or processor are expected to report all personal data breaches to an appropriate individual as set out in the Data Breach Reporting Procedure as soon as they become aware of the breach.
The Council will log all personal data breaches and will investigate each incident without delay. Appropriate remedial action will be taken as soon as possible to isolate and contain the breach, evaluate and minimise its impact, and to recover from the effects of the breach. Data protection near misses will also be recorded and investigated in the same manner as data protection breaches. The breach reporting procedure will set out responsibilities, decision-making criteria and timescales for notifying data subjects, the Information Commissioner and the media about a personal data breach.
The Council’s Data Protection policy can be found on our website at www.northwarks.gov.uk
If you would like information about what we hold about you personally, you can do so using the contact details below:
Telephone: 01827 719238 for further information
Fax: 01827 719225
For independent advice about data protection, please contact the Information Commissioner at:
Telephone: 01625 545745
Fax: 01625 524510
Last updated Wednesday, 9th January 2019