The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are "special categories" of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Gender
  • National Insurance number
  • Bank account details, payroll records and tax status information
  • Election date
  • Declaration of Interests
  • Performance appraisal information
  • CCTV footage and other information obtained through electronic means such as swipecard records or location data
  • Information about your use of our information and communications systems
  • Photographs

We may also collect, store and use the following "special categories" of more sensitive personal information:

  • Information about your political opinions
  • Information about your health, including any medical condition, health and sickness records
  • Information about criminal convictions and offences

How is your personal information collected?

We typically collect personal information about members through the New Councillor Form and associated documentation directly from members.

We will collect additional personal information in the course of your term of office.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you
  2. Where we need to comply with a legal obligation
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else's interests)
  2. Where it is needed in the public interest or for official purposes

Situations in which we will use your personal information

We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to perform our official authority on the basis of the Localism Act 2011, the Local Government Act 1972, the Local Authorities (Members’ Allowances) (England) Regulations 2003 and similar legislation and to enable us to comply with legal obligations. In limited cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

  • Paying you
  • Gathering evidence for possible proceedings in accordance with the Members’ Code of Conduct
  • Education, training and development requirements
  • Complying with health and safety obligations including the reporting of accidents at work
  • To prevent fraud
  • To monitor your use of our information and communication systems to ensure compliance with our ICT policies
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
  • To enable us to record security or health and safety incidents for review after such incidents are reported to us

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to pay you or we may be prevented from complying with our legal obligations (such as to ensure your health and safety).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit written consent
  2. Where we need to carry out our legal obligations and in line with our data protection policy
  3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our data protection policy
  4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We will use your particularly sensitive personal information in the following ways:

  • We will use information about your physical or mental health, or disability status, to ensure your health and safety when at the Council’s premises, to provide appropriate adjustments taking account of any disability
  • We will use information about your political opinions in line with how have made this public yourself, so for instance to associate you with the political party with which you are affiliated

Do we need your consent?

We do not need your consent if we use special categories of your personal information for the reasons set out above. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We do not envisage that we will hold information about criminal convictions.

We will only collect information about criminal convictions if it is relevant to your qualification as a councillor or where required to do so in accordance with the Council’s Members’ Code of Conduct where we are legally able to do so.

We are allowed to use your personal information in this way where it is in the substantial public interest on the basis of law.

Data sharing

We may have to share your data with third parties, including third-party service providers.

We require third parties to respect the security of your data and to treat it in accordance with the law.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We may share your personal information with third parties where it is necessary for us to do so in line with a public task that we are carrying out.

Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and also other authorities, such as where you sit on a joint committee.

How secure is my information with third-party service providers and other entities?

All our third-party service providers and other entities are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may also need to share your personal information with a regulator or to otherwise comply with the law.