Privacy and Cookies Notice

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

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, 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. 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 collection of unique tax reference numbers to determine the employment status of contractors and 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.

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, address, email address, telephone number, date of birth)
• Identification numbers (e.g. NHS number, National Insurance number, Unique Tax Reference 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
• licences or permits held
• student and pupil records
• business activities
• case file information
• birth/death data provided by/to the office of national statistics
• Vehicle Registration details

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.

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), Driver and Vehicle Licensing Agency (DVLA), Department for Environment, Food & Rural Affairs (Defra)
• 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 licence 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), Driver and Vehicle Licensing Agency (DVLA)
• 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):

• The Cabinet Office as part of the National Fraud Initiative (NFI)
• Department for Work and Pensions
• Other local authorities
• Her Majesty's Revenue & Customs (HMRC)
• The Police
• Health bodies (NHS Trusts, GPs)
• Wolverhampton Homes
• Credit Reference Agencies (and to recover debt)

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

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 and other public bodies. For example; the Department for Work and Pensions (DWP), Department for Education (DfE), 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. 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 Cabinet Office as part of the National Fraud Initiative (NFI)
• 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.

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:

• Public Health
• Children and Young People
• Adult Social Care
• Potentially Violent Persons Register

Automated decision making means that a decision-making process is totally automated and excludes any human influence on the outcome.

Profiling is where decisions are made about you based on certain things in your personal information, e.g. your health conditions, a social care status.

Article 22(1) of the GDPR limits the circumstances in which the Council can make these automated decisions or profile you to the following:

• You have entered into a contract with the Council and it is necessary for the performance of the contract
• A Union or Member state law applies
• You have given consent

If and when the Council uses your personal information to profile you, in order to deliver the most appropriate service to you, you will be informed.

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 2018/ 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 protection 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.

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.

• 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.
• 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 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.

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/

The Council publishes responses to Freedom of Information (FOI) requests it receives on a Disclosure Log

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

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

This privacy notice provides you with information about what we do with your personal data (information that is about you and identifies you).

The Revenue and Benefits Service administer housing benefit, council tax support and discretionary housing payments, council tax discretionary discounts, help with housing costs through household support fund, business grants, the assessment, billing and recovery of council tax, business rates, business improvement district levies and recovery of sundry debts.

Information we need

We only collect the information we need about your personal, household and financial information to enable us to carry out one or more of the services outlined above. Types of information about you and members of your household could include but is not limited to:

• name
• address
• date of birth
• national insurance number
• telephone number
• email address
• immigration Status

information relating to your income including state benefits, earnings, pensions, capital, property, bank / building society account details, employers name and address, landlords / agent name and address, rent

We also collect, exchange and share some information with third parties, this could include but is not limited to your landlord, the Department for Work and Pensions (DWP), Her Majesties Revenues and Customs (HMRC), Valuation Office Agency (VOA) etc.

Processing your personal data

The following acts allow us to collect, store and process your personal data:

• Local Government Finance Act 1992
• National Non-Domestic Rates under the Local Government Finance Act 1988
• Housing Benefit Regulations 2006 and Local Government Finance Act 2012
• Social Security Administration Act 1992
• Digital Economy Act 2017, part 5, Chapter 3

Using your personal data

Will use your personal data to administer housing benefit and council tax support and discretionary housing payments, in the assessment, billing and recovery of council tax, business rates, business improvement district levies and sundry debts.

Sharing your personal data

Your personal information remains confidential; however, some information may be shared, matched or obtained from other internal council departments, or with external partners and agencies outside of the Council to:

• Ensure that the information is accurate
• Prevent, detect and prosecute fraud
• Protect public funds
• Recover debts owed to the council.

Examples of external agencies include:

• Other Local Authorities
• Magistrates and other Courts
• Enforcement Agents
• Department for Works and Pensions
• Her Majesty’s Revenues and Customs
• Valuation Office Agency
• The Home Office
• Police
• The Rent Officer
• The Office for National Statistics
• Employers
• Landlords / Letting Agents - If your Housing Benefit is paid directly to your landlord, we may share payment details (amounts and dates) with them as we have to provide this information
• Solicitors
• Mag:net Solutions Limited
• Transunion
• Experian Ltd
• Equifax Ltd

Sometimes we may use the information you have provided for research and analysis to help us better deliver services and share this with our partners. We remove any personal information that may identify you as an individual or household and only use and share anonymous statistics.

For further information relating to sharing your information with credit reference agencies, please visit the link below.

visit Experian.com

City of Wolverhampton Council also uses the services of the following companies to process information on its behalf:

• IEG4 Ltd
• NEC Software Solution
• Govtech Solutions Ltd
• Analyse Local Ltd
• Inform CPI
• Critiqom
• Civica UK Ltd

City of Wolverhampton takes part in the National Fraud Initiative see the link for details:

visit www.gov.uk

Retention Policy

We will keep your information for as long as it is required by us or other regulatory bodies in order to comply with legal and regulatory requirements or for other operational reasons. In most cases this will be for a minimum of six years after a claim has closed, or an account ended with no outstanding balance; a sundry debt being repaid in full; or a council tax or business rates account ending where there is no outstanding balance.

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.

Your Rights

You have the right to:

• request a copy of your information (known as a subject access request),
• request rectification or erasure of your information,
• request a restriction on the processing of your information,
• object to processing of your information, and
• complain to the Information Commissioner’s Office about the way City of Wolverhampton Council processes your information.

If you require further information about the use of your data or would like to exercise any of the above rights, please contact:

Data Protection Officer

Email: data.protection@wolverhampton.gov.uk

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

Telephone: 01902 554498

For further information relating to how City of Wolverhampton Council processes your personal data please visit the main website City of Wolverhampton Council website.

Fair Processing Notice Data Matching

You may also want to see our pages about:

Housing Benefits and Council Tax Reduction

Business Rates

Council Tax