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Privacy Notice
~ May 2018 ~
Data Controller Data Protection Officer The Commissioner of Police for the Director of Information City of London City of London Police IMS City of London Police HQ PO Box 36451 PO Box 36451 London, London, EC2M 4WN EC2M 4WN
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PRIVACY NOTICE WHO WE ARE
Data protection law in the UK and EU The City of London Police is the changed on the 25th May 2018. This territorial police force responsible for notice sets out your rights as an policing the City of London and has the individual in how the City of London national operational responsibility of Police process your personal data operating the National Cyber Crime under the new law. Reporting Centre, Action Fraud.
This notice comes into effect on 25th The Commissioner of Police for the City May 2018 and was last updated in May of London is the Data Controller and as 2018. such has overall responsibility for the lawful processing of all personal data As an EU member state the UK must processed by the force. He is assisted legislate to meet the EU Regulation by the Data Protection Officer who 2016/679 (more commonly referred to provides advice and guidance in as the General Data Protection relation to data protection law. Our Regulation) as well as the EU Directive data protection registration number is 2016/680 (Law Enforcement Directive). Z4894582 which is renewed each year. The UK government has enshrined both the regulation and the directive into To ensure that we process your the UK Data Protection Act 2018, which personal information fairly and lawfully, is formed of seven parts, referred to this notice informs you: herein as “the Act”. Why we need your personal Under the Act the City of London Police information; recognises its obligations and responsibilities as defined within Parts 2 How it will be used; (general processing) and 3 (law With whom it will be shared; and enforcement processing). What rights you have in relation to This Privacy Notice explains how and the personal information we collect. why the City of London Police process OUR COMMITMENT TO YOU your personal data, under Part 2, “general data” and Part 3 “law The City of London Police recognises enforcement data” and the steps we the importance of protecting personal take to keep your information safe. It and sensitive information in all that we also describes your rights in regard to do, and takes care to meet our legal your personal information and how to duties. The City of London Police puts in place all reasonable technical, complain to the Information security and procedural controls Commissioner if you have concerns as required to protect your personal to how we have handled your data. information for the whole of its life, in whatever format we hold that information.
HOW THE LAW PROTECTS YOU
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Your privacy is protected by law, which potential); Former and potential says that we can use your personal members of staff, pensioners and information only if we have a proper beneficiaries. reason to do so. This includes sharing it outside of the City of London Police. WHAT WE PROCESS The reasons why we may process your The type of personal information we personal information are: hold will vary depending upon the reason you have had contact with us Law enforcement purposes, as is but it may include: necessary for us to process your personal information under the Your name and address; Fingerprints, lawful basis of ‘public interest’ and DNA or photograph; Family, lifestyle ‘official authority’; and social circumstances; Education and training details; Employment Assist us in meeting our “Legal details; Financial details; Goods or Obligations” as employers; services provided; Racial or ethnic origin; Political opinions; Religious or To manage “Contracts” with those other beliefs of a similar nature; Trade who supply us with goods and union membership; Physical or mental services; health or condition; Sexual life; To help us support those who we Offences and alleged offences; come into contact with, which can Criminal proceedings, outcomes and be done by obtaining their sentences; Sound and visual images; “Consent”, or due to our “Legitimate References to manual records or files; Interests”, this includes processes to Information relating to safety and improve the service we provide the health; Complaint, incident, civil public; litigation and accident details To perform tasks which are We will use the minimum amount of considered as being in the “Public personal information necessary to fulfil Interest”. a particular purpose. Your personal information may be held on a computer system, in a paper record such as in a physical file or a PROCESSING UNDER photograph. PART 2 (GENERAL DATA) INFORMATION SOURCES
In order to carry out the purposes To carry out the purposes we have described above the City of London described we may obtain personal Police may obtain, use and disclose personal information relating to a wide information from a wide variety of variety of individuals including: sources, including:
Our staff, officers, volunteers, agents, HM Revenue and Customs; Legal temporary and casual workers; representatives; Solicitors; Courts; Suppliers, Complainants, Voluntary sector organisations; correspondents, litigants and enquirers; Independent Office for Police Relatives, guardians and associates of Conduct; Her Majesty’s Inspectorate of the individual concerned; Advisers, consultants and other professional Constabulary; Auditors; Police and experts; Victims (current, past and Crime Commissioners; Central
OFFICIAL OFFICIAL government, governmental agencies Health Care Providers and departments; Relatives, guardians or other persons associated with an Disclosures of personal information are individual; Current, past or prospective made on a case-by-case basis, only employers of the individual; relevant information, specific to the Healthcare, social and welfare advisers purpose and circumstances, will be or practitioners; Education, training disclosed and with necessary controls establishments and examining bodies; in place. Business associates and other professional advisors; Employees, The City of London Police will also officers and agents of The City of disclose personal information to other London Police; Suppliers, providers of bodies or individuals when required to goods or services; Persons making an do so, this could be under an act of enquiry or complaint; Financial legislation, by a rule of law, or by court organisations and advisors; Credit order. This may include, but is not reference agencies; Survey and limited to: research organisations; Trade union, staff associations and professional Child Maintenance Service; bodies; Local government; Voluntary Children and Family Courts Services; and charitable organisations; Ombudsmen and regulatory Home Office; authorities; The media. Courts; WHO WE SHARE YOUR PERSONAL Any other Regulatory Body who can INFORMATION WITH demonstrate that there is a legitimate purpose for the To carry out the purposes described the processing of your personal data. City of London Police may disclose personal information to a wide variety of recipients including those from The City of London Police may also whom personal data is obtained. This disclose personal information on a may include, but is not limited to: discretionary basis for the purpose of, and in connection with, any legal Support Services for Victims and proceedings or for obtaining legal Offenders; advice. To bodies or individuals working on our behalf such as IT contractors or HOW LONG WE KEEP YOUR survey organisations; PERSONAL INFORMATION Local government; The City of London Police keeps your personal information as long as is Central government; necessary for the particular purpose or Ombudsmen and regulatory purposes for which it is held. authorities; Records that contain your personal The media; information processed for “general
OFFICIAL OFFICIAL data” purposes will be managed in duty or responsibility of the police accordance with the Forces Retention arising from common or statute law. Schedule. WHAT WE PROCESS
In order to carry out the purposes PROCESSING UNDER PART described above, The City of London 3 (LAW ENFORCEMENT) Police may obtain, use and disclose personal information relating to a wide The processing of data for law variety of individuals including but not enforcement purposes can only be limited to: undertaken by an organisation which is considered a competent authority and has to be listed within Schedule 7 of the Offenders and suspected offenders; Act. Witnesses or reporting persons; Law enforcement purposes are: Individuals passing information to The City of London Police; and “the prevention, investigation, detection or prosecution of criminal Victims, both current, past and potential; offences or the execution of criminal penalties, including the safeguarding In order to carry out our statutory against and the prevention of threats responsibility we will process varying to public security”. types of personal data, this includes:
The City of London Police has a Your name and address; Employment statutory duty to uphold the law, details; Financial details; Racial or prevent crime, bring offenders to justice ethnic origin; Political opinions; and protect the public. To do this it is Religious or other beliefs of a similar necessary for us to process your nature; Physical or mental health personal information under the lawful condition; Sexual life; Offences and basis of ‘public task’ and ‘official alleged offences; Criminal authority’. This means we process your proceedings, Outcomes and personal information for carrying out sentences; Cautions; Physical identifiers tasks that are laid down in law and including DNA, fingerprints, and other collectively described as the genetic samples; Photograph, Sound administration of justice. and visual images; Criminal Intelligence; Information relating to The Administration of Justice, includes safety; Incidents, and Accident details the prevention and detection of crime; apprehension and prosecution of We will use only the minimum amount offenders; protecting life and property; of personal information necessary to preserving order; maintenance of law fulfil a particular purpose or purposes. and order; assisting the public in Personal information can be accordance with force policies and information that is held on a computer, procedures; national security; in a paper record such as a file or defending civil proceedings and any images, but it can also include other
OFFICIAL OFFICIAL types of electronically held information organisations that process data for a such as CCTV images. similar reason, in the UK and/or overseas, or in order to keep people INFORMATION SOURCES safe. These organisations include, but The data we process for law not limited to: enforcement purposes come from a wide variety of sources, including; Other law enforcement agencies (including international agencies); Other law enforcement agencies; HM Revenue and Customs; International Partner agencies working on crime reduction initiatives; law enforcement agencies and bodies; Licensing authorities; Legal Partners in the Criminal Justice representatives; Prosecuting arena; authorities; Solicitors; Courts; Prisons Local government; and Young Offender Institutions; Security companies; Partner agencies Authorities involved in offender involved in crime and disorder management; strategies; Private sector organisations International agencies concerned working with the police in anti-crime with the safeguarding of strategies; Voluntary sector international and domestic national organisations; Approved organisations security; and people working with the police; Third parties involved with Independent Office for Police investigations relating to the Conduct; Her Majesty’s Inspectorate of safeguarding of national security; Constabulary; Governmental agencies and and departments; Emergency services Other bodies or individuals where it is such as the Fire Brigade, National necessary to prevent harm to Health Service or Ambulance; Persons individuals. arrested; Victims; Witnesses; Relatives, Disclosures of personal information is guardians or other persons associated considered on a case-by-case basis, with the individual; The City of London using only the personal information Police CCTV systems; Body worn video appropriate to a specific purpose and and from correspondence sent to us. circumstances, and with necessary There may be times where we obtain controls in place. personal information from sources such Some of the bodies or individuals to as other police services and our own which we may disclose personal police systems such as our local information are situated outside of the information system. European Union - some of which do not WHO WE SHARE YOUR PERSONAL have laws that protect data protection INFORMATION WITH rights as extensively as in the United Kingdom. If we do transfer personal To enable The City of London Police to data to such territories, we undertake meet their statutory duty we may be to ensure that there are appropriate required to share your data with other safeguards in place to certify that it is
OFFICIAL OFFICIAL adequately protected as required by However your information rights will be the legislation. dependent on the reason why and how the data was collected and why it The City of London Police will also is being used. disclose personal information to other bodies or individuals when required to In order to exercise your rights under do so, or under an act of legislation, a data protection law, we will need to rule of law, and by court order. This may verify your identity for your security. include, but is not limited to: You can contact us by emailing data.protection[a]cityoflondon.police. Serious Fraud Office; uk, writing to Data Protection Officer, National Fraud Initiative; IMS, City of London Police, PO Box 36451, London EC2M 4WN or online at Courts; www.cityoflondon.police.uk HOW LONG WE KEEP YOUR PERSONAL INFORMATION HOW TO GET A COPY OF YOUR PERSONAL INFORMATION The City of London Police keeps your personal information as long as is This is commonly known as subject necessary for the particular purpose or access and is the right which allows you purposes for which it is held. Personal access to your personal data and information which is placed on the supplementary information. You can Police National Computer is retained, make a subject access request by reviewed and deleted in accordance using the contact information above. with the Retention Guidelines for Once we have received your request Nominal Records on the Police we will respond within 1 month. National Computer RIGHT TO BE INFORMED Other records that contain your personal information and which was This places an obligation upon the City processed for law enforcement of London Police to tell you how we purposes are retained in accordance obtain your personal information and with the College of Policing guidance describe how we will use, retain, store on the Management of Police and who we may share it with. Information (MoPI), and the City of London Police’s Record Retention We have written this Privacy Notice to Policy. explain how we will use your personal information and tell you what your rights are under the legislation YOUR RIGHTS LETTING US KNOW IF YOUR PERSONAL A key area of change in the new Data INFORMATION NEEDS UPDATING Protection Act relates to individuals’ You are entitled to have personal data rights, the law refreshers existing rights rectified if it is inaccurate or by clarifying and extending them and incomplete. introduces new rights.
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IF YOU WANT US TO ERASE YOUR The processing of your personal data PERSONAL INFORMATION based on legitimate interests or the You have the right to request the performance of a task in the public interest/exercise of official authority deletion or removal of your personal (including profiling); data and/or the right to ‘block’ or restrict the processing of your personal The processing of their personal data data where there is no compelling for direct marketing (including profiling); and reason for its continued processing. The processing of their personal data If you feel that we should no longer be for the purposes of using your personal information, or that scientific/historical research and we are illegally using your data, you statistics. can request that we erase the personal If you are not satisfied with our response information we hold on you. When we or believe that we are not processing receive your request, we will confirm your personal information in whether the personal information has accordance with the law, you can been deleted or tell you the reason complain to the Information why it cannot be deleted. There may Commissioner’s Office (ICO) by be legal reasons why we need to keep emailing casework[a]ico.org.uk or telephoning 0303 123 1113. Additional your personal information. contact methods are detailed on their If you want to request that we erase website: https://ico.org.uk/global/contact-us your personal information, please contact us using the details above.
RIGHT RELATING TO AUTOMATED CHANGES TO THIS PRIVACY NOTICE DECISION MAKING We regularly review our privacy notice. Automated individual decision making We will publish any updates on the City of London Police website. You can and profiling is a decision made by request a copy of our privacy notice by automated means without any human using the details above. involvement. If we plan to use your personal OBTAINING YOUR INFORMATION IN A information for a new purpose we will PORTABLE FORMAT update our privacy notice and communicate the changes before we The right to data portability allows you start any new processing. to obtain and reuse your personal data for your own purposes across different services. You have the right to get copies of your personal information from us in a format that can be easily re-used.
YOUR RIGHT TO COMPLAIN
Individuals have the right to object to:
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