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Privacy and Cookies Notice

This privacy notice tells you what to expect when the council uses your personal information. The cookies notice explains how cookies help the website analyse how users use the site.

Contents:

  1. Overview
  2. Why we process data
  3. Categories of Data the council collects
  4. Who your data is shared with
  5. How we collect your data and from where
  6. How your data is used
  7. The Councils responsibilities
  8. Your Data Rights
  9. Access non-personal council data
  10. How to raise a complaint about information


Cookies

The City of Wolverhampton Council currently uses Google Analytics to monitor traffic to and around our website. Google Analytics uses cookies to help the website analyse how users use the site. Find out more about our use of cookies.



1. Overview

The City of Wolverhampton Council collects, holds and uses personal information about residents and service users, to allow us to provide public services. This privacy notice tells you what to expect when the council uses your personal information. Your privacy is important to us, and we are committed to handling your personal data securely in line with UK Data Protection laws.

The City of Wolverhampton Council is the Data Controller for Council Data. Our Data Protection Registration number is: Z5569755.

Data Protection officer for the Council is: The Information Governance Manager - Anna Zollino-Biscotti. Contact them on: DPO@Wolverhampton.gov.uk

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2. Why we process data

We collect and use your personal data for several reasons, this depends on how you interact with the council.

Some of the reasons are things the council must do by law/under our statutory obligations. Below are some examples of the many pieces of law that council works under, but there are more: Local Government Act, Health and Social Care Act 2012, Safeguarding vulnerable people The Care Act 2014, Licensing Act 2003, Housing and Planning Act 2016, The Privacy and Electronic Communications (EC Directive) Regulations 2003.

These types of laws ask the Council to;

  • submit data as required to central government, e.g. Department for Education (DfE), HM Revenues and Customs (HMRC), Health and Safety Executive (HSE).
  • make sure we meet our legal obligations - including those related to diversity and equalities.
  • crime prevention and local fraud initiatives, including the use of CCTV.
  • we are required 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.
  • for 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. For more information about the data matching the council does, have a look here: http://www.wolverhampton.gov.uk/article/3060/Fair-Processing-Notice-Data-Matching
  • safeguarding vulnerable children and adults.
  • where relevant UK Data Protection laws allows us to use data. (General Data Protection Regulation 2016/679, Data Protection Act 2018).
  • 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 government 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
  • providing of education
  • administering the assessment and collection of taxes and other revenue including benefits and grants
  • licensing and regulatory activities
  • providing social services
  • 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 Wolverhampton
  • 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.

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3. Categories of data the Council collects

We need to collect your personal or special category data of a more sensitive nature, to deliver some of our services. This may be based on a legal requirement for the council to provide a service, or it may be a service you have signed up for (consented to).

No more information will be collected then is required to deliver that service.

Types of personal information we collect about you may include:

  • personal details (name, date of birth)
  • identification numbers (e.g. NHS number, National Insurance Number)
  • family details
  • lifestyle and social circumstances
  • goods and services
  • economic / financial details
  • employment and education details
  • housing needs
  • visual images, personal appearance and behaviour
  • CCTV images
  • licenses or permits held
  • student and pupil records
  • business activities
  • case file information
  • birth/death data provided by/to the office of national statistics

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
  • political opinions
  • offences (including alleged offences)
  • religious or other beliefs of a similar nature
  • criminal proceedings, outcomes and sentences
  • genetic or biometric data
  • sex life or sexual orientation

Equalities information

City of Wolverhampton Council may use information such as your;

  • ethnic background
  • first language
  • gender
  • sex life or sexual orientation
  • age

This will be for statistical reasons about the population of the city, and the take up of council services by various groups. This is to help comply with our legal obligations and to plan the provision of future services.  This type of analysis will not identify individuals or have an impact on your entitlement to council services and facilities.

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4. Who your data is shared with

Sharing to provide services

Your personal information may be shared with internal departments in the Council, or with external partners and agencies outside of the Council. This may include charities involved in delivering services on the Councils behalf. Sometimes we will have a legal reason to share your data with a partner. They will only have access to your information on a need to know basis. We will only share what they need to know to do the job or deliver a service to you. Your privacy and the security of sharing this information is checked when we start to work with someone new. Examples are:

  • educators and examining bodies (Schools and education providers in Wolverhampton and neighbouring areas. Exam Bodies operating nationally such as OCR, Edexcel, Ofsted)
  • providers of goods and services, sometimes we ask other companies to provide services on the Council's behalf, such as waste collection, or computer systems provided by specialist company, housing companies such as Wolverhampton Homes, Sanctuary Group, Nehemiah UCHA, Midland Heart
  • local and central government and other public bodies. For example; the Department for Work and Pensions (DWP), Department for Education (DfE), Cabinet Office, HM Revenues and Customs (HMRC)
  • other Local Authorities (other Councils)
  • ombudsman and regulatory authorities, who will be investigating your concerns or complaints.
  • licensing authorities who oversee who can have a license for a taxi, serving alcohol or food in local businesses.
  • health bodies in the local area, and sometimes nationally. Wolverhampton GP's, The Royal Wolverhampton Hospitals NHS Trust, Black County Partnership NHS Foundation Trust, Wolverhampton Clinical Commissioning Group (CCG),
  • partners that are part of National or Regional improvement projects. For example, the Better Care Fund, Headstart, Recovery Near You (for drug and alcohol advice and support)

We also share information with 3rd party organisations, such as insurers or solicitors who are acting on your behalf. This is usually done with your consent, unless there is a legal reason (as below) to share without your consent.

Sharing to comply with the Law

The council may also provide personal information to third parties, where it is necessary to do so to comply with the law. We will share where we are required to under UK Data Protection law (General Data Protection Regulation 2016/679, Data Protection Act 2018). For example, we might need to use your information and share it with others for one or more of the following reasons:

  • for the purposes of the prevention and detection of crime.
  • to protect the public purse and to minimise waste.
  • it is otherwise necessary to comply with any other legal obligations.

Examples of third parties who we may share your information with, where a law requires us to, include (but are not limited to):

  • health bodies (NHS Trusts, GPs)
  • the Police (West Midlands Police, Staffordshire Police, Staffordshire and West Midlands Community Rehabilitation Company (Probation service))
  • Ofsted
  • local and central government and other public bodies. For example; the Department for Work and Pensions (DWP), Department for Education (DfE), Cabinet Office, HM Revenues and Customs (HMRC)
  • other Local Authorities (other Councils)
  • Care Quality Commission
  • courts, prisons
  • West Midlands Fire Service
  • we may also share information with utility companies, credit reference agencies, insurers, service providers or contractors and partner organisations, where the sharing of information is required by a law. We make sure that any information we share is necessary, kept to a minimum and lawful.

The Council puts agreements in place with partners we share with to ensure we all protect your data properly, and are only sharing the minimum amount of data we need to provide you with a service. More information can be found at City of Wolverhampton Council - Information Sharing Where we need to share sensitive or confidential information such as medical details, we will do so only with your permission or where we are legally required to. We may share sensitive or confidential information to prevent risk of harm to you or another person, for example in the case of Safeguarding vulnerable people.

The detection and prevention of fraud

We are required by law to protect our public funds; therefore, we may use any of the information you provide to us for the prevention and detection of fraud, or to comply with the law. As well as conducting our own 'Data Matching' (where personal details we hold on one system may be checked against the details on other systems to identify fraudulent claims or transactions) we may also share your information with other public bodies. These include (but are not limited to):

We may share your data with 3rd countries or international organisations, only where;

  • there is a legal reason to share
  • or, you have provided consent for us to share
  • and where there are appropriate safeguards in place to ensure the level of protection of your data is guaranteed.

We endeavour to publish a list of our information sharing partners here: http://www.wolverhampton.gov.uk/article/3327/Information-Sharing

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5. How we collect your data and from where

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.

On paper:
You may complete assessment forms, or request forms on paper that you send to us. You may write us letters and send these in on paper.

Online:
You may complete online forms, make requests, or make online payments to us. See our City of Wolverhampton Council - Privacy & cookies

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.

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

  • educators, examining bodies
  • Ofsted, Ombudsman and regulatory authorities
  • providers of goods and services
  • local and central government (e.g. Department of Work and Pensions, HMRC)
  • licensing authorities
  • partners that are part of National or Regional improvement projects. For example; the Better Care Fund, Headstart, Recovery Near You (for drug and alcohol advice and support)
  • health bodies (NHS Trusts, GPs)
  • national Databases such as;
    • the NHS PDS (Personal Demographics Service)
  • the Police
  • Care Quality Commission
  • courts, prisons
  • other Local Authorities
  • The Audit Commission
  • Wolverhampton Homes & TMOs

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 social care 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 City of Wolverhampton Council.

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6. How your data is used

Information which you have provided the Council will be stored securely, on encrypted and physically protected servers, systems or paper storage areas (Filing cabinets, Archives). We will use your information for the reasons (purposes) stated when the information was collected from you. It will not be reused for different purposes, or sold on to others.

Your data will be placed on an appropriate system, such as the council tax system, social services 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.

Some areas of the council that use your personal data have very specific reasons for doing so. Some Council departments may ask you to complete assessments that result in an automated decision being made about you, or could be seen as profiling. This is where a computer programme will make the decision based on a set of criteria. You can ask the Council to explain the outcomes of any automated decisions made about you, and ask for a person to make the decision.

Specific areas of the council have set out how they use your data in their own Privacy Notices which are available here:

Website Cookies http://www.wolverhampton.gov.uk/article/12565/Privacy-and-Cookies-Notice#cookies

Public Health http://www.wolverhampton.gov.uk/CHttpHandler.ashx?id=9899&p=0

Children and Young People http://www.wolverhampton.gov.uk/CHttpHandler.ashx?id=7320&p=0

Adult Social Care http://www.wolverhampton.gov.uk/CHttpHandler.ashx?id=3950&p=0

Potentially Violent Persons Register http://www.wolverhampton.gov.uk/CHttpHandler.ashx?id=10986&p=0

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7. The Councils responsibilities

Everyone working for City of Wolverhampton Council has a legal duty to work within the Data Protection Principles. They must keep information about you confidential and secure, use it only for specific purposes and keep it only for as long as necessary. The Laws and best practice we abide by are;

  • Data Protection Act 1998/ General Data Protection Regulation 2016/679
  • Human Rights Act
  • Caldicott Principles relating to confidentiality.
  • British Standard and International Standard (BS/ISO) 15489-Records Management
  • Lord Chancellors Code of Practice on Records Management

Each of the departments within the Council may have other specific pieces of law or guidance they must follow which have an impact on recording or using the information we hold. For example, Guidance form professional bodies on record keeping for Social Workers, legal requirements to record and keep licencing information, or planning applications.

Where we share information with other bodies or agencies, we will ensure the confidentiality and security of your data. This will normally be done by having a contract and confidentiality clauses in place. We also carry out data privacy impact assessment each time we start a new project, to help us build in security and privacy to protect your information.
 
We will keep your information in line with legislation and guidance on records retention periods. We will not keep your information longer than it is needed. We will dispose of paper records or delete any electronic personal information in a secure way.

We do not share your data with private companies, unless they have a contract with the council to provide a service on behalf of the council. For example, a company who will conduct a survey on the council's behalf can only use the data we give them for our survey and they must delete it after the work has been done. Or where you have provided your consent for us to share with other private companies.

For more detail on how we work within these guidelines please reference our Information governance policies here: http://www.wolverhampton.gov.uk/igov

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8. Your Data Rights

Under the General Data Protection Regulation 2016/679 and the Data Protection Act 2018, you have rights of how your personal and special category (known as sensitive) information is used.

Please see the Information Commissioners Office guidance on your rights here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

  • You have the right to be informed of how the Council are 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.
  • You have the right of access to your data. All requests for access can be sent to the Council using the contact details are below.

Post:
Information Governance Team
City of Wolverhampton Council
Civic Centre
St Peter's Square
Wolverhampton
WV1 1SH

Telephone: 01902 554498

Email: data.protection@wolverhampton.gov.uk

For further information please contact the council's Information Governance Team.

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9. Access non-personal council data

The council routinely publishes sets of non-personal data that we hold.  You may find what you are looking for on the Publication Scheme here: http://www.wolverhampton.gov.uk/article/3196/The-Publication-Scheme

Certain sets of data about accounts and performance, assets, housing, planning and land, are available on DataShare here: http://data.wolverhampton.gov.uk/

If you have a different question, or can't find the information you are looking for on the Councils website, you can make a request for non-personal information under the Freedom of Information Act 2000 or the Environmental Information Regulations 2004 via:

Post:
Information Governance Team
City of Wolverhampton Council
Civic Centre
St Peter's Square
Wolverhampton
WV1 1SH

Telephone: 01902 554498

Email: foi@wolverhampton.gov.uk

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10. How to raise a complaint about information

If you have a complaint in relation to your data rights or a freedom of information request, please contact us in the first instance to request an internal review of our response.

  • For Data Protection/ Data Rights complaints, you can use the contact details form the "How to access information held about you" section.
  • For Freedom of Information complaints, you can use the contact details form the "How to ask about other information held by the council" section.

If you follow this procedure and are still not happy, you may wish to contact The Information Commissioner's Office:

Post:
The 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

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Cookies

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, your computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Email privacy notice

We (City of Wolverhampton Council) use GovDelivery as our email marketing provider. All data is processed in accordance with the UK Data Protection Laws (The General Data Protection Regulation 2016/679 and the Data Protection Act 2018). This means that we are the licensee and owner of the personal data processed by GovDelivery on our behalf. Personal data is stored securely by GovDelivery on servers located in the USA and all parties ensure that the personal data is adequately protected in accordance with Article 25 of the EU Directive 95/46/EC and UK Data Protection Laws. We take your privacy and the security of your information very seriously.

What we collect

We collect the following information from you:

  • Full name
  • Email
  • Postcode
  • Company name
  • School
  • Ward

What we do with the information we gather

We use this information to provide a service that allows us to engage with customers via email. Our promotional or marketing messages can benefit you by giving you information about our own services and those provided by approved third parties (such as companies or groups we work with).

Representative examples of the promotional or marketing messages which we may send you include but are not limited to:

  • information about activities and events we and other organisations provide
  • information on new services and features within services of interest
  • opportunities to do more business with the council online
  • promoting services that may interest you, including supporting families with young people, employment or training
  • giving you information on energy, heating or water saving services
  • telling you how you can get advice on setting up your own business or business growth
  • inviting you to take part in surveys
  • access to work programs or employment training or employment opportunities
  • activities to help bring communities together

Telling us about changes to your email information

You have the right to have inaccurate/outdated information amended, deleted or destroyed. If any of your email details change please tell us by emailing webmaster@wolverhampton.gov.uk or log in to your GovDelivery account and make the changes yourself.

How to opt out

You can opt out of receiving emails from us at any time by logging in to your GovDelivery account.  From here you can also manage your subscriber preferences.

The opportunity to opt out is also offered to you in each individual email campaign we organise via GovDelivery.

How to access your information

We will be as open as possible with you about the personal information we hold about you, and if something is wrong we want to work with you to put it right. You can use the contact details on this page to get in touch.

Finding out about the personal information we hold about you

UK Data Protection Law gives you a number of rights in relation to your personal information. You can find out about your rights, and get further guidance, on the ICO website.

You can ask us whether we are keeping personal information about you by using the details on this page to get in touch.

What we collect

We may collect the following information:

  • name and job title
  • contact information including e-mail address
  • demographic information such as postcode
  • preferences and interests
  • other information relevant to customer surveys and/or offers

What we do with the information we gather

We will use the information you have provided us with to understand your needs and provide you with a better service, and in particular for the following reasons:

  • internal record keeping
  • we may use the information to improve our products and services
  • we may periodically send promotional e-mails about new products, special offers or other information which we think you may find interesting using the e-mail address which you have provided
  • from time to time, we may also use your information to contact you for market research purposes
  • we may contact you by e-mail, phone, fax or mail
  • we may use the information to customise the website according to your interests

Remember you can manage your preferences or opt out of receiving emails from us at any time by logging in to your GovDelivery account.

Security

City of Wolverhampton Council is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.


 

Google Analytics

City of Wolverhampton Council currently uses Google Analytics to monitor traffic to and around our website. This helps us to provide the best possible user experience and encourages customers to use more cost-effective channels for accessing information on City of Wolverhampton Council services. Analytics also help us to identify if our digital channels are offering value for money.

How we audited these cookies

  1. Clear all existing cookies from the browser.
  2. Browse through navigation and pages within the website.
  3. Revisit the cookies tab in the browser to discover cookies that are used on the site.
  4. Use definitions of cookies provided by the analytics supplier.

Google Analytics uses the following cookies on our website:

  • pref: This cookie expires after 2 years and is considered as minimally intrusive. It is used to remember your language preferences if you choose to translate any pages. If you block this cookie - the language will default to English and the site will work normally. However, if you want to use the translate feature on more than one page at a time - you will need to enable the cookie.
  • __utma: This cookie expires after 2 years and is considered as minimally intrusive. Each unique browser that visits a page on the site is provided with a unique ID via the __utma cookie. In this way, subsequent visits to the website via the same browser are recorded as belonging to the same (unique) visitor. Thus, if a person interacted with the website using different browsers, the Analytics reports would track this activity under two unique visitors. Similarly if the same browser were used by two different visitors, but with a separate computer account for each, the activity would be recorded under two unique visitor IDs. On the other hand, if the browser happens to be used by two different people sharing the same computer account, one unique visitor ID is recorded, even though two unique individuals accessed the site.
  • __utmb expires after 30 minutes and __utmc expires at the end of your session: These cookies are considered as minimally intrusive.  Google Analytics uses these two cookies to establish a session. If either of these two cookies is absent, further activity by the user initiates the start of a new session.
  • _utmz: This cookie expires after 6 months and is considered as minimally intrusive. When visitors reach the site via a search engine result, a direct link, or an ad that links to the page, Google Analytics stores the type of referral information in a cookie. The parameters in the cookie value string are parsed and sent in the GIF Request (in the utmcc variable). The expiration date for the cookie is set as 6 months into the future.  This cookie gets updated with each subsequent page view to the site; thus it is used to determine visitor navigation within the site.

Google Analytics uses cookies to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

Google will not associate your IP address with any other data held by Google.

By using this website, you consent to the processing of data about you in the manner and for the purposes set out in this information. 

*Minimally intrusive - limited to first party websites with a low level of intrusiveness and risk of harm to individuals.

How will we keep our cookies policy up to date

City of Wolverhampton Council will aim to review what cookies are used on our site every 6 months. We will conduct the same audit process as outlined above and update this policy accordingly.

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