Last updated: 11 April 2019
We are updating this Privacy Notice and our service specific Privacy Notices to reflect changes we have made as part of our ongoing commitment to be transparent about how we use your data and keep it safe. We have included changes to address the new standards introduced by the European data protection law, known as the General Data Protection Regulation (GDPR), and the new Data Protection Act 2018. The Privacy Notices will also be updated in line with any new recommendations by the UK Regulator, the Information Commissioner.
Our privacy notices set out how we, Warwickshire County Council (WCC), collect, store and handle your personal information and what your information rights are. Your rights will vary with the service being used. We provide a wide range of public services, so one notice for all services may not give you enough detail. You can also find links to further notices for each service area. There may be a service specific privacy notice for you to find out how your information is used and your rights.
If you want to keep a paper or electronic copy of these notices, please go to the end and use the ‘Print this page’ button.
Personal information may be collected on a paper or online form, by telephone, email, CCTV or by a member of our staff, or one of our partners.
Who we are
Warwickshire County Council is registered with the Information Commissioner’s Office (ICO) as a ‘data controller’ under the Data Protection Act, entry Z4835730. We are a public authority and have a nominated Data Protection Officer. See our contact information below.
What personal information we obtain
Our registration entry under the Data Protection Act 1998 described in general terms the purposes, the categories of personal data and the categories of the recipients. These haven’t changed. This entry applies to council staff and members of the public. For further details see our service specific privacy notices links below or in the links in “You may also be interested in” on the right hand menu.
Why we collect information about you
We need to collect and hold information about you, in order to:
- deliver public services
- confirm your identity to provide some services
- contact you by post, email or telephone
- understand your needs to provide the services that you request
- understand what we can do for you and inform you of other relevant services and benefits
- obtain your opinion about our services
- update your customer record
- help us to build up a picture of how we are performing at delivering services to you and what services the people of Warwickshire need
- process financial transactions
- prevent and detect fraud and corruption in the use of public funds
- allow us to undertake statutory functions efficiently and effectively
- make sure we meet our statutory obligations including those related to diversity and equalities.
We may not be able to provide you with a product or service unless we have enough information, or your permission to use that information.
Lawful bases for processing the information we collect from you
We have to ensure that we have a lawful basis to collect your personal information which is one of the following:
- For compliance with a legal obligation as required by UK or EU law to process for a specific purpose
- For a public task in the public interest or an official function which has a clear basis in law
- For a contract for the supply of requested goods or services
- For consent, where there is documented evidence of that consent
- For legitimate Interests for security interests as a public authority
- For vital Interests to protect life
For service level details see service specific privacy notices.
How we use your information
We will use the information you provide in a manner that conforms to the Data Protection legislation. We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept.
In general, we process your information for the following purposes:
- for the service you requested, and to monitor and improve the council’s performance in responding to your request
- to allow us to be able to communicate and provide services and benefits appropriate to your needs
- to ensure that we meet our legal obligations
- where necessary for the law enforcement functions
- to prevent and detect fraud or crime
- to process financial transactions including grants, payments and benefits involving the council, or where we are acting on behalf of other government bodies, e.g. Department for Work and Pensions
- to collect monies owed to us
- where necessary to protect individuals from harm or injury
- to allow the statistical analysis of data so we can plan the provision of services.
We will not pass any personal data on to third parties, other than those who either process information on our behalf, or because of a legal requirement, and it will only do so, where possible, after we have ensured that sufficient steps have been taken to protect the personal data by the recipient. We do not sell your information to any organisation.
We will not disclose any information that you provide ‘in confidence’ to us, to anyone else without your permission, except in the few situations where disclosure is required by law, or where we have good reason to believe that failing to share the information would put someone else at risk. You will be told about this.
We may process your information overseas using web services that are hosted outside the European Economic Area, but only with data processing agreements that meet our obligations under the Data Protection Act.
We may need to pass your information to other people and organisations that provide the service. These providers are obliged to keep your details securely, and use them only to fulfil your request. If we wish to pass your sensitive or confidential information onto a third party, we will only do so once we have obtained your consent, unless we are legally required to do so.
We may disclose information to other partners where it is necessary, either to comply with a legal obligation, or where permitted under the Data Protection Act, e.g. where the disclosure is necessary for the purposes of the prevention and/or detection of crime.
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 or where we are legally required to.
We may disclose information when necessary to prevent risk of harm to an individual.
At no time will your information be passed to organisations external to us and our partners, for marketing or sales purposes or for any commercial use without your prior express consent.
We will provide further information of what information is shared with other organisations on data collection forms, service specific privacy notices and sharing agreements. These agreements can be found on our ‘sharing your information’ page and related links at: www.warwickshire.gov.uk/sharinginformation
Communication with the Council
Telephone calls and Live chat
We will inform you if we record or monitor any telephone calls you make to us. Calls made direct to, or from, our Customer Service Centre (01926 410410) are recorded and kept for 12 months from the date of the call. We do not record any financial card details if you then make payments by telephone. If the call is transferred to a member of staff outside the Customer Service Centre, the recording stops.Calls may be recorded if telephoning direct to other service teams on alternative numbers.
Live chat is an alternative to the telephone. You can print or receive an email of your chat record each time. Chat is transcribed and a record kept for 6 months from the date of the recording.
These records will be used, to increase your security, for our record keeping of the transaction and for our staff training purposes.
If you email us we may keep a record of your contact and your email address and the email for our record keeping of the transaction. For security reasons we will not include any confidential information about you in any email we send to you, unless you agree to this.
We suggest that you keep the amount of confidential information you send to us via email to a minimum and use email encryption, our secure online forms and services.
Where you receive emails directly from a service, you can withdraw consent and ask to be removed from the mailing list at any time by contacting the service.
Email alerts and newsletters sent from this service will come from an @public.govdelivery.com email address.
Using our website
If you are a user with general public access, the Warwickshire web site (www.warwickshire.gov.uk) does not store or capture personal information, but merely logs a number called your IP address which is automatically recognised by the system.
The system will record personal information if you:
- subscribe to or apply for services that require personal information,
- report a fault and give your contact details for us to respond,
- contact us and leave your details for us to respond.
This statement only covers the council websites maintained by us and does not cover other websites linked from our site.
My account – self-service
We use a range of different systems, requiring a different account username and password to sign in. We make sure these are kept secure in our systems but you are responsible for maintaining the confidentiality of your account and password and for restricting access to your computers and other applicable devices, and you agree to accept responsibility for all activities that occur under your account or password.
We have installed CCTV systems in some of our premises used by members of the public, for the purposes of public and staff safety and crime prevention and detection. CCTV is also installed on the outside of some of our buildings for the purposes of monitoring building security and crime prevention and detection.
They are installed in our recycling sites for the purposes of public and staff safety, crime prevention and detection, and the abuse of council policies. They are installed on highways for the purpose of monitoring traffic on a permanent or temporary basis. In all locations, signs are displayed notifying you that CCTV is in operation and providing details of who to contact for further information about the scheme.
Body Worn Cameras incorporating audio recording are being used by Civil Parking Enforcement Officers and Household Waste and Recycling Centre operatives when necessary for operational purposes.<
The aim of the technology is to:
- promote the safety of the Officers
- reduce the potential number of confrontational situations experienced by Officers
- reduce potential escalation of incidents
- augment opportunities for evidence capture
Images captured by CCTV and Body Worn Cameras will not be kept for longer than necessary. Our standard retention period is 30 days from the date of capture. However, on occasions, there may be a need to keep images for longer, for example where a crime is being investigated.
You have the right to see CCTV and Body Worn Camera images/audio recording of yourself in accordance with the Data Protection Act and be provided with a copy of the images.
We will only disclose images and audio to other authorised bodies who intend to use it for the purposes stated above. Images and audio will not be released to the media for entertainment purposes or placed on the internet for public viewing.
We operate CCTV and disclose in accordance with the codes of practice issued by the Information Commissioner and the Home Office.
Profiling and automated decision making
Detect and prevent fraud or crime
Warwickshire County 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 fraud. We may also share this information with other bodies responsible for auditing, administering public funds, or where undertaking a public function, in order to prevent and detect fraud. This includes the Cabinet Office, the Department for Work and Pensions, other local authorities, HM Revenue and Customs, and the Police.
Section 68 of the Serious Crime Act 2007 enables public authorities to disclose information for the purposes of preventing fraud, as a member of a specified anti-fraud organisation or otherwise in accordance with any arrangements made with such an organisation. For further information see our page on the National Fraud Initiative at www.warwickshire.gov.uk/nfi.
In limited situations, we may monitor and record electronic transactions (website, email and telephone conversations). This will only be used to prevent or detect a crime, or investigate or detect the unauthorised use of the telecommunications system and only as permitted by the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000.
Emergency response management
Data matching may also be used to assist the council in responding to emergencies or major accidents, by allowing the council, in conjunction with the emergency services, to identify individuals who may need additional support - for example in the event an emergency evacuation.
How long your information will be held
We will not keep your information any longer than needed to provide the services you require. We may keep your data longer if we need to retain it for legal, regulatory or best practice reasons. We will tell you in our service specific privacy notices of the retention period that applies.
Information considered to be of cultural or historical significance may be retained with the County Record Office for archival purposes, as per their Acquisitions and Disposal policy.
How we protect your information
The information you provide will be subject to rigorous measures and procedures to make sure it can’t be seen, accessed or disclosed to anyone who shouldn’t be allowed to see it.
We have a comprehensive set of Information and Security policies. These define our commitments and responsibilities to your privacy and cover a range of information and technology security areas. We provide training to staff who handle personal information and treat it as a disciplinary matter if they misuse or do not look after your personal information properly.
We conduct assessments of privacy when making changes to processes or systems that hold your personal data. We assess the technical security of our systems and supplier systems.
We will not keep your information longer than it is needed or where the law states how long this should be kept. We will dispose of paper records or delete any electronic personal information in a secure way.
We will investigate data incidents where we have found that your personal information may have or has been disclosed inappropriately and attempt to recover any data. We will inform you unless we decide it would present a risk to you and inform the authorities such as Police, Information Commissioner or NHS where required.
Your information rights
In general, you have the right to request that Warwickshire County Council:
- provide a copy of your personal information
- correct any errors in your personal information and restrict processing until completed
- object to the processing, depending on the service and legal basis
- erase personal information, depending on the service and legal basis
- withdraw consent and have your data deleted, if consent is used as the legal basis for the service
- to be informed of automated decision making, including profiling for the service
The service specific privacy notice will detail what information rights you have.
Where possible we will seek to comply with your request but we may be required to hold, retain or process information to comply with a legal obligation or as a public task.
We try to ensure that any information we hold about you is correct. There may be situations where you find the information we hold is no longer accurate and you have the right to have this corrected. Please contact the Council service/team holding your information in the first instance.
Your rights are also set out in the Council’s Information rights Policy.
You are legally entitled to request access to any information about you that we hold, and a copy. See www.warwickshire.gov.uk/accesstoinformation for options on how to request a copy of your personal information.
Warwickshire County Council
Telephone: 01926 410410
If you have any concerns or comments please contact the Council’s Data Protection Officer directly:
Data Protection Officer
Warwickshire County Council
Email: [email protected]>
How to complain
If you wish to complain about your personal data privacy or information rights please contact the service in the first instance or at www.warwickshire.gov.uk/complaints.
If you wish to raise the matter directly with the Data Protection Officer, use the contact details above.
You have the right to complain to the supervisory authority – the Information Commissioner’s Office (ICO). The ICO is an independent body set up to uphold information rights in the UK. They can also provide advice and guidance and can be contacted through their website: www.ico.org.uk, via their helpline on 0303 123 1113 or in writing to:
Information Commissioner’s Office
Changes to this privacy notice
We will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with changes in the law. When such changes occur, we will revise the ‘last updated’ date at the top of this notice and the current version will be at www.warwickshire.gov.uk/privacy