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Privacy policy statement

We design our privacy policy statement and procedures for managing personal information to satisfy legal requirements and meet the standards residents, service users, employees, customers, partners and other public authorities expect from us.
Whether you are visiting our website, contacting us by email, by phone or visiting a council office or council-managed location, we may collect some personal information about you. Whenever we collect your personal information, we want you to know that we will handle it responsibly and lawfully.

Why we collect your personal information

Some of the reasons why the council needs to collect your personal information are:

  • Maintaining the electoral register.
  • Protecting you or others by helping to detect, investigate, enforce and prevent crime and fraud.
  • Providing a service you or others have requested for.
  • Processing job applications, school places, housing applications and other requests you or others might make to us in our role as a local authority and employer.
  • Processing payments made to the council for council tax, debts, fines, rent and other services we offer.
  • Sometimes we are bound by law to collect personal information or support its collection because of legal reasons.
  • To provide healthcare services and safeguard the health and well-being, and environment of our residents.
  • Making payments to you and others for various welfare benefits, other benefits, salaries and compensation.
  • Investigating matters that concern or involve our residents.
  • Helping us plan to improve services.
  • Ensure that planning and building regulations are complied with.
  • When we act in a statutory role to issue licences, parking notices, provide education, social services and other statutory functions.
  • Studying trends and contributing to research that will benefit your health and well-being.
  • Improving your browsing experience when you use our website. Although we never use this information to identify you, it is still your personal information.

Whatever the reason is for collecting your personal information, we ensure there is an appropriate lawful basis in the General Data Protection Regulation and Data Protection Act, for doing so.

Lawful basis is legal paths in data protection law that regulate our approach and conduct when we collect your information.

Depending on the purpose for collecting your information, our lawful basis might be; consent, or contract, where you have made the information public, when the law says we must, to protect you or others when you or others are not in a position to provide consent, if the information is important for the public good and this reason is supported by a specific law, because of our role as a Local Authority responsible for employment, provision of health and social care, investigating your capacity to work, social security and protection, for reasons of public health, preventative or occupational medicine, preserving the record for the future, and to study patterns that will help us provide better services.

Personal information we collect

Here is a list of personal information we may collect.

  • Name, email ID and contact number
  • Location information
  • Internet protocol address

Some of the information we collect is considered sensitive and some is considered personal. Whether it is personal or sensitive, we will treat it with care and ensure that it is processed lawfully and responsibly.

Location API Services

Sandwell Holiday Activities website employs location and Maps API services to provide location-based information to its users. These services involve collecting and processing geolocation data, which may include your location information.

  • OpenRouteService
    OpenRouteService computes the distances and times of routes significantly faster using Time-Distance Matrix Matrices than using the directions API. This service determines the optimal routes for visitors to access the holiday activities. This data assists us in improving our service and providing a better user experience. We do not gather any personally identifiable information about you.
  • OpenStreetMap
    The OpenRouteService API uses free geospatial data provided by users and gathered from OpenStreetMap. OpenStreetMap prioritises local knowledge in contributing to and maintaining data, allowing mappers, GIS experts and engineers to submit data on geographic features.

How we collect your personal information

The council collects your personal information in the following ways:

  • Through contact or paper forms
  • When you talk to one of our officers by phone
  • Emails
  • When you visit any of our offices, buildings or council-managed locations.
  • Documents you give to us.
  • On CCTV

The laws that allow us to use your personal information

To be able to collect, process, share and retain your personal information, we rely on different laws that tell us what information we are allowed to collect, how we process this personal information, who we can share this information with and how long we can keep it for. Some of these laws tell us how to make sure people are safe and some of them tell us what information we are allowed to share with you. Here is a list of important legislation we rely on:

  • The Care Act 2014
  • The Public Records Act 1958
  • Children Act 2004
  • Children and Adoption Act 2006
  • Local Authority Social Services Act 1970
  • Education Act 2011
  • Children and Families Act 2014
  • Children and Social Work Act 2017
  • Children and Young Persons Act 2008
  • Foster Service Regulations 2011
  • Safeguarding Vulnerable Groups Act 2006
  • Registration Service Act 1953
  • Council Tax (administration and enforcement) Regulations 1992
  • Local Government Finance Act 1992
  • National Health Service Act 2006
  • The Health and Social Care Act
  • The Public Records Act 1967
  • The Local Government Act 1972
  • The School Governance Regulations 2012
  • The General Data Protection Regulation 2016
  • The Data Protection Act 2018
  • The Privacy and Electronic Communications Regulations 2003
  • The Race Relations Act 1976
  • The Disability Discrimination Act 1995
  • The Employment Relations Act 1999
  • The Mental Health Act 1983
  • The Mental Capacity Act 2005
  • The Human Rights Act 1998

Some laws we rely on are not listed here, but are connected with these laws and might contain directives not mentioned in these. We use relevant legislation to guide our conduct across the services and areas we are responsible for.

Who we may share your personal information with

When we process your personal information, we may share it with other organisations or individuals. The third parties we share your personal information with are determined by the service we are working to deliver to you or on your behalf, what the law says we must do and in some cases, fulfilling a request received from you to share your personal information. Below are the categories of third parties we may share your personal information with:

Public Authorities

  • Her Majesty’s Revenue and Customs and the Department for Work and Pensions
  • Law enforcement and the Courts
  • Some educational institutions
  • The National Health Service
  • Other Local Authorities and Public Authorities
  • Disclosure checking services
  • Members of Parliament and other elected representatives
  • Across Sandwell Metropolitan Borough Council’s services (on a need-to-know basis only)

Non-Public Authorities

  • Charitable organisations
  • Health care providers
  • Housing providers and Private Landlords
  • Adoption and fostering agencies
  • Employment agencies
  • Some educational institutions
  • Private Service Delivery organisations
  • Legal Counsel representing you or the Council
  • Utility providers

Before we share your personal information, we make sure that those receiving this information understand their legal responsibility, we ensure your information is shared securely, and we only share what is necessary. Sometimes, before we share your personal information we decide whether the decision to share it is appropriate. We also make sure there is a written agreement between the council and the third party.

How long we keep your personal information

Sandwell Council’s Retention Policy sets out the information held by the Council, and how long the associated records should be held. Sandwell MBC’s retention schedule has been developed and checked against the recommendations and best practise of the Records Management Society of Great Britain, the recommendations of the legislature, other local authorities, the relevant code of practice and, in certain cases, the statute of limitations in England and Wales.

Your rights under the law

Here are the rights you have and what they mean when we are in possession of your personal information.

Right to be Informed

We must tell you what information we need from you, why we need your information, the law that allows us to process your information, how we will process your information, if we share your information and with who we share it, the rights the law has allowed you to exercise, how long we intend to keep your information, how you can access your information with us, how to contact our Data Protection Officer, and how to contact the Information Commissioners Office.

Right of Access

You can request to see your personal information we hold. When you exercise this right, it is called a Subject Access Request. The law mandates us to respond within one month of receiving your request.

Right to Rectification

If you discover that the information we hold about you is incomplete or wrong, depending on the reason for collecting that information, we can correct the information without delay.

Right to Erasure

There may be occasions when we no longer need your information for the particular reason it was collected, or where you had to give us permission to use your information and you would like to withdraw that permission, and where we may be holding that information against the law. If this should ever happen, you are allowed to request that the council should securely remove this information from our systems.

Right to Restriction of Processing

Instead of asking us to remove your personal information from our systems, in cases where you have concerns that the information is incorrect, or no longer needed by us, or you question the lawful reason we gave for holding your information, you can ask us to limit the use of the information. It might also be that you want us to hold on to the information because you might need it for legal purposes.
When you make any request, we will investigate whether you are entitled to have your request granted. Even if we find out that you are not entitled to this right in a particular circumstance, we will still let you know before we continue to use your information.

Right to Data Portability

If you have had to give us permission to use your personal data (consent), or we have collected your personal data to process an employment contract and this personal data is processed automatically by our computers, you can request a copy of this data in digital format (i.e. in a format that another computer can read) and/or transfer to another local authority or organisation.
It is important to note that this right does not always apply as we provide most of our services as a public authority and the law allows us to be exempt from this right in most cases.

Right to Object

You have a right to ask us to stop processing information that refers to your particular circumstance. We will sometimes use this information because we are a public authority. But the law still allows you to request that we not continue to use the particular information. Where we refuse your request, we will respectfully give you our reasons.

Right to Reject Automated Decisions

The law allows you to refuse or reject the results from the automated processing of your personal information regarding health, economic status, personal preferences, interests, performance at work, reliability, behaviour, location, movements and anything that affects you legally. You also have the right in such a case, to ask that a human processes the information instead.
However, this right will not apply in many of the functions we perform in our role as a public authority and if the processing involves entering into a contract with you.

How to access your personal information with us

We realise on occasion, you might want to see the information we have collected about you, along with an explanation of the lawful basis we used to obtain and process it.

Such a request is called a Subject Access Request. You can do this by telling us verbally or in writing. Here is useful guidance to follow when you do this:

  • Decide what personal information you want us to look for. For example, an application you made for a school place
  • Then, tell us what you want, in person, by phone or in writing
  • Fill out any forms we ask for
  • Provide any form of identification we ask for

You can make a request to access your information by using this form or writing to the address below:

Go Play Sandwell, Corbett Street, Smethwick B66 3PX

Filming and photographs

During holiday activity events, we may use video and photographs to record these. At these events, we will display signage to tell you what we are doing. If you prefer not to be filmed or photographed at such events, you should tell the council officers at the event.

How to contact the Data Protection Officer & Information Commissioner’s Office

The council has a dedicated officer to make sure we respect your rights – this is the Data Protection Officer.

You can contact the Data Protection Officer in writing, by email or by phone.

Office of the DPO
Sandwell Council
West Midlands
B69 3DE

Email: dp_officer@sandwelldwell.gov.uk
Telephone: +44 12156 93172

If for any reason you are not happy with how we have handled your personal information or the response from our Data Protection Officer, you can contact the Information Commissioner’s Office (ICO).

They have the powers to ask us for information and we must cooperate with them.

You can contact the ICO in writing, by email or by phone.

Information Commissioner’s Office
Wycliffe House
Water Lane

Email: casework@ico.org.uk

Telephone: Call from within the UK at +44 30312 31113 (local rate) or +44 016255 45745 if you prefer to use a national rate.
Calling from outside the UK +44 16255 45745.

This privacy policy was last reviewed on 17/02/2023.