Data Protection Statement
PRIVACY NOTICE(OFFENDERS)
This statement confirms the commitment of TONBRIDGE & MALLING SAFER TOWNS Business Crime Reduction Partnership Exclusion schemes and explains why TONBRIDGE & MALLING SAFER TOWNS processes the personal data of specific individuals (offenders) and the lawful basis for that processing.
It describes the kind of information about Offenders that TONBRIDGE & MALLING SAFER TOWNS processes and what it does with that information.
1. Who we are and what we do – the role of TONBRIDGE & MALLING SAFER TOWNS is explained in our website www.tmsafertowns.org.uk
Contact details: TONBRIDGE & MALLING SAFER TOWNS,
Community Safety Unit.
Tonbridge & Malling Borough Council
Gibson Drive
West Malling,
Kent.
ME19 4LZ
safertowns@gmx.com
2. TONBRIDGE & MALLING SAFER TOWNS’s Data Controller is responsible for ensuring its compliance with current Data Protection law and can be contacted at the above address or email account. The Scheme is registered with the Information Commissioners Office as a Business Crime Reduction Partnership.
3. Purpose of processing personal data
Members of TONBRIDGE & MALLING SAFER TOWNS have the right to protect their property, staff and customers from crime and anti-social behaviour and to exclude from their premises any individuals who are proven threats to their property, staff or customers or disrupt the peaceful enjoyment that their customers expect from the goods and/or services that our Members offer. TONBRIDGE & MALLING SAFER TOWNS processes Offenders’ personal data for the management of its Exclusion Scheme on behalf of its Members, to inform Members of an offender’s modus operandi, to collate intelligence on criminal activity within the area of the TONBRIDGE & MALLING SAFER TOWNS operation and to contribute to legal proceedings against offenders where appropriate.
4. TONBRIDGE & MALLING SAFER TOWNS’s area of operation, and its Exclusion Scheme, is within the boundaries of the Borough of Tonbridge & Malling.
5. Types of processing
TONBRIDGE & MALLING SAFER TOWNS undertakes the following types of processing of personal data of Offenders:
a. Data collection; see Sources of personal data below;
b. Data storage; storage of Offenders’ data in a facility independently certified as secure to a high standard;
c. Data retention; see Data Retention period below;
d. Data collation; associating individual Offenders with multiple incidents, and with other Offenders;
e. Data sharing; as defined in Recipients, or categories of recipients, of personal data below;
f. Data deletion; see Data Retention period below;
g. Data analysis; of de-personalised data for historical comparisons etc.
6. Lawful basis of processing
TONBRIDGE & MALLING SAFER TOWNS Members’ ‘legitimate interests’ provides the lawful basis on which it may process specific items of Offenders’ personal data for specific purposes without Offenders’ consent. TONBRIDGE & MALLING SAFER TOWNS has assessed the impact of its processing on Offenders’ rights and freedoms, has balanced these with its Members’ own rights, and has concluded that its Members’ rights prevail over Offenders’ rights in this specific matter. Therefore, for the purposes of the management of its Exclusion Scheme on behalf of its Members, to inform Members of an offender’s modus operandi, to collate intelligence on criminal activity within the area of TONBRIDGE & MALLING SAFER TOWNS’s operation and to contribute to legal proceedings against Offenders where appropriate, Members’ legitimate interests constitute TONBRIDGE & MALLING SAFER TOWNS’s lawful basis for processing Offenders’ personal data without requiring consent.
6. Categories and types of personal data processed
a. Offender’s name and facial image and any relevant information about the nature of his/her activities; the purpose of this processing is to enable Members to identify Offenders in order to submit reports about them, to include them in a list or gallery of excluded persons (if appropriate and in line with TONBRIDGE & MALLING SAFER TOWNS Rules & Protocols), and to provide information about them which may be necessary to protect the property and personal safety of Members and their staff, customers etc. This data may be shared among Members and other agencies that have a legitimate interest.
b. Offenders’ postal and email addresses, telephone number(s) and other contact details; the purpose of this processing is to enable TONBRIDGE & MALLING SAFER TOWNS to communicate with Offenders from time to time, for example to send warning letters, confirmation of exclusions, rules of the exclusion scheme, or confirmation that exclusions have expired. Such data will not be shared with Members except for the purposes of civil recovery or any legal proceedings.
c. Information and evidence about incidents in which an Offender has been involved; the purpose of this processing is to enable TONBRIDGE & MALLING SAFER TOWNS to authorise the issuing of Exclusion Notices, to inform Members of an offender’s modus operandi, to collate intelligence on criminal activity within the area of TONBRIDGE & MALLING SAFER TOWNS’s operation and to defend its legal rights against any claim or suit by an Offender or other party. Such data may be shared with Members.
d. For the purposes of identification, some sensitive or ‘special category’ personal data may be processed by the BCRP e.g. ethnicity and for the safety and protection of our members, some medical conditions where the condition has symptoms that would render the Offender a danger to our Members. The dissemination of this information to our Members will not be widespread or general in nature but rather targeted to those most likely to be affected.
7. Offenders’ personal data may be collected or provided to the BCRP from:
a. Offenders who may voluntarily offer information about themselves;
b. Members who may submit reports about incidents in which Offenders have been involved. They may also send relevant ‘intelligence’ about Offenders, for example they may provide a name when asked to identify an unidentified CCTV image;
c. Police or other public agencies may provide Offenders’ personal data under a formal Information Sharing Agreement.
d. Social media platforms where such information is in the public realm by virtue of being displayed, without privacy controls, on a publicly accessible platform.
9. The following types of individuals may have access to TONBRIDGE & MALLING SAFER TOWNS data, including the personal data of Offenders: Kent Police and Partner Agencies, TONBRIDGE & MALLING SAFER TOWNS Member Businesses, Offenders via Subject Access Request
10. The BCRP will not transfer Offenders’ data outside the UK.
11. Data retention period: When an Offender is reported by a Member for participating in any threat or damage to any Member’s property, staff or customers, his/her name, date of birth and facial image together with any relevant information of offences or offending behaviour may be shared among Members for 12 months or for the period of exclusion which may be longer dependent upon the circumstances. If no further report is submitted during that period, the Offender’s data will be withdrawn from Members at the expiry of that period. It will be retained for a further 12 months in the Scheme’s database (which can only be accessed by the Data Controller and authorised personnel) after which time, if no further incidents are reported, it will be irrevocably deleted. 12. If during the 12 months when an Offender’s data is circulated among Members, he/she is reported for another incident involving a threat or damage to any Member’s property, staff or customers, his/her name, date of birth and facial image may be circulated among Members for a further 12 months. Additionally, the Offender may be excluded from all the properties of all or some Members for 12 months, and this fact will be shared with Members. If no further report is submitted by a Member during that period, the Offender’s data will be withdrawn from Members at the expiry of that period. It will be retained for a further 12 months in the BCRP’s database (which can only be accessed by the Data Controller and authorised personnel) after which, if no further incidents are reported, it will be irrevocably deleted.
Offenders’ rights
12. Every Offenders has the right to obtain a copy of all the personal data which TONBRIDGE & MALLING SAFER TOWNS holds about him or her; to do so the Offender must contact the Data Controller (see contact details above); the Offender may be required to provide proof of his/her identity. In any case TONBRIDGE & MALLING SAFER TOWNS will respond to the request within 30 days and provide full documentation to demonstrate compliance with Data Protection law. If, when an Offender accesses his/her personal data, any of it is deemed by the Offender to be incorrect, unnecessary or disproportionate, the Offender can require TONBRIDGE & MALLING SAFER TOWNS to correct it. Offenders do not have the right to require TONBRIDGE & MALLING SAFER TOWNS to delete correct, necessary or proportionate information.
13. Offenders have the right to complain about TONBRIDGE & MALLING SAFER TOWNS to the Information Commissioners Office. Offenders can submit a complaint on the ICO’s website at https://ico.org.uk/concerns/handling/
14. BCRP website:
Cookies: The TONBRIDGE & MALLING SAFER TOWNS website uses 3rd party cookies to make our website better. We use them to understand how visitors use and interact with our website. Amongst other things, the cookies we use allow us to calculate how many visitors we have – anonymously, of course – and how long they stay on our site. How do I turn cookies off? Most browsers accept cookies automatically, but you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. Generally, you have the option to accept all cookies, to be notified when a cookie is issued or reject all cookies. Visit the ‘options’ or ‘preferences’ menu on your browser to change settings.
User agreement: By continuing to use our site, you agree to the placement of cookies on your device. If you choose not to receive our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.
Opt out: If you’d like to opt out of cookies, please go to the Network Advertising Initiative website at www.networkadvertising.org where you will be able to opt out of a number of networks.
Changes: We may need to update this policy in the future. We encourage you to review it regularly. This policy was last updated on 05/04/2019. For more information about cookies, and how to manage and disable them visit www.allaboutcookies.org
Disclaimer: TONBRIDGE & MALLING SAFER TOWNS seeks to ensure that all information on this website is accurate. However, our BCRP and its employees cannot accept any responsibility or liability for any claim, loss or damage whatsoever from the use of any information within, or accessed through, this website.
PRIVACY STATEMENT GENERAL PUBLIC
TONBRIDGE & MALLING SAFER TOWNS is committed to protecting your privacy. This Privacy Statement explains how we use the information which we may collect through the TONBRIDGE & MALLING SAFER TOWNS website (the “website”). References in this Privacy Policy to “we”/ “us” shall be deemed to be references to TONBRIDGE & MALLING SAFER TOWNS. If you are a member of TONBRIDGE & MALLING SAFER TOWNS or an offender who has received a warning or exclusion notice from us then please see the relevant Privacy Notice on the TONBRIDGE & MALLING SAFER TOWNS website which explains how we may retain, use, process your information.
1.1 If you have any queries in relation to our Privacy Statement, please contact us at:
TONBRIDGE & MALLING SAFER TOWNS,
Community Safety Unit.
Tonbridge & Malling Borough Council
Gibson Drive
West Malling, Kent
ME19 4LZ safertowns@gmx.com
1.2 We process personal data in accordance with the Data Protection Act 2018.
1.3 Where the website contains links to other websites we are not responsible for their privacy practices. This privacy statement applies solely to the TONBRIDGE & MALLING SAFER TOWNS website.
1.4 If you are not happy with our Privacy Statement, we ask that you stop using the website.
1.5 By submitting information to us via our Contact form or using our website you consent to the collection and use of your personal information in the manner set out in this Privacy Statement.
Personal Information
2.1 It may be necessary for us to collect your personal information. The types of information collected will vary depending on your use of the website, as described below.
2.2 To contact us you are required to give your contact information (name, email address and phone number). This will trigger an email to us to contact you in relation to your enquiry. Information you send us for the purpose of your enquiry could be with a view to membership. This information will be treated by us with the greatest care and for the purpose of the enquiry only.
Use of Information
3.1 Personal information will only be used for the purpose for which you have provided; to communicate with you about our work, your use of our website and/or changes to the website.
3.2 In order to provide our services we keep a record of all correspondence to help us keep track of the enquiries we receive, to comply with the law.
3.3 We will never pass your personal information to anyone else without your consent.
3.4 If your personal information changes or if you no longer wish to receive communication or emails from us, please let us know and we will correct, update or remove your details. This can be done by writing to us at TONBRIDGE & MALLING SAFER TOWNS, Community Safety Unit, Tonbridge & Malling Borough Council, Gibson Drive, West Malling, Kent. ME19 4LZ, or www.safertowns@gmx.com
Security
4.1 TONBRIDGE & MALLING SAFER TOWNS follows strict security procedures in the storage and disclosure of information which you may give to us, to prevent unauthorised access. However, the Internet is not a secure environment and we cannot guarantee the security of any information.
PRIVACY STATEMENT – MEMBERS
This statement confirms the commitment of TONBRIDGE & MALLING SAFER TOWNS to protect your privacy and to process your personal information in a manner which meets the requirements of the Data Protection Act 2018 (The Act).
PRIVACY NOTICE (MEMBERS)
1. This document explains what TONBRIDGE & MALLING SAFER TOWNS (the BCRP) is, why it processes its Members’ personal data, and the lawful basis for that processing. It describes the kind of personal data about members that the BCRP is allowed to process, and that the BCRP can do with it.
2. Who we are and what we do – the role of TONBRIDGE & MALLING SAFER TOWNS is explained in our website www.tmsafertowns.org.uk
TONBRIDGE & MALLING SAFER TOWNS,
Community Safety Unit.
Tonbridge & Malling Borough Council
Gibson Drive
West Malling, Kent
ME19 4LZ
safertowns@gmx.com
3. TONBRIDGE & MALLING SAFER TOWNS’s Data Controller is responsible for ensuring its compliance with current Data Protection Law and can be contacted at the above address or email account. TONBRIDGE & MALLING SAFER TOWNS is registered with the information Commissioners Office as a Business Crime Reduction Partnership.
4. Purpose of processing personal data – TONBRIDGE & MALLING SAFER TOWNS processes Members’ personal data for the following purposes:
(a) To enable the efficient management of TONBRIDGE & MALLING SAFER TOWNS; to manage the membership of TONBRIDGE & MALLING SAFER TOWNS including subscriptions where relevant; invitations to TONBRIDGE & MALLING SAFER TOWNS meetings and training opportunities where relevant etc.
(b) To defend and indemnify TONBRIDGE & MALLING SAFER TOWNS in case of any Member’s non-compliance with TONBRIDGE & MALLING SAFER TOWNS Rules and Protocols;
(c) To enable TONBRIDGE & MALLING SAFER TOWNS to communicate efficient to Members by sending news, alerts and documents and information about events which are relevant to them
5. Lawful basis of processing – TONBRIDGE & MALLING SAFER TOWNS existing contract/agreement between itself and its Members requires that Members provide their name, postal and email addresses, telephone etc. to TONBRIDGE & MALLING SAFER TOWNS. This contract/agreement means that TONBRIDGE & MALLING SAFER TOWNS lawful basis for processing Members’ personal data is “contract” and therefore TONBRIDGE & MALLING SAFER TOWNS can process Members’ personal data without their further consent.
6. Categories and types of personal data processes - Name of a contact person, name and place of employment, postal and email addresses, telephone and other contact details will be processed
7. No sensitive or “special category” personal data (ethnicity, sexuality, religious beliefs etc) is processed by TONBRIDGE & MALLING SAFER TOWNS
8. Sources of personal data – TONBRIDGE & MALLING SAFER TOWNS obtains Members’ personal data from existing contracts/agreements with Members; Members may themselves update their personal data.
9. Recipients of Members’ personal data – TONBRIDGE & MALLING SAFER TOWNS Board of Management, Data Controller, authorised TONBRIDGE & MALLING SAFER TOWNS staff and formally contracted Data Processors may access Members’ personal data; Members’ personal data will not be passed to any third party unless to the police under warrant or with the express permission of the Member; TONBRIDGE & MALLING SAFER TOWNS will not transfer Members’ personal data outside the UK
10. Data retention period – TONBRIDGE & MALLING SAFER TOWNS will retain Members’ personal data only for as long as each Member remains a Member of the Scheme; when a Member ceases to be a Member of TONBRIDGE & MALLING SAFER TOWNS, he/she must confirm this with TONBRIDGE & MALLING SAFER TOWNS’s Board of Management as specified in TONBRIDGE & MALLING SAFER TOWNS Rules & Protocols at which time all associated personal data will be irrevocably deleted. In the case of submitted reports, the submitting Member’s email address only will continue to be associated with such reports for as long as the report is retained by the Scheme; this is required where a report may be used for evidential purposes in legal proceedings.
11. Members’ rights - Members can obtain a copy of all their personal data held by TONBRIDGE & MALLING SAFER TOWNS; Members may access this at any time on TONBRIDGE & MALLING SAFER TOWNS online system (My Account) or may be obtained on application to the Data Controller (see Contact Details above). Members can correct any erroneous data at any time on TONBRIDGE & MALLING SAFER TOWNS online system (My Account) or may require TONBRIDGE & MALLING SAFER TOWNS to correct any errors on their behalf. At the conclusion of their Membership, Members’ personal data will be irrevocably deleted by the Scheme with the exception of email addresses associated with Incident reports (see Data Retention Period above) and may require the data Controller to confirm such deletion. Members have the right to complain about TONBRIDGE & MALLING SAFER TOWNS to the Information Commissioners at https://ico.org.uk/concerns/handling/ TONBRIDGE & MALLING SAFER TOWNS www.tmsafertowns.org.uk
There may be hyperlinks within the TONBRIDGE & MALLING SAFER TOWNS website which will take you away from the TONBRIDGE & MALLING SAFER TOWNS website. The linked sites are not under the control of TONBRIDGE & MALLING SAFER TOWNS and we are not responsible for the contents of any linked site or any link contained in a linked site, or any changes or updates to such sites.
Disclaimer: TONBRIDGE & MALLING SAFER TOWNS seeks to ensure that all information on its website is accurate. However, TONBRIDGE & MALLING SAFER TOWNS and its employees cannot accept any responsibility or liability for any claim, loss or damage whatsoever from the use of any information within, or accessed through, this website.
Cookies: TONBRIDGE & MALLING SAFER TOWNS website uses 3rd party cookies to make our website better. We use them to understand how visitors use and interact with our website. Amongst other things, the cookies we use allow us to calculate how many visitors we have – anonymously, of course – and how long they stay on our site.
How do I turn cookies off? Most browsers accept cookies automatically, but you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. Generally, you have the option to accept all cookies, to be notified when a cookie is issued or reject all cookies. Visit the ‘options’ or ‘preferences’ menu on your browser to change settings. You can find out more about how to switch off cookies here.
User agreement: By continuing to use our site, you agree to the placement of cookies on your device. If you choose not to receive our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.
Opt out: If you’d like to opt out of cookies, please go to the Network Advertising Initiative website at www.networkadvertising.org where you will be able to opt out of a number of networks. Changes We may need to update this policy in the future. We encourage you to review it regularly. This policy was last updated on 05/05/2019.
For more information about cookies, and how to manage and disable them visit www.allaboutcookies.org
Disclaimer: TONBRIDGE & MALLING SAFER TOWNS seeks to ensure that all information on this website is accurate. However, TONBRIDGE & MALLING SAFER TOWNS and its employees cannot accept any responsibility or liability for any claim, loss or damage whatsoever from the use of any information within, or accessed through, this website.
