Privacy

South Staffordshire Council (“the Council”) collects, holds and uses personal information about residents and service users, to allow us to provide public services. 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other service specific notices and privacy policies and is not intended to override them.  

Your privacy is important to us, and we are committed to handling your personal data securely in line with UK Data Protection laws. 

South Staffordshire Council of The Council Offices, Wolverhampton Road, Codsall, WV8 1PX, is the Data Controller for the Council’s Data.   

Our Data Protection Registration number is: Z7513328. 

The Data Protection Officer for the Council is the Corporate Director of Governance- Lorraine Fowkes. Contact – DPO@sstaffs.gov.uk 

This privacy policy aims to give you information on how the Council collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete online forms or sign up for email updates.    

This website is not intended for children and we do not knowingly collect data relating to children. 

We do not transfer your personal data outside the UK. 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns in accordance with the Council’s customer complaints procedure before you approach the ICO.  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

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). 

We may collect, use, store and transfer different kinds of personal data about you including special category data of a sensitive nature to deliver some of our services.   

No more information will be collected than is needed to deliver that service. 

Types of personal information we collect about you may include:- 

• Identity information eg, name, maiden name, title, address, email address, telephone number, date of birth, marital status, gender 
• Identification numbers for example National Insurance Number, NHS number, Unique Tax Reference Number 
• Family details eg name, date of birth, address of your family, housing needs 
• Financial details eg bank account, employment information, payment card details, business activities 
• Technical Data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.  

Special Categories of data, also known as sensitive personal information, that we may hold about you include:- 

• Physical  or mental health details 
• Social care needs 
• Racial or ethnic origin 
• Trade union membership 
• Political affiliation/opinions 
• Offences (including alleged offences)/criminal proceedings and outcomes. 
• Sex life or sexual orientation 
• Religious or other beliefs of a similar nature 

We may use information such as your:- 

• Ethnic background 

• Gender 

• First language 

• Sexual orientation 

• Age 

This will be for statistical reasons about the population of the district and the take up of council services.  This is to help comply with legal obligations and to plan the provision of future services. This analysis will not identify individuals or impact on your entitlement to council services and facilities. 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to provide you with the service or perform the contract we have with you. 

We use different methods to collect data from and about you including through:  

Direct Interactions:  

You may provide your data by completing assessment forms, or request forms on paper that you send to us. You may write us letters and send these in on paper or contact us face to face.  We may keep a record of your contact to assist on the delivery and improvement of the services we provide to you and others. Any such records that include any personal information will be kept securely.  

Telephone calls:  

Ordinarily we will inform you if we record or monitor any telephone calls you make to us. This is to increase your security, for our record keeping of the phone call, and for training and quality purposes.  

Emails:  

If you email us, we may keep a record of your contact and your email address for our record keeping. We will not include any confidential information about you in any email we send to you unless sent securely, or you have agreed to us contacting you with this information. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum.  

Online:  

You may complete online forms, make requests, or make online payments to us.

On systems:  

We may log any information you provide to us on a computer system to help us keep track of your request, or any actions we need to complete. We may add your information to systems where we are required to by laws.  

Automated technologies or interactions: As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details. 

From other sources:  

We may receive information about you from other organisations or agencies such as:  

• Ombudsman and regulatory authorities  

• providers of goods and services  

• local and central government and other public bodies. For example; the Department for Work and Pensions (DWP), Cabinet Office, HM Revenues and Customs (HMRC), Driver and Vehicle Licensing Agency (DVLA)  

• licensing authorities  

• partners that are part of National or Regional improvement projects.   

• health bodies (NHS Trusts, GPs)  

• national Databases such as ONS and Census information; 

• the Police  

• Care Quality Commission  

• courts, prisons  

• other Local Authorities  

• The Cabinet Office as part of the National Fraud Initiative (NFI)  

• HomesPlus & Tenancy Management Organisations  

We will receive information about you either for a legal reason, or because you are receiving a service jointly delivered by another organisation and the Council. You may have asked for your information to be shared with the Council. Information can be provided to us by any format described at the beginning of this section.  

We will match data from other sources to the data we hold at the council, to ensure we have the correct information about you.  

For example:  

• If your health details are shared by your GP or Hospital with the Council for your health and social care, we will match your NHS number to our system to ensure your records are complete and link to the correct entry on our systems.  

• If your benefit details are shared by the DWP with the Council, we will match your national insurance number with our council tax and benefits system to ensure your records are complete and link to your record only.

These are some examples, but we may match and add other types of your information, that has been shared with the Council, to our systems to record and hold it as part of your record with the Council.

We will only use your personal data when the law allows us to and for the purposes stated when the information was collected from you.  It will not be reused for different purposes or sold on to others.  We use your personal data:  

Where we need to provide a service to you. 

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. 

Where we need to comply with a legal obligation. 

Where your data is placed on an appropriate system, such as the council tax system, housing system, customer services system, or benefits systems, and so on. It will be used to provide or administrate that service. We may cross reference this data between systems to keep your information as accurate and up to date as possible in line with Data Protection best practice.  

Access to each of the Councils systems, for council staff, is based on a need-to-know basis. Not all council staff have access to all council systems, access to your data is strictly controlled, and only given to staff who have a real need to know to do their job. For a member of staff to access any system, this must be authorised by a manager. The council uses systems which can be audited to see who has used your records, so we can keep them confidential. Specific areas of the council may set out how they use your data in their own Privacy Notices. 

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.  

Some of the reasons are things the council must do by law/under our statutory obligations. The following are a few examples of the many pieces of law that the council works under, but there are more: Local Government Act, Health and Social Care Act 2012, Safeguarding vulnerable people, The Care Act 2014, Licencing Act 2003, Housing and Planning Act 2016, The Privacy and Electronic Communications (EC Directive) Regulations 2003, Criminal Finance Act 2017, Income Tax (Earnings & Pensions) Act 2003 as amended by Finance Act 2020, The Finance Bill 2021.  

These types of laws ask the council to:

• Submit data as required to central government, e.g. HM Revenues and Customs (HMRC), Health and Safety Executive (HSE).  
• Make sure we meet our legal obligations - including those related to diversity and equalities. 
• Support Crime prevention and local fraud initiatives, including the collection of unique tax reference numbers to determine the employment status of contractors and the use of CCTV  
• By law, to protect the public funds we administer; we may share information provided to us with other bodies responsible for auditing, or administering public funds, or undertaking a public function.  
• Undertake Data Matching, where personal details held by one organisation are checked against those held by another organisation. This allows potentially fraudulent claims, transaction, application, taxes and payments to be identified.   
• Safeguarding vulnerable children and adults.  
• To use data where relevant UK Data Protection laws allows us to so. (General Data Protection Regulation 2016/679, Data Protection Act 2018).  
• Perform corporate administration, and all activities we are required to carry out as a data controller and public authority. Some of the reasons will be to provide a range of services to local people and businesses which include: 

                   - updating your customer record
                   - maintaining our own accounts and records 
                   - supporting and managing our employees 
                   - carrying out health and public awareness campaigns 
                   - managing our property 
                   - administering the assessment and collection of taxes
                     and other revenue including benefits and grants  
                   -  licensing and regulatory activities  
                   - providing commercial services, such as, administration
                     and enforcement of parking regulations and restrictions 
                   - providing non-commercial activities, such as,
                     refuse collections from residential properties,  
                   - internal financial support and corporate functions  
                   - managing archived records for historical and research reasons 
                   - promoting public health for the district  
                   - informing you of other relevant services and benefits 
 

Some of the reasons will be because you have signed up to receive a service the council offers, or given your consent for us to use your details to:

•  understand your needs, and provide the services that you request  
• provide leisure and cultural services  
• promote the services we provide  
• carrying out surveys to get your opinions on our services  
• undertake research  
• market local tourism  

We may not be able to provide you with a product or service unless we have enough information, or your permission to use your information. We aim to keep your information accurate and up to date. 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.   

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.  

How long will you use my personal data for?  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.  

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.  

In some circumstances you can ask us to delete your data -  see 'Your legal rights' below for further information. 

Alternatively, we could refuse to comply with your request in certain circumstances.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Under certain circumstances, you have rights under data protection laws in relation to your personal data and sensitive information.  

Please see the Information Commissioners Office  guidance on your rights here.  

• You have the right to be informed of how the Council is processing your data. This Privacy Notice explains this. Where you have signed up to a council service which relies on your consent alone (i.e. the services are not covered by a statutory duty) you have the right to withdraw your consent.  

• Your rights in relation to automated decision making and profiling are explained clearly here by the Information Commissioners Office.  

• You have the right of access to your data. All requests for access can be sent to the Council using this email address - dpo@sstaffs.gov.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. What we may need from you  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.  

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.