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Processing personal data

Bedfordshire Police, Cambridgeshire and Hertfordshire Constabularies (BCH) process personal information for a variety of reasons which are not related to law enforcement.

For example we process personal data for the following lawful purposes to;

  • assist us in meeting our legal obligations as employers,
  • manage contracts with those who supply us with goods and services,
  • help us support those who we come into contact with, which can be done by obtaining their consent, or due to our public task, this includes processes to improve the service we provide the public.

If there is a statutory or contractual obligation to provide data for a non-law enforcement purpose, you will be advised at the point of collection. For non-law enforcement processing this will usually only be in relation to recruitment or employment where the information is necessary in order to perform a contract or take steps at the request of the data subject, before entering a contract. If the necessary data is not provided it may affect your application or our ability to enter into a contract with you.

View Part 2 of the general processing under the Data Protection Act 2018.

Personal information we hold

In order to carry out the purposes described above, BCH may obtain, use and disclose personal information relating to a wide variety of individuals including;

  • our staff, officers, volunteers, agents
  • temporary and casual workers
  • suppliers
  • complainants
  • correspondents
  • litigants and enquirers
  • relatives, guardians and associates of the individual concerned
  • advisers, consultants and other professional experts
  • victims (current, past and potential)
  • former and potential members of staff
  • pensioners and beneficiaries. 

Types of personal information we process

The type of personal information we hold varies depending on the reason a person has had contact with us, but it may include;

  • your name and address
  • fingerprints, DNA or photograph
  • family, lifestyle and social circumstances
  • education and training details
  • employment details
  • financial details
  • goods or services provided
  • racial or ethnic origin
  • political opinions
  • religious or other beliefs of a similar nature
  • trade union membership
  • physical or mental health or condition
  • sexual life
  • offences and alleged offences
  • criminal proceedings, outcomes and sentences
  • sound and visual images
  • references to manual records or files
  • information relating to safety and health
  • complaint, incident, civil litigation and accident details.

We will use the minimum amount of personal information necessary to fulfil a particular purpose. Your personal information may be held on a computer system or as a paper record, such as in a physical file or a photograph.

Research participant information

Hertfordshire Constabulary has a statutory duty under the Police Reform and Social Responsibility Act 2011, to obtain the views of service users and residents on policing in their area.

Following an interaction with Hertfordshire Constabulary we may process your contact details to invite your participation in a survey.

Data and purpose

If you respond to an invitation to participate in a survey we will match your responses with the incident or crime record held on our own police systems. If you advised us of your ethnicity or the fact you have a disability at the time of reporting the incident this data will be matched with your response.

This type of personal data is sensitive in nature and is referred to as special category data. Access to your data will be limited to authorised members of staff for research purposes.

Data will be held in an identifiable format for a two-year period after which time it will be anonymised. The only identifying information associated to your feedback will be your mobile number and the crime or incident reference number.

Please note – we had previously advised that data would be held in an identifiable format for 1 year. Should you wish to withdraw your consent and have your data deleted you can do so at any time, as explained in the consent section below.

Any data used in organisational learning or analysis produced from the survey responses will be anonymised and therefore will not contain any personal data.

If you are provided support through one of our victim care providers you will only be asked to provide feedback on the service if you consent to doing so. Any feedback provided will be used to assist us in ensuring the effectiveness of victim services provided within Hertfordshire.

Legal basis of processing

The lawful basis for the processing of your contact details is Article 6 (1) (e) of the GDPR, as it is necessary for the performance of our public task to obtain views from crime victims and members of the community.

We collect data in our surveys for research purposes only however, if you raise an issue of concern or complaint this would be recorded separately and processed under Article 6 (1) (e) for the performance of our public task. Research participant answers will not be used by any entity as an aid for sales.

Consent

The lawful basis for the processing of your responses will be Article 6 (1) (a) consent.

We will rely on your explicit consent for the processing of any special category personal data and it should be noted as explained above that we will process special category data you have already given us if you consent to completing a survey.

We therefore rely on Article 9 (1) (a) explicit consent for any special category personal data that you provide in your response or which you provided to us when reporting the incident.

You have a right to withdraw your consent at any time by emailing.

Data processors

Hertfordshire Constabulary use Snap Surveys to host surveys on our behalf. We also use Upland Software to conduct SMS or online surveys on our behalf.

If you have been a victim/witness of a crime or incident you may be contacted by Hertfordshire Constabulary telephone researchers to ask if you consent to participating in a victim satisfaction survey. The answers provided by participants will be captured in a survey hosted by Snap Surveys.

If you contact us, or you are a victim of crime you may receive an SMS invitation to participate in an SMS text message survey. If you agree to participate in our SMS text messaging survey by indicating yes to our invitation you consent to receiving our survey by text.

SMS texts cost standard network rates. Please seek the bill payers’ permission before participating in the survey.

You can ask to be removed from future invitations by replying STOP or by email to echo@herts.pnn.police.uk. You will not be sent another survey invitation unless/until you expressly opt in to providing us feedback at another time.

The privacy policies for Snap Survey (opens in a new window) and Upland Software (opens in a new window) are available on their websites.

Rights

Research participants have a right to access the personal information we have collected about them and to have any information that is inaccurate or incomplete rectified.

Research participation is voluntary, consent can be withdrawn at any time and individuals can request that their personal information is deleted.

For more information regarding your rights please refer to our data rights page.

Retention

The data collected from surveys will be held for a two-year period after which time only anonymised data will be held.

WeProtect

WeProtect delivers instant victim referral for police forces and front-line service providers working to tackle domestic abuse across the UK. All victims referred through WeProtect benefit from early legal intervention, ensuring that the relevant course for protection is put into action without delay.

The WeProtect application has been developed by Morgan Wiseman Solicitors as part of the Domestic Abuse (DA) Alliance partnership.

Hertfordshire Constabulary are participating in the DA Alliance partnership and will be offering the WeProtect service to victims.

The aim of this service is to reduce repeat victimisation by combining legal services with referral pathways into agencies that can support their recovery and help break the cycle of domestic abuse. 

Data and purpose

Attending officers will ask victims of domestic abuse if they would like to be referred to the DA Alliance by the officer submitting their details through the WeProtect application. 

The details that will be required are:

  • Name
  • Contact number
  • Best time to be contacted
  • Were there any previous incidents (yes or no answer)
  • Are there any current bail conditions (yes or no answer)

The submitted data is received by the First Line Response Team at Morgan Wiseman Solicitors (MWS). They will contact you at the preferred time and subject to your consent a fact file and Legal Aid assessment will be completed to assess Legal Aid eligibility and the best legal course of action.

Should you wish to proceed with the recommended course of action you will then be transferred directly to/or called back by a member of the Second Line Response Team (legal caseworkers). This team will prepare documents/evidence to further progress the course of action.

If you qualify for Legal Aid (as assessed by the First Line Response Team) you may be required by the Legal Aid Agency to make a small contribution towards the overall costs (assessed based on your disposable income). Note that this charge has to be paid directly to the Legal Aid agency by yourself. It is possible that you will not qualify for Legal Aid and should this be the case MWS will advise accordingly.

The WeProtect service refers victims to MWS as they have developed the DA Alliance Partnership however, you can withdraw consent at any stage of the process and are free to seek legal advice or assistance from any other solicitor.

Legal basis of processing

Consent

The lawful basis for the referral is Article 6 (1) (a) of the GDPR, as it is reliant solely on victim consent.

You have the option to withdraw consent throughout the process.

This can be done using the following helpline contact number:

Victim support line: 0800 101 7110. 

Rights

Once a referral has been made the data is held by MWS who are data controller and will be responsible for providing your right of access to the personal information submitted and to have any information that is inaccurate or incomplete rectified.

For more information regarding your rights please refer to the Morgan Wiseman privacy policy.

Retention

MWS will hold data in line with their retention schedule, should you decide not to proceed with their legal representation your data will be anonymised and held only for statistical purposes. Anonymised data is not personal data as it is no longer possible to identify any individuals.

Where we get personal information from

To carry out the purposes we have described, we may obtain personal information from a wide variety of sources, including;

  • HM Revenue and Customs
  • legal representatives
  • solicitors
  • courts
  • voluntary sector organisations
  • Independent Office for Police Conduct
  • Her Majesty’s Inspectorate of Constabulary
  • auditors
  • Police and Crime Commissioners
  • central government, government agencies and departments
  • relatives, guardians or other persons associated with an individual
  • current, past or prospective employers of the individual
  • healthcare, social and welfare advisers or practitioners
  • education, training establishments and examining bodies
  • business associates and other professional advisors
  • employees, officers and agents of BCH
  • suppliers/providers of goods or services
  • persons making an enquiry or complaint
  • financial organisations and advisors
  • credit reference agencies
  • survey and research organisations
  • trade union, staff associations and professional bodies
  • local government
  • voluntary and charitable organisations
  • Ombudsmen and regulatory authorities
  • the media.

How we handle personal information

We handle personal information according to the requirements of Part 2 of the UK Data Protection Act 2018, which applies the GDPR standards for processing of data considered as general data. Your personal information, held on our systems and in our files, is secure and is accessed by our staff, police officers, contractors and data processors working on our behalf, outsourced providers in accordance with their contract and volunteers when required to do so for a lawful purpose.

We will ensure that your personal information is handled fairly and lawfully.  We will strive to ensure that any personal information used by us or on our behalf is compliant in terms of accuracy, relevance, and adequacy, is not excessive and is kept as up to date as possible and is protected appropriately.

We will review to ensure it is still required and is lawful for us to continue to retain it and when no longer required for any purpose detailed in this notice, we will securely destroy it.

Who we share personal information with

To carry out the purposes described, BCH may disclose personal information to a wide variety of recipients, including those listed from whom personal data may have been gained. This may also include;

  • support services for victims and offenders
  • bodies or individuals working on our behalf such as IT contractors or survey organisations
  • local government
  • central government
  • Ombudsmen and regulatory authorities
  • the media
  • healthcare providers. 

Disclosures of personal information outside of an already established contractual or legal obligation will be made on a case-by-case basis, only relevant information specific to the purpose and circumstances, will be disclosed and with necessary controls in place.

BCH will also disclose personal information to other bodies or individuals when required to do so, this could be under an act of legislation, by a rule of law, or by court order. This may include;

  • child maintenance service
  • children and family courts services
  • Home Office
  • courts
  • any other regulatory body who can demonstrate that there is a legitimate purpose for the processing of your personal data. 

BCH may also disclose personal information on a discretionary basis for the purpose of, and in connection with, any legal proceedings or for obtaining legal advice.

How long we keep personal information

BCH holds your personal information as long as is necessary for the particular purpose/s for which it is processed.

The minimum standards for retention of personal data held by BCH are in line with the National Police Chief’s Council (NPCC) Retention Schedule.

Information rights

A key area of change in the new Data Protection Act 2018 relates to individuals’ rights.

The law enhances existing rights by clarifying and extending them and introduces additional rights. However, your information rights are dependent on the purposes for which data was collected and processed.

Visit our information rights page for further information about your rights.

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