Privacy Policy
Updated 21 July 2023
PRIVACY NOTICE
The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.
This privacy notice applies to services provided by The Consultation and Engagement Team and tells you what to expect us to do with your personal information. It should be read in conjunction with the Council’s privacy notice at https://www.hounslow.gov.uk/info/20110/open_data_and_information_requests/1368/privacy_notice .
If you have any questions about this privacy notice or any concerns about how we process your data, please contact engage@hounslow.gov.uk. The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.
What type of information we have
Please note that you can browse any publicly accessible sections of this website completely anonymously without signing up.
We currently collect and process the following information:
Profile Information collected from you when you register to use this site (those with asterisk are mandatory when registering):Please note that you can browse any publicly accessible sections of this website completely anonymously without signing up.
Email address (for log-in and communication purposes)
Postcode
Age range
Sex
Gender reassignment/identity
Relationship status
Religion/belief
Disability
Sexual orientation
Race/ethnicity
Pregnancy
The content you create as part of your interactions with this website. These can include:
Responses to surveys
Comments on discussion forums
Any of the other engagement opportunities available here.
We collect information about your usage of the site, such as:
Pages visited
Documents downloaded
For more information about the above and the use of cookies, please read the Cookie Policy (LINK).
How do we get your information?
Most of the personal information we process is provided to us direct by you. You may provide us your personal data by filling in the registration form or by participating in consultations/engagement on this site.
If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information.
Our lawful basis for processing your information
For engagement and consultation activity carried out on this website, we rely on UK GDPR:
Article 6(1)(e) - Public task: ‘processing is necessary for the performance of a task carried out in the public interest';
Or Article 6(1)(c) ‘for compliance with a legal obligation to which the controller is subject’ as our lawful basis.
We rely on Article 6(1)(a) consent when you register and request to be notified of updates and alerts. You can delete your account with us at any time by contacting engage@hounslow.gov.uk. You can opt out of updates and alerts at any time by updating your registration profile.
We rely on consent to use any cookies except for strictly necessary cookies.
The information you provide us with when you register on the site contains Special Category Data, including age, sex, ethnicity, religion, disabilities, health and languages. Where we process these (Special Category data), we rely upon Article 9(2)(g) - ‘processing is necessary for reasons of substantial public interest’ with the substantial public interest conditions being:
‘Statutory etc and government purposes,
Equality of opportunity or treatment
To ensure equality of opportunity or treatment within our programme
Why we need your information (purposes of processing)
The personal data we collect will be used for the following purposes:
Creating and administrating account
facilitate your participation in our consultation and engagement activities
understand your views about a particular topic or Hounslow’s activity
analyse consultation and engagement activity
inform Hounslow’s future strategy, policy, service design and budget planning
undertake equalities monitoring
authenticate and verify your account (through your email address)
communicate information to you about engagement and consultation opportunities, events and other initiatives, if you have requested to be kept informed
remind you to update your account information
inform you of the outcome of the engagement and consultation activities, if you have requested to be kept informed
respond to enquiries and comments
to contact you if you object to a Traffic Regulation Order or in other consultations where we are required to contact you
understand how users interact with the website and improve how our website functions – including cookies
protect the integrity of discussion from individuals and groups who may attempt to unduly influence the outcomes of the consultation process
provide access to private areas of the website for invited users.
You can delete your account with us at any time by contacting engage@hounslow.gov.uk. Please note that all consultation responses will be deleted from the website with the deletion of an account. However, we will not be able to delete responses that have been included (in aggregate, non-identified form) in reports (or data tables) already produced based on the responses available at that time.
You can also update your information and preferences at any time by logging into your account.
The processing of special category data is necessary for statutory purposes including equalities monitoring or to understand the potential impact of proposals on conditions related to special category data within your response (e.g. when identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained.) It is necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained.
Who your information may be shared with (internally and externally)
We may share aggregated and anonymised information with:
Services within the council who are responsible for the management of the engagement or consultation activity.
A third-party supplier who has been contracted to independently analyse the consultation responses. Registration information (user name and email address) will be removed before data is shared.
Organisations such as schools and academies with whom we may be consulting in partnership or on behalf of.
District or borough councils or government departments with whom we may be consulting in partnership or on behalf of. Registration information (user name and email address) will be removed before data is shared.
Any personal information provided that could identify you will be removed before consultation results are published.
Granicus’ teams (Granicus is the website/platform host/provider) do not have access to your user information stored on this website. Moderators are only able to view publicly visible usernames and text or image-based contributions for the express purposes of moderating those elements. If you feel a comment or contribution on the site is in breach of the rules you are within your right to alert the moderators through the “alert moderator” link near the comment you believe needs to be escalated to the moderation team. Alerting a moderator will not reveal your identity to the person who posted the comment.
There will be times when we are under a legal duty to share information. This includes, but is not limited to:
disclosure under a court order
sharing with the Ministry of Justice for inspection purposes
sharing with the police for the prevention or detection of crime
where there is an overriding public interest to prevent abuse or serious harm to others
disclosure to a Regulator if we identify a situation of potential misconduct or if the information is requested
We will therefore share personal information with law enforcement or other authorities if required by applicable law.
We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.
We are not seeking to share data that is not aggregated and anonymised.
How long we keep your information
The personal information you provide to create an account (register) will be kept until you ask us to delete your account or update your details. If your account has been inactive for more than two years, we will delete it.
We will not be able to delete responses that have been included (in aggregate, non-identified form) in reports (or data tables) already produced based on the responses available at that time.
We will hold any personal information provided by you as part of engagement or consultation activity for six years following the closure of a consultation. We will keep your personal data for as long as it is required by us or other regulatory bodies, and in accordance with our Local Authority Retention and Disposal Schedules.
We will then dispose of your information in the most secure manner possible.
Transfers to third countries
Some of the Granicus entities, Data Processors and other third parties share your personal data with are located outside of the UK or European Economic Area (EEA).
If Granicus transfer your personal data to entities outside of the EEA (which include IT service providers, recruitment partners and other Granicus entities in the US and India), they will make sure that your data is being protected as required by applicable data protection law. For transfers to other Granicus entities, Granicus will be bound by the EU Standard Data Protection Clauses (see – Article 46(2)(c) of the General Data Protection Regulation). For transfers to third party service providers, Granicus will do this by putting in place the EU Standard Data Protection Clauses (see – Article 46(2)(c) of the General Data Protection Regulation).
Business Intelligence, Profiling and Analysis
We may analyse your personal information to improve the council’s services for the following purposes:
undertake statutory functions efficiently and effectively
service planning by understanding your needs and your community's needs and to provide the services that you or your community request
understanding what we can do for you and your community and inform you of other relevant services and benefits
help us to build up a picture of how we are performing at delivering services to you and what services the people of Hounslow need
analysis of costs and spend of services we provide so that we can ensure better and efficient use of public funds
The council is committed to using pseudonymised or anonymised information where practical, and in many cases this will be the default position.
Pseudonymisation is a procedure by which the most identifying 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. An example of this is your National Insurance number or Council Tax Reference number.
Anonymisation is the process of removing identifying particulars or details. This means that the data cannot be linked back to identify you.
Data Matching and Auditing
We are required by law to protect the public funds we administer. We may use the information you provide to us for the prevention and detection of crime. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Audit Commission, the Department for Work and Pensions, other local authorities, HM Revenue and Customers and the Police.
The council uses data matching as a way of processing large volumes of information. While this can be a useful way of detecting fraud, it also enables us to identify information that is inaccurate or out of date, helping us comply with Data Protection law, while improving service provision.
As part of the council’s fraud prevention and detection activities, the council participates in the National Fraud Initiative (NFI). The data matching exercise is run by the Cabinet Office. You can find more information about this at the link below:
Your data protection rights
All individual rights requests should be sent to Customer Relations to log and assign a ticket number. For more details about Individual Rights see the Data Protection Policy.
The rights will differ depending on the lawful basis for processing – see table.
Please make sure that you familiarise yourself with this.
| Right to Rectification | Right to Erasure | Right to Restrict Processing | Right to Data Portability | Right to Object |
Consent | ✔ | ✔ | ✔ | ✔ | ✔ |
Contract | In limited circumstances (e.g name/age is incorrect) |
|
| ✔ |
|
Legal Obligation | In limited circumstances (e.g name/age is incorrect) |
|
|
|
|
Vital Interests | ✔ |
|
|
|
|
Public Task | In limited circumstances (e.g name/age is incorrect) |
|
|
| ✔ |
Legitimate Interests | ✔ | ✔ | ✔ |
| ✔ |
The rights available to you depend on our reason for processing your information. For further information about your data protection rights and how to make a request, please see ‘Your rights’
Your right to make a complaint
The Council tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
If you want to make a complaint you can contact us on:
Complaints Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB
Data Protection Officer
The Council’s Data Protection Officer can be contacted on:
Information Governance Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB
Information Commissioner’s Office
The Information Commissioner is the UK's independent body set up to uphold information rights.
If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website: https://ico.org.uk/
If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow Cheshire
SK9 5AF
Telephone: 0303 123 1113 or 01625 545 745
Email: casework@ico.org.uk
A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176. You can view our registration on the Information Commissioner's website.