Prevent service privacy notice
Brighton & Hove City Council is committed to protecting your personal information.
As a data controller, we have a responsibility to make sure you know why and how your personal information is being collected. This is in accordance with relevant data protection law.
The primary laws which govern how Brighton & Hove City Council collects and use personal information (known as data) about you are:
However, Prevent (including Channel) is also subject to other specific laws which define when and for what purposes it can use your personal data.
Why we are collecting your data and our lawful basis for doing so
We are collecting your data for the purpose of preventing and safeguarding individuals who may be vulnerable to being drawn into terrorism or supporting terrorism. The data collected can be used to form casefiles in order for Prevent Officers to provide appropriate support to those individuals. Prevent also collects information to support their work with a wide range of sectors where there are risks of radicalisation.
As a ‘Specified Authority’ we have a duty to prevent and safeguard people from being drawn into terrorism or supporting terrorism under the Counter Terrorism and Security Act 2015 and the Counter Terrorism and Border Security Act 2019. The council also has a duty under the Crime and Disorder Act 2015 to prevent and reduce crime and disorder in the area.
Prevent also collects information from training and awareness raising sessions delivered to individuals from across various sectors and communities, for example, Council Workers, Adult and Children Services, Charities, communities and the education sector.
Information will also be collected when officers liaise with organisations throughout the city to prevent and assess risks, as well as communicate with individuals from different parts of the community to foster cohesion. This is done so for the performance of a task carried out in the public interest.
We also collect special category data, and in these instances the lawful basis would fall under substantial public interest, specifically the Data Protection Act (2018), Schedule 1, Part 2, Paragraph 6 ‘Statutory etc. and government purposes’.
The data we may collect
- Contact details including name, address, email address, telephone number
- Date of birth
- Proof of identity
- National identifiers such as; NI numbers
- Information about your family
- IP address and information regarding what pages are accessed and when
- Social and personal circumstances
- Housing information relating your council tenancy
- Visual images and audio, personal appearance and behaviour
Special Category Data
- Physical or mental health details
- Racial or ethnic origin
- Gender and sexual orientation
- Political opinions and affiliation
- Offences (including alleged offences)
- Criminal proceedings, outcomes and sentences
Who we’ll share your data with
Your data may be shared internally with potentially any team within the council but the most common areas we would share with are Children Services, Adult Social Care, Safer Communities, Housing, Premises, Information Technology & Digital, Legal Services and Elected Members.
Your information may also be shared externally with the Police and Counter-Terrorism Police, Probation and Prison Services, our commissioned services, Health Sector, Education Sector, Third Sector, Home Office, East Sussex Fire & Rescue and Office for Security and Counter-Terrorism.
Data that is shared is always done:
- on a case-by-case basis
- using the minimum personal data necessary to provide the service
- with the appropriate security controls in place
- in line with legislation
Information is only shared with those agencies and bodies who have a need to know, or where you have consented to share your personal data.
We may use the information we hold about you to assist in the detection and prevention of crime or fraud.
We may also share this information with other bodies that inspect and manage public funds.
Holding your personal information
We will not keep your data for longer than is necessary, subject to any legal obligations we have to retain the data.
How long we keep it will vary according to the services you are involved with, and the lawful basis for processing within those services.
However, the principles we will use to determine how long your data will be kept include:
- what type of services you received, and whether you are still receiving them
- whether we are still under a legal obligation, either to you or under UK Law
- any standards and guidance set out by the various regulators for our functions
- whether you have expressed a preference that your data be retained, such as exercising a right to restricted processing
How your data will be stored
Your information will be stored on electronic databases, document management systems and on paper records.
Who can access your data?
We will only make your information available to those who need to know, in order to perform their council role.
How do we protect your data?
Examples of the security measures we use are:
- training for our staff, making them aware of how to handle information securely, and how and when to report when something goes wrong
- we use encryption when data is being sent, meaning that information is scrambled so that it cannot be read without access to an unlock key. The hidden information is said to then be encrypted
- where possible, data will be pseudonymised, meaning that your identity will be removed, so that work can be done without your identity being known by the people doing that work
Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information, from getting access to it.
Regular testing of our technology and ways of working, including keeping up to date on the latest security updates (called patches).
Transferring data outside the European Economic Area
Your information is not processed outside of the European Economic Area.
Your individual rights
You have the following rights in relation to your personal information:
The right to be informed – you have right to know about the collection and use of your personal data. We will inform you through our service-specific notices
The right of access – you can request to know what we hold on you, along with an explanation for how it is used by making a Subject Access Request
The right to rectification – you have the right to ask us to update, amend or change your information if it is factually inaccurate or incomplete
The right to restrict processing – you have the right to request that we limit using your personal data for specific purposes. If you do not believe we have a lawful basis for a particular purpose, or where you consider the data to be incorrect. Upon receiving a restriction request, we are obliged to consider our use of the data and provide you with a response
The right to object – you have the right, in certain circumstances, to object to us collecting, using and storing your information. Upon receiving a request of this type, we are required to stop using your data whilst we investigate and provide a response
Automated decision making and profiling - we will tell you if we make an automated decision, including profiling, with your personal information. If we do this you have the right to ask us to make this decision manually instead
At present, the council only uses automated decision processes to identify first round offers of school placements. These offers are subject to appeal and you have the right to seek a review of your school placement offer by a council officer.
How to get advice or make a complaint
Data protection contacts
If you wish to discuss any of your data protection rights, you can contact the Data Protection Team on 01273 295959 or by email at firstname.lastname@example.org
Whilst we would prefer that you contact us first with any concerns that you might have, you can also contact the Information Commissioner’s Office. The ICO is the national regulator with responsibility for ensuring compliance with data protection.
Information Commissioner’s Office
You also have the right to lodge a complaint with a supervisory authority. Contact details for the ICO is stated below:
You can contact the ICO:
- on their website
- by telephone: 0303 123 1113
- by post: Wycliffe House, Water Ln, Wilmslow SK9 5AF
This Privacy Notice will be subject to review when there is a change.