The following privacy notice tells individuals what to expect when they have been registered as a potentially aggressive and violent person on the council’s Caution Register

This notice explains how personal information is going to be used, what it is used for, who it might be shared with and why and for how long it is to be kept.

The council (CBC) is fully committed to complying with The Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

We ensure that your personal data is processed fairly, lawfully kept safe and secure and retained for no longer than is necessary.

The Data Protection Officer for CBC is Head of Legal, Democracy and HR.

Crawley Borough Council is registered as a Data Controller with The Information Commissioner’s Office (Registration Number Z5327706).

If you have any concerns or questions about how we look after your personal information please contact the Data Protection Officer.

• Your name
• Your address
• Contact details
• Notes and other information we obtain directly from you about actual or potential violent behaviour - for example we may make a note of the words you said if you threatened a member of staff
• Notes and information we obtain from any council department or third parties in relation to actual or potential violent behaviour
• Photographs/images recorded by the council’s CCTV systems

The Council owes a duty of care to its employees under the Health and Safety at Work etc. Act 1974 and has a legal duty under RIDDOR – Reporting of injuries, Diseases and Dangerous Occurrences Regulations 2013 – to record and report incidents of work related violence.

In the event or likelihood of this happening, personal information about you will be collected to assess the risks to our employees (including the risk of reasonably foreseeable violence) and retained on a Potentially Violent Persons Register or Caution Register for short.

We will use the information we hold about you for the purposes stated, in general this will be to assess the risks to our employees. We will therefore use the information we hold about you on the Caution Register to assess if there is a risk to our staff when they contact or visit you.

We collect this information via a number of methods including:

• Collecting information from those who you may have been violent or aggressive towards
• Council employees who have completed an incident report form
• Other sources  we may receive information about you form other organisation, agencies or service providers

We may receive information about you for a legal reason.

Council staff who look after the Caution Register and staff who are working with you or have a need to contact/visit you will have access to the data on the Caution Register. Access is controlled and limited to those who need the information in order to carry out their duties safely.

In order to prevent unauthorised access or disclosure of the details on the Caution register suitable controls are in place to limit the number of staff who can see the register.

Records will not be visible for general viewing.

We may share your information with other agencies, organisations and contractors that may come into direct contact with you. We do this to assess the risks to their employees as part of their work.

Under UK Data Protection Laws we also have a duty to pass information to third party organisations such as the Police if there has been a crime committed.

Where we feel that others are at risk, we will share the information without your consent.

When sharing information we do so in line with UK Data Protection Laws and any agreed information sharing protocols.

We will not share data with third-parties for marketing purposes.

Any information gathered will be kept in line with statutory requirements as set out above. Personal data will not be retained for longer than necessary in relation to the purposes for which they were collected.  Retention periods will be in line with the Council’s Policy on the Management of the Register of Aggressive & Potentially Violent persons (caution register).
Information held on the Register will be subject to periodic review.

All the information we collect is stored securely on our IT systems. All information we hold about you is confidential.

You have the right to:

1. Be informed of data processing (which is covered by this privacy notice)
2. Access your personal information (known as a Subject Access Request)
3. Have inaccuracies corrected
4. Have information erased
5. Restrict processing
6. Data portability
7. Intervention in respect of automated decision making/profiling
8. Withdraw consent for us to use your data, if we have no legal reason to do so
9. Complain to the Information Commissioner’s Office (see below)

Please note that that these rights do not apply in all cases. To exercise any of these rights please contact the Data Protection Officer.

If you have any worries or questions about how your personal information is handled please contact our Data Protection Officer.

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

• Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire DK9 5AF
• Tel:  0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
• Visit ico.org.uk
• Email casework@ico.org.uk