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The council is committed to protecting and respecting your privacy. Through this privacy notice we have sought to be as transparent as possible to fully explain how your personal information is held and processed. This notice explains how we collect, use and share your information and how we keep it and how we keep it secure.
This privacy notice also explains when and why we collect personal information about people who engage or come into contact with us, whether via applying or receiving our services, living or visiting the borough or our website. In addition to this privacy notice some services have their own dedicated privacy notice to tell people in more detail how they use your information and the legal basis for using the information.
We collect information about you when you register with us, contact us or use our services.
The information we collect may include your:
We may also record and monitor telephone calls to our Contact Centre for quality and training purposes and also collect information when you voluntarily complete customer surveys and provide feedback.
From May 2018, genetic data and biometric data will be treated as sensitive personal data.
We need your personal data in order to provide you with council services that you apply for or receive from us and also where we are required to use information in order to meet our statutory obligations. We will only collect personal data that is absolutely necessary and any information we collect about you will be strictly in accordance with the data protection law and other statutory obligations which we are bound by.
In general we will use your information to:
To do so we may share your information between services and with other organisations, including:
The council has statutory obligations to collect, process and share personal information without consent, with our partners such as the NHS, housing associations, schools, central government, such as DWP, HMRC, Home Office, Dept. Of Education, Dept. of Health, other councils and law enforcement agencies such as the Police and the Crown prosecution service, for the following purposes:
To ensure that the council provides you with an efficient and effective service we will sometimes need to share your information between teams within the council. We may also share your information with our partners to deliver national government programmes and initiatives such as the Troubled Families programme, or improving services we deliver, or provide the services you agreed to receive.
In most cases this will be done where there is a lawful basis under the conditions set out in data protection laws. We may also share your information with third party service providers working on our behalf for the purposes of completing tasks and providing services to you on our behalf (for example; domiciliary care providers). However, when we use third party service providers, we disclose only personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure, as required by the Data Protection Act 1998 and General Data Protection Regulation 2016 (GDPR), and not to use it for any other purposes.
We will never use or share your personal information to third parties for marketing purposes without your permission.
We are required by law to participate in National Fraud Initiative (NFI) data matching exercises. Council Tax information may be provided to the Audit Commission for NFI purposes and will be used for cross-system and cross-authority comparison for fraud prevention and detection.
We will also share our data with companies who undertake data matching exercises for Single Person Discount, this is to identify discrepancies. We share our data through LOCTA - the Local Authority Council Tax data sharing hub, who locate debtors who no longer reside in the council. For some debts, we also use external bailiff collection. We use an external provider to process our online claims and to identify changes in circumstances.
The council must have a lawful basis for processing your information. In most cases the information will be collected and used where we have statutory obligations to collect, use or share your information; in those instances we have a public interest basis for processing your information. In some instances the services we provide are optional, which means that the council will only provide the service if the customer has requested the service or the customer consents to the service. In that instance, consenting to the service does not necessarily mean that the lawful basis for processing your information is consent; the council may rely on the public interest basis where it has specific powers to provide the service.
Where your consent is required to process your information we will seek your consent. However, where your consent is not required to process your information, for example the council has a lawful basis for processing your information, your consent will not be sought. Where we need to disclose sensitive or confidential information such as medical details to other partners, we will do so only with your prior explicit consent unless we are legally entitled to share the data.
The council may also process your information where processing is necessary for the performance of a contract and where processing is necessary to protect your vital interest or the vital interest of another person. The council may also process your information where we are obliged to process your information to comply with the law.
We have statutory authority to collect and process your personal information for the provision of our service, your consent therefore is not required to process your information. Where the service is optional, we will not process your information until you have consented to receive the service. Once we have your consent for the service, your information will be processed under our statutory authority to provide the service.
We review our retention periods of the information we hold about you on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as it is necessary for the relevant activity or service that we provide to you, or as required by law.
We will retain your information for the period in which your information is being used for service provision or for our wider functions including debt collection. We have legal authority to process your information; your right to be forgotten does not apply to our functions and services
For the purpose of training and security calls to and from our contact centres are recorded.
Data Protection Officer,
Digital and IT,
London Borough of Sutton
Civic Offices, St. Nicholas Way,
Sutton SM1 1EA.
If you would like to know more about your rights under the Data Protection law, and what you should expect from us, visit the ICOs website.