Data Protection privacy notice

The Council uses personal information to:

• Deliver services and support to residents and businesses
• Help investigate any concerns or complaints including concerns or complaints raised by councillors or MPs on behalf of constituents
• Plan and manage council services, including checking on the quality of services, developing future services and keeping track of spending
• Carry out the Council’s regulatory, licensing and enforcement functions, for example. planning permissions, trading standards and food safety
• Deal with payments, grants, benefits and other financial transactions
• Check an individual’s identity or entitlement to personal information
• Carry out research and consult with residents and people who use council services
• Fulfil our statutory obligations such as protecting vulnerable children and adults
• Understand more about the nature and causes of disease and ill-health in the area and to improve the health of the population we serve (see the separate Public Health privacy notice).

The Integrated Commissioning Unit (ICU) is a joint commissioning team for Portsmouth City Council and NHS Portsmouth Clinical Commissioning Group. The ICU aims to deliver efficiencies across departments and improve outcomes for vulnerable adults, children and families in Portsmouth through the commissioning of whole life pathways, joining up the delivery of services, and adopting a strategic approach to the wider determinants of health and wellbeing.

The Council has entered into an agreement with Portsmouth CCG under Section 75 of the NHS Act 2006 (as amended), the Secretary of State can make provision for local authorities and National Health Service (NHS) bodies to enter into partnership arrangements in relation to certain functions, where these arrangements are likely to lead to an improvement in the way in which those functions are exercised.

The staff who work in the ICU will jointly process health and care data with staff from Portsmouth Clinical Commissioning Group.

The Council provides various services to the public and local businesses.  We have to hold the details of the people who have requested a service in order to provide a service to them. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who receive a service to carry out a survey to find out if they are happy with the service they received.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

The Council uses information about people who use Council services for research, planning and statistical purposes, to monitor the performance of local services and to evaluate and develop those services. Statistics are used in such a way that individuals cannot be identified.

When you telephone the Council, including when you call the City Helpdesk, your call may be recorded. The reasons for this include to help with staff training and to maintain records of conversations, to help with the detection, investigation and prevention of crime. We will tell you if your call is being recorded.

The Council uses Next Generation Text Services, NGT Lite, to provide text call services. NGT Lite can be used in parallel with a phone call to send and receive telephone conversations via text.

The Council also uses a third party telephone interpretation service to help callers communicate across different languages.

Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with the Council’s information security policies.  Email monitoring or blocking software may also be used.

The Council uses a secure email service for sending personal data outside the Council. Other organisations are responsible for ensuring that any email that is sent to the Council is secure and within the bounds of the law.

If you need to send us sensitive information, we recommend using our secure online forms (where provided) or the postal service.

Email addresses and preferences

Portsmouth City Council uses a govDelivery, email marketing platform supplied by Granicus to send communications and to manage the email addresses and preferences of My Portsmouth Updates subscribers. govDelivery is a secure platform that adheres to the council’s information security standards and data processing policies and complies with the European Union-US Privacy Shield framework.

Granicus and govDelivery does not use your email addresses or preferences for anything other than providing the service to the Council and will not pass on your email address for promotional purposes to any other person or organisation (third parties).

Read the Granicus Privacy Shield statement online

Information collected for use with govDelivery services will be only be used for the purpose of keeping you informed about topics that you have told us you are interested in. Subscribers to ‘My Portsmouth Updates’ can indicate their chosen email topics when they sign up for the service online. You will not be added to any mailing list or receive any mail unless you have chosen to do so.  You can unsubscribe from this service at any time.

The council uses a range of social media services to publicise council news, stories, offers and events and to receive comments and feedback from residents including through direct messages, which are private, and through posts which are public to other social media users.

The information you provide via social media is subject to the social media service providers’ privacy notices and policies. Any information you post on the council’s social media platforms is also subject to the council’s social media moderation policy.

When we receive a complaint from a person we generally make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy, which is available on request. Information relating to a complaint will normally be retained for up to 7 years from when the complaint is resolved.

It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

When individuals apply to work at the Council, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Disclosure & Barring Service we will not do so without informing them beforehand unless the disclosure is required by law.

Personal information about unsuccessful candidates will be held for 6 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.

Once a person has taken up employment with the City Council, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment or in order for the Council to meet a legal obligation, for example inspection by a regulatory body such as the Care Quality Commission or Ofsted and statutory reporting to the Department of Health or Department of Education.

Once their employment with the City Council has ended, we will retain/delete the file in accordance with the requirements of our retention schedule.

The general data protection regulation (GDPR) states that the council should not hold personal data longer than is absolutely necessary. Our corporate retention schedule tells you how long we keep the records we work with, what we do with them at the end of that time, and the reasons why we do those things.

You can find out more about it on the corporate retention schedule page.

When you visit the Council’s website www.portsmouth.gov.uk to view a page or download a form, we will collect the following information if you accept analytical cookies:

• the domain name (if available) and IP address from which you accessed our site
• the date and time you visited
• the pages you viewed
• the type of browser and operating system you used

We do this to find out things such as the number of visitors to the various parts of the site which helps us to improve our website service. This information is only processed in a way which does not identify anyone.

We use a third party service, Google Analytics, to collect this information. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

We will make it clear to you whenever we collect any personal information through our website and will explain what we intend to do with it.

You can find out more about how we use cookies on our websites and how we protect the privacy of people who use our websites by reading the Council’s Cookies and Privacy Policy.

Portsmouth City Council will process your personal information appropriately and legally in accordance with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.

Information is held on a secure server which is only accessible to staff within the Portsmouth City Council’s Public Health Intelligence Team. These staff members are trained in data protection/information governance.

We have processes to securely protect these records and we only keep information for as long as is necessary and in accordance with the law; and which is consistent with the data access agreement between UK Health Security Agency and Portsmouth City Council

We use data processors who are third parties who provide elements of services for us. This includes Microsoft UK who supply Microsoft Office 365 cloud based services to the council. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us.

They will hold it securely and retain it for the period we instruct. If it is necessary for us to transfer your personal information outside of the UK this will only be done in accordance with the UK GDPR.

Records are kept in line with the Council’s retention policy and we will not keep your information longer than necessary.

The Council has a duty to ensure that all council staff and volunteers, and companies or persons providing services or undertaking contracts on behalf of the Council create full, accurate and reliable records of their actions. The Records Management Policy sets out how those records should be managed to ensure they are kept safe and to meet the demands of the law and of regulatory bodies.

You can view the corporate retention schedule here.

Individuals can find out if we hold any personal information by making a ‘subject access request’. If we do hold information about you we will:

• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form.

To make a request to the City Council for any personal information we may hold you need to put the request in writing addressing it to:

Data Protection Officer

Portsmouth City Council

Civic Offices,
Portsmouth,
PO1 2AL

Request forms are available to print and complete:

• For access to Children’s Social Care records, please complete the Access to personal records form.
• For access to Adult Social Care records, please refer to the privacy statement for Adult Social Care which explains how you can access your personal information.
• For access to records relating to any other service, please complete the Data subject access request form.

Please bring your completed request form to ground floor reception at the Civic Offices, along with:

• a form of identification (passport or driving licence)
• a recent bank statement or utility bill

The following may also be helpful:

• any former names
• former addresses
• any reference numbers given to you by Council services

If you cannot come to the Civic Offices, have difficulty making a written request, or don’t have any form of identification please use the contact details below to discuss your request with us.

If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the Data Protection Officer.

Please be aware that we would not let you see any parts of your record which contain:

• Confidential information about other people; or
• Information that a professional thinks will cause serious harm to your or someone else’s physical or mental wellbeing; or
• If we think that a crime may be prevented or found out by disclosing information to you.

You also have the right to see CCTV images of yourself and be provided with a copy. For further information and details of exceptions, see the Council’s Community Safety and CCTV page.

You can ask to see CCTV images by making a subject access request using the Data subject access – request form or as detailed above.

In many circumstances we will not share or disclose personal information without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.

We may pass relevant information, such as your contact details, on to different parts of the council so that we can co-ordinate our services properly. For example, housing will tell the council tax team when someone has a change of address.

Where we do not directly provide a particular service, we may need to pass your information on to the company or organisation which provides services on our behalf.

We use a number of commercial organisations and systems suppliers to either store personal information or to manage it on our behalf.

We also have agreements in place with partner organisations, including NHS organisations and the police to share information where this will benefit individuals or the local community.  We will usually obtain your consent to do this. Follow the link for the Portsmouth Information Sharing Framework, which sets out the conditions under which we will share information with other organisations

We may pass your information to other agencies or organisations as allowed or required by law, for example to enable them to carry out their statutory duties or where it is necessary to prevent harm to yourself or other individuals.

We may be required by law to disclose your personal information without your consent for the purposes of preventing or detecting crime/fraud or apprehending and prosecuting offenders (for example to the police, Cabinet Office, Department for Work and Pensions or as part of the National Fraud Initiative) or where we have a statutory duty to do so. For more information follow the link to read our National Fraud Initiative page.

Sometimes we are required to give personal information to a court, for example for child protection purposes and in connection with mental health law.

Data processors are third parties who provide elements of our services for us, such as IT systems suppliers and market researchers who handle or collect personal data on behalf of the Council. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from the Council or approved sub-contractors. Data processors are required to hold any personal information securely and to retain it for the period we instruct.

We take any complaints we receive very seriously. Please bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate.

You should let us know if you disagree with something written in your record. We may not always be able to change or remove the information. However, we will correct factual inaccuracies and may include your comments in the record.

We are happy to provide any additional information or explanation about how the City Council collects and uses personal information.

Any complaints, queries or requests should be sent to the Council’s Data Protection Officer.

Email: foi@portsmouthcc.gov.uk

Telephone: 023 9282 2251

For independent advice about data protection, privacy and sharing issues, you can contact the Information Commissioner’s Office (ICO) at:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 (if you prefer to use a national rate number).

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

If you want to request details of our privacy policy and how we collect and use personal information, you can write to:

Data Protection Officer
Portsmouth City Council
Civic Offices,
Portsmouth,
PO1 2AL

Email: DataProtection@portsmouthcc.gov.uk

Telephone: 023 9282 2251

There are additional privacy notices that apply to council services, as follows:

• Adult social care privacy notice
• Adult Care and Public Health
• Allegations Against Persons in Positions of Trust
• ASB CCTV privacy notice
• Children and Families Services privacy notice
• Cleaner Air Zone privacy notice
• Community youth play services privacy notice
• Coronavirus – Public health COVID-19 testing data privacy notice
• Coronavirus – sharing vulnerable persons’ information
• Coronavirus – test and trace data privacy notice
• Council Tax “Energy” Rebate Privacy notice
• Data Sharing Agreement – Portsmouth City Council and Ministry of Housing
• Elective Home Education
• Education privacy notice
• Energy Bills Support Scheme (EBSS): Alternative Funding (AF) and Alternative Fuel Payment (AFP) – Privacy Notice
• External partners register for data sharing agreements privacy notice
• Housing management privacy notice
• Housing management – garage and parking privacy notice
• Housing needs advice and support privacy notice
• Kennels privacy notice
• Leaseholder services privacy notice
• Neighbourhoods privacy notice
• Parking privacy notice
• Photographic Consent
• Planning Policy Consultee Database – Privacy Notice
• Portsmouth Safeguarding Children Board privacy notice
• Prevent privacy notice
• Private sector housing privacy notice
• Public health privacy notice
• Public health privacy notice – birth records
• Public health privacy notice – death records
• Public health privacy notice – national child measurement programme
• Recruitment privacy notice
• Revenues and benefits service privacy notice
• School admissions privacy notice 
• Supported housing privacy notice
• Supported housing privacy notice (easy read)
• Telecare service privacy notice
• Tell Us Once (TUO) privacy notice
• Temporary recruitment agency privacy notice
• Voting and elections privacy notice