Last updated: 31 May 2017, version 11 WCC Full Privacy Notice (PDF, 43.93 KB)
Warwickshire County Council is registered as a ‘data controller’ under the Data Protection Act (ICO registration Z4835730) as we collect and process personal information about you. We process and hold information your information in order to provide public services. This notice explains how we use and share your information. 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.
We will continually review and update this privacy notice to reflect changes in our services and feedback from service users. We will be introducing a new customer privacy notice and service specific notices to meet the new data protection legislation including the General Data Protection Regulation coming into force on 25 May 2018.
When such changes occur, we will revise the ‘last updated’ date at the top of this page.
Why do 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
- 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.
How we use your information
We will use the information you provide in a manner that conforms to the Data Protection Act. 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. We will 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.
- 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 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, privacy notices and specific service sharing agreements. These can be found on our ‘sharing your information’ page and related links at: www.warwickshire.gov.uk/sharinginformation
Improving customer records
We are working to make our record keeping more efficient and be able to provide relevant services more quickly across our partners in Warwickshire. Your basic customer record comprises of your name, address, date of birth, gender, contact details (telephone/email), information which can be used to confirm your identity, a brief summary of your contact with the council, an indicator of the services used, and a customer reference number. This will not contain extensive details of the services you have received. However, this will also act as an index to other council systems, and be able to feed information into them, e.g. so you can tell us once of changes to your address and contact information.
Aggregated, anonymised or pseudonymised health data (including births and deaths data, and Hospital Episode Statistics) is used by Warwickshire County Council’s Public Health Intelligence team in supporting the effective and efficient discharge of its statutory duty and wider responsibilities to improve and protect the health and wellbeing of the populations it serves, and reduce health inequalities. For more information of the role and duties of the Public Health function see: www.warwickshire.gov.uk/publichealth
Purposes and data held
The Intelligence team will access health and related information to analyse the health needs and outcomes of the local population and for monitoring trends and patterns of diseases and the associated risk factors.
All information accessed, processed and stored by Public Health Intelligence staff will be used to measure the health, mortality or care needs of the population; for planning, evaluating and monitoring health; protecting and improving public health. It is used to carry out and support:
- health needs assessments
- health equity analysis
- commissioning and delivery of services to promote health and prevent ill health
- public health surveillance
- identifying inequalities in the way people access services
- joint strategic needs assessment
- health protection and other partnership activities
To deliver public health, local authorities need to use available health data sources to get relevant health and social care information. This data can contain person identifiable data which may identify patients such as name, address, age, sex, ethnicity, disease, use of hospital services, and/or NHS Number.
The Public Health Intelligence team will have access to the following data:
- Primary Care Mortality Database (PCMD) – The PCMD holds mortality data as provided at the time of registration of the death along with additional GP details, geographical indexing and coroner details where applicable.
- Births and Vital Statistics datasets – Births files include date of birth, sex, birth weight, address, postcode, place of birth, stillbirth indicators and age of mother. Deaths data includes: deaths broken down by age, sex, area and cause of death sourced from the deaths register.
- Hospital Episode Data (HES) – is a data warehouse containing details of all admissions, outpatient appointments and A&E attendances at NHS hospitals in England. This data is collected during a patient’s time at hospital and is submitted to allow hospitals to be paid for the care they deliver. HES data is designed to enable secondary use, that is use for non-clinical purposes, of this administrative data.
We are committed to using pseudonymised or anonymised information as much as is practical, and in many cases this will be the default position. Pseudonymisation is a procedure by which the most identifiable fields within a data record are replaced by one or more artificial identifiers, or pseudonyms. There can be a single pseudonym for a collection of replaced fields or a pseudonym per replaced field. The purpose is to render the data record less identifiable and therefore lower customer or patient objections to its use.
Anonymisation is the process of removing identifying particulars or details from (something, especially medical test results) for statistical or other purposes.
Any information held by the council about individuals will be held securely and in compliance with the Data Protection Act 1998. Information will not be held for longer than required and will be disposed of securely. The legal basis for the flow of data for the above purposes is set out in Section 42(4) of the Statistics and Registration Service Act (2007) as amended by section 287 of the Health and Social Care Act (2012) and Regulation 3 of the Health Service (Control of Patient Information) Regulations 2002. The Council has a Data Access Agreement with NHS Digital and data are supplied in accordance with section 42(4) of the Statistics and Registration Service Act 2007 as amended by section 287 of the Health and Social Care Act 2012, and Regulation 3 of the Health Service (Control of Patient Information) Regulations 2002.
You have the right to opt-out of the Public Health Intelligence Team receiving or holding your personal identifiable information. There are occasions where service providers will have a legal duty to share information, for example for safeguarding or criminal issues. The process for opting out will depend on the specific data and what programme it relates to. If you have any questions about our use of these data, wish to request a copy of the information we hold about you, or if you wish to discuss your rights in relation to opting-out from these processes, please contact the Public Health Intelligence team at email@example.com.
NHS number and social care
If you’re receiving support from Adult Social Care then the NHS may share your NHS number with the Council’s Adult Social Care service where this is relevant for your direct care as a patient. This is so that the NHS and Adult Social Care are using the same number to identify you whilst providing your care.
By using the same number the NHS and Adult Social Care can work together more closely to improve your care and support and make sure that you receive timely, effective and appropriate care.
Purposes and data held
Your NHS number is accessed through an NHS service called the Personal Demographic Service (PDS). Adult Social Care sends basic information such as your name, address and date of birth to the PDS so they can find your NHS number. Once retrieved from the PDS the NHS number is stored on the Council’s Social Care system. The NHS number will only be used by health and social care teams in the provision of direct care to ensure consistent and suitable care can be provided.
Health and social care professionals directly involved in care require access to the most up-to-date information about a patient and this is only possible by linking information through the use of the NHS Number. Access to any information about a social care service user or patient is strictly controlled based on the role of the professional and an audit record is kept of all access to this information. For example, social workers will only have access to information that is relevant to them carrying out their care duties.
The NHS number may also be printed on a subset of printed documentation that is specifically used to communicate between health and social care organisations. This brings the benefit of better co-ordinated and safer care across health and social care through the use of the unique identifier rather than a reliance on name and date of birth to identify a patient.
The Council uses the NHS Number in order to meet its statutory functions within Social Care in terms of:
- Ensuring integrated care
- Cooperating with partners
- Sharing of support plans
- Review of care provision
- Movement of people
- Discharge of patients from hospital
- Discharge of patients who have received treatment for a mental disorder
The legal basis for the NHS to release NHS Numbers to the Council is the Health and Social Care Act 2012 s261. The Health and Social Care (Safety and Quality) Act requires the sharing of information and use of the NHS Number in certain circumstances between providers and commissioners. The Council has a Data Access Agreement with NHS Digital
You have the right to object to the processing of your NHS Number. This will not stop you from receiving care, but may impact on the timeliness about how we are able to support you. To help you decide, we will discuss with you how this may affect our ability to provide you with care, and any other options you have. If you object to the use of your NHS Number please contact your named social worker, or the Council’s Information Management service.
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 in the event of e.g. an emergency evacuation.
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.
This 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 consent to this .
We suggest that you keep the amount of confidential information you send to us via email to a minimum and use our secure online forms and services.
You can sign up for email alerts for selected services using an external service from GovDelivery, with control over your preferences.
Using our website
If you are a user with general public access, the Warwickshire website 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.
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.
Images captured by CCTV will not be kept for longer than necessary. 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 images of yourself and be provided with a copy of the images.
Body Worn Videos (BWV) incorporating audio recording are being used by Civil Parking Enforcement Officers when necessary for operational purposes. The aim of the BWV 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.
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.
How we protect your information
You have the right to request that Warwickshire County Council stop processing your personal data in relation to any council service. However, this may cause delays or prevent us delivering a service to you. Where possible we will seek to comply with your request but we may be required to hold or process information to comply with a legal requirement.
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.
You are legally entitled to request access to any information about you that we hold, and a copy.
Please see www.warwickshire.gov.uk/dataprotectionact for options on how to access your personal information.
Contact information and further advice
If you would like to discuss your information rights further, please contact us:
Warwickshire County Council, Shire Hall, Warwick, CV34 4RL
Telephone: 01926 418633
If you have concerns about the use of your personal data, the Information Commissioners Office is an independent body set up to uphold information rights in the UK. They can be contacted through their website: www.ico.org.uk, or their helpline on 0303 123 1113, or in writing to:
Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF