Privacy notices - children's services

1. Children's Services

Purpose for processing your information

The Royal Borough of Kensington and Chelsea’s and Westminster City Council Children’s Services collect and use personal information about you and your family. The council is registered as a Data Controller under the Data Protection Act 2018.

This privacy notice broadly explains what information we collect, the purpose for using, the types of personal information and who we may share it with.

It applies to all personal information collected for or on behalf of the council whether by letter, email, face-to-face, telephone, online or any other method.

To understand how your own personal information is used you may need to refer to any personal communications you have received from the council or check any specific Children’s Services privacy notices. Alternatively contact the department directly to ask about your personal circumstances.

How we collect your information

We collect information in a number of ways, for example, by letter, email, face-to-face, telephone, online forms, surveys.

Purpose for using your information

We use information about children and young people to enable us to carry out specific functions for which we are responsible. There are a variety of reasons why we work with families and ways that we collect data to support you and your family. Some of the purposes for collecting your data are listed below in specific Fair Processing Notices.

Legal Basis for Processing

The basis on which we lawfully process personal information is found in the Data Protection Act 2018 (DPA’18). The following are examples of special categories of personal information, some of which we may collect and use as part of working with children and their families:

• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• genetic data, biometric data for the purpose of uniquely identifying a person
• data concerning health
• data concerning a person’s sex life or sexual orientation

This information is only used for the intended purpose but if we intend to use it for any other purpose; we will normally ask you first. In some cases, the council may use your information for another purpose if it has a legal duty to do so, to provide a complete service to you, to prevent and detect crimes (e.g. fraud), or if there is a risk of serious harm or threat to life.

Statutory provisions could include:

Section 115 of the Crime and Disorder Act 1998

This provision allows the police, local authorities, health authorities and probation trusts to share information about any person for the purposes of preventing crime and disorder.

Section 17 of the Children Act 1989 and Section 11 of the Children Act 2004

The collection of Child in Need, child protection, early help and youth offending data is covered by Section 17 of the Children Act 1989. Local authorities collect and share this information under these implied powers in order to support and/or protect children. Some of this data is likely to meet the definition of Special Categories of Personal Data (under the terms of the DPA’18).

Education Act 1996 section 537A

The collection of school census information.

Welfare Reform Act 2012

The sharing of information with the Department for Work and Pensions (DWP) in relation to worklessness and other benefits claimed by families is covered generally by Section 131 of the Welfare Reform Act 2012. The Secretary of State, or a person providing the services of the Secretary of State, may supply relevant information to a qualifying person for prescribed purposes relating to welfare services or council tax.

The Welfare Reform Act 2012 section 134 allows for longer term data sharing powers between DWP, their service providers and local authorities. Furthermore, Ministers of the Crown have ordinary common law power to do whatever a natural person may do.

Digital Economy Act 2017

The Digital Economy Act enables public authorities to share relevant information on the individuals and families they are working with in compliance with the Data Protection Act 2018 for the primary purpose of supporting the wellbeing of individuals and households.

The following conditions which are set out in the Act must be met:

• Condition 1: the purpose is the improvement or targeting of a public service provided to individuals or households, or the facilitation of the provision of a benefit (whether or not financial) to individuals or households
• Condition 2: the purpose is the improvement of the wellbeing of individuals or households
• Condition 3: the purpose is the supporting of the delivery of a specified person’s functions, or the administration, monitoring or enforcement of a specified person’s functions

Public Task

The following conditions need to be applied:

• you can rely on this lawful basis if you need to process personal data:
• in the exercise of official authority’. This covers public functions and powers that are set out in law; or
• to perform a specific task in the public interest that is set out in law
• It is most relevant to public authorities, but it can apply to any organisation that exercises official authority or carries out tasks in the public interest

Collecting personal data

The information you provide helps us to support your family and make sure that we meet our legal duties and responsibilities, for example to carry out an educational or social care assessment.

We then use this data to:

• provide you and your family with help, advice and appropriate services
• measure whether our services are improving life for children and families
• help us develop and improve our services
• complete statistical returns to Government departments
• administer and protect public funds
• contact you with details of Research Programmes that may benefit you or your family for you to decide whether to take part or not

The categories of personal information that we collect and use may include the following:

• personal and family details
• lifestyle and social circumstances
• financial details
• employment and education details
• NHS number
• housing needs
• visual images
• details of personal appearance and behaviour
• licenses or permits held
• student and pupil records
• case file information

Who we may share your information with

Where necessary we will share information with Council departments and services as well as other organisations such as our partners, third party contractors, government bodies, the police, health and social care organisations, housing associations, landlords and educational establishments.

We will only share information with these organisations where it is appropriate and legal to do so. We will also share information, for example, if there is a risk of serious harm or threat to life, for the prevention and detection of fraud or crime, assessment of any tax or duty or if we are required to do so by any court or law. Where this is necessary, we are required to comply with all aspects of the DPA’18.

Details for Transfers

It may sometimes be necessary to transfer personal information overseas. When this is needed, information may be transferred to countries or territories around the world. Any transfers made will be in full compliance with all aspects of the DPA’18.

How long do we keep your information?

We will only keep your information for as long as is required by law and in accordance with the council’s corporate retention schedule.

Information that cannot identify you

We may also anonymise some personal data you provide to us to ensure that you cannot be identified and use this data to allow the Council to effectively target and plan the provision of services. We may also use this type of data for research purposes although no personal data will be shared.

Your Rights and Access to your information

You have the right to request a copy of the information that we hold about you.

The DPA’18 also gives you additional rights about the information we hold about you and how we use it, including the right to:

• object to and restrict further processing of your data; however, this may have an impact on the services we are able to deliver to you.
• request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.
• request your data to be rectified if it is inaccurate or incomplete
• have your data transferred or copied should you move to another authority
• not be subject to automated decision-making including profiling

If you want to see information stored about you, you will need to submit a ‘Subject Access Request’.

Please send an email to this address for further details:

RBKC: dataprotectionact@rbkc.gov.uk

WCC: dataprotection@westminster.gov.uk

Personal information collected via online forms

Our policy is to respect and protect the privacy of anyone who visits our websites. Where we ask you for personal information via an online form, this information will only be used for the purpose indicated and will be held in a secure manner. It will not be used for any other purpose without your permission and will not be kept for longer than necessary. If you are concerned about providing your personal information online, please contact us and we will arrange alternative means for you to provide this information.

Use of IP addresses and cookies

Cookies enhance your experience using our websites. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work more efficiently, as well as to provide information to the owners of the site.

We use cookies to audit the use of our website and help us to customise it for your visit. We do not store or transmit any personally identifiable data on these cookies. You can change your cookie setting at any time in the security settings in the browser you use to access the internet. Please note however, that rejecting all cookies may impact your enjoyment or use of this website.

We collect IP addresses* only for the purposes of system administration and to audit the use of our site. We do not link IP addresses to anything personally identifiable, which means that while your user session will be logged you will remain anonymous to us.

Some of our websites are hosted on a digital platform maintained by a company called Open Objects. Open Object sites also use cookies which are collected when anybody visits their websites. When the user’s session has ended no data is stored. The data collected when the website is used is to assist with the user’s experience while navigating the site. No data collected is shared with third parties

* An IP address is a unique string of numbers that identifies each computer

Changes in your personal circumstances

You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.

If you have any concerns

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information; please send an email to this address if you wish to send a complaint:

For RBKC: dataprotection@rbkc.gov.uk

For WCC: dataprotection@westminter.gov.uk

If you are not satisfied with the council’s response you have a right to complain to the Information Commissioner’s Office (ICO).

Changes to our privacy policy

As the council creates new services, this may generate further need to amend the privacy notice. If our privacy notice changes at any time in the future, it will be posted on this page.

Supporting documents

Privacy notice for the Supporting Families programme

2. Supporting Families

Purpose for processing your information

The Supporting Families programme is the council’s response to the government’s national Troubled Families programme. The programme aims to improve the lives of families who have multiple, complex needs by providing help and support.

We collect the following information:

By working closely with partner organisations and sharing information with them we can identify families who are experiencing difficulties to ensure they receive co-ordinated help and support.

To be eligible for the programme a family must be experiencing at least two of the following:

• children who have not been attending school regularly, i.e. with attendance levels of less than 90%
• children of all ages who need help who are identified as in need or are subject to a Child Protection Plan.
• adults out of work or at risk of financial exclusion and young people at risk of worklessness, eg:
  • parent(s) who is receiving out of work benefits or universal credit because they are not earning
  • parent(s)/families with unmanaged debt or considerable rent arrears
  • a young person not in education, employment or training
• families affected by domestic violence and abuse
• parents and children with a range of health problems, eg
  • parent(s)/child/young person with mental health problems
  • parent(s) receiving out of work benefits relating to a disability
• parents and/or children involved in crime or antisocial behaviour, eg
  • a child/young person who has commited a proven offence within the last 12 months or has received a police caution
  • a parent/child/young person who has received an ASB (anti-social behaviour) intervention within the last 12 months

This information is only used for the intended purpose of identifying families who are experiencing difficulties to ensure they receive co-ordinated help and support. Where a family meets Supporting Families criteria but are not receiving coordinated support, we will share contact details of the family with the Westminster City Council’s Family Hub programme. This will mean that a worker from a relevant agency can make contact with the family and, with consent, make sure that the services based in the hub work with the family so that, where possible, any problems identified are addressed.

However, if we intend to use information for any other purpose; we will normally ask you first. In some cases, the Council may use your information for another purpose if it has a legal duty to do so, such as to provide further services to you, or if there is a risk of serious harm or threat to life.

How we use information to identify families who meet the criteria

For the Supporting Families programme we collect data from internal departments and partner organisations to identify families who are experiencing serious difficulties and ensure they receive co-ordinated help and support. These organisations are:

• Department for Work and Pensions
• Children’s Centres
• Metropolitan Police Service
• some partner agencies in the voluntary sector

Who the information is shared with

In order to identify families who may need help and the kind of support they may require, the council will share information with partner organisations as follows:

Department for Work and Pensions

Full addresses and unique property reference numbers will be shared for individuals who meet any of the eligibility criteria listed above. The purpose of this information sharing is to enable the local authority to confirm which families include adults who are receiving out of work benefits and so may benefit from support relating to finding employment.

Office for National Statistics

As part of the programme, the local authority is required to share some information with the Government’s nominated evaluation partner, the Office for National Statistics (ONS). This includes personal information on individuals and families (such as names and dates of birth) who have been assessed as meeting criteria for the programme and those who have not been included on the programme but may have received other services.

The ONS will link this with information routinely collected by Government departments to develop a wider picture of the needs of families and the progress they have made. The results will be shared with the Government and Local Authorities but in an ‘anonymised’ form to protect families’ privacy. Anonymised data is data that cannot be used to identify an individual.

Prior to this sharing of information with the Government a Data Agreement has been put in place to ensure that all information is transferred, handled and stored in accordance with the Data Protection Act, security measures are in place to prevent the unauthorised use of information and ensure individuals cannot be identified from the information sets directly or any published reports.

The Metropolitan Police Service

Personal data restricted to name, date of birth and postcode will be shared. The purpose of this information sharing is to identify which individuals (who may benefit from a wider service from the local authority) may need help to avoid future involvement in crime or anti-social behaviour.

All information will be used in accordance with the Data Protection Act 2018, as informed by the General Data Protection Regulation (GDPR) legislation, Crime and Disorder Act 1998, Children Act 1989 and 2004, Welfare Reform Act 2012, Localism Act 2011, Local Government Act 1972 and other relevant legislation.

Information will be held securely and will only be used and shared on a strict need to know basis with authorised partners in Westminster for the purpose of identifying, supporting and evaluating the work with families who have the most need.

How long do we keep your information?

The Government wishes to understand whether the programme has been effective in helping families turn their lives around, whether it is a good use of public money and the degree to which services improve over time. All information gathered for the purposes of the programme will be retained for up to one year after the end of the programme to allow for evaluation. It will therefore be deleted when no longer needed under strict information security arrangements

Your rights and access to your information

You have the right to request a copy of the information that we hold about you.

The new General Data Protection Regulation also gives you additional rights about the information we hold about you and how we use it.

• you have a right to withdraw consent and the right to object and restrict further processing of your data; however, this may affect service delivery to you.
• you have a right to request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.
• you have a right to request your data to be rectified if it is inaccurate or incomplete
• you have a right to have your data transferred or copied should you move to another authority
• you have a right not to be subject to automated decision-making including profiling

If you have any concerns

If you have any questions about this privacy statement or data protection issues generally, you can contact dataprotection@westminster.gov.uk.

If you would like to know more about Supporting Families please write to us at:

Supporting Families, Children’s Services, Royal Borough of Kensington and Chelsea, Kensington Town Hall, Horton Street, London W8 7NX

You have a right to complain to us if you think we may not have complied with our obligations as to how personal information should be handled; please see our Fair Processing Notice or our complaints section.

If you think we may not have complied with our obligations regarding the handling of your personal information and should you remain dissatisfied with the council’s response, you have a right to lodge a complaint with the Information Commissioner’s Office Report a concern by visiting ICO.

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details in order for us to maintain an accurate and up to date record of your information.

3. Tracking and surveying the participation of young people in education, employment and training

Purpose for processing your information

Westminster City Council has a responsibility to encourage, enable and assist young people that are residents in the borough, aged 16 and 17 years at the start of each academic year (and up to 25 years in respect of young people with learning difficulties and/or disabilities), to participate in education, employment or training and to mitigate against the risk of becoming Not In Education, Employment or Training (NEET). 

In line with this responsibility, the council must ensure arrangements are in place to accurately track whether young people are participating in education, employment or training, and submit statutory returns to the Department for Education (DfE) on the number of young people who are NEET or whose current activity is not known. 

The identification of young people who are NEET through this tracking makes it possible for the Councils to offer support and encouragement to young people to re-engage with education, employment or training opportunities, either directly or through commissioned or partner organisations. 

We collect the following information

The information that is collected includes the following:

• personal and family details: name, age, gender, language, parent/carer name
• personal sensitive information: ethnicity, religion
• contact details: phone number, email address, home address
• education/employment details: education setting, academic year

If a young person is not participating in education, employment or training, additional information may be collected as follows to allow the Council to offer appropriate support:

• qualifications and achievements
• interests and ambitions
• Special Educational Needs or Disabilities (SEND)
• physical or mental health or condition
• substance misuse
• offending behaviour
• refugee or asylum seeker
• LGBTQ
• looked after child or care leaver
• teen parent
• young carer

This information is only used for the purposes of tracking young people’s participation in education, employment or training and for the purposes of supporting young people to re-engage with these opportunities if they have become NEET. However, if we intend to use your information for any other purposes we will normally ask you first. In some cases, the council may use your information for another purpose if it has a legal duty to do so, such as to provide further services to you, or if there is a risk of serious harm or threat to life.

How we collect your information

Prospects Services have been commissioned by the council to collect this information on their behalf. The majority of the information is collected directly from schools and colleges.

Prospects Services also collect information directly from young people and/or their parent/Carer in a number of ways, for example, by letter, email, face-to-face, telephone, online forms, surveys.

Who the information is shared with

The council has a statutory duty to report to the DfE the total number of young people who are participating in education, employment or training, the number of young people who are Not in employment, Education or Training and the number of young people whose current activity is not known. 

Information will sometimes be shared with council departments and services. For example, this could be to identify whether a young person is known to council services in order to establish whether they are participating in education, employment or training, where the current activity of the young person is not known. 
Where a young person is identified as NEET, Prospects will gain their verbal consent to make a referral to support or advice services. Residents of the City of Westminster will be referred to the Westminster Employment Service, an in-house council service. 

We will only share information with these organisations where it is appropriate and legal to do so.  We will share information, for example, if there is a risk of serious harm or threat to life, for the prevention and detection of fraud or crime, assessment of any tax or duty or if we are required to do so by any court or law.  
All information will be used in accordance with the Data Protection Act 2018, as informed by the General Data Protection Regulation (GDPR) legislation, Crime and Disorder Act 1998, Children Act 1989 and 2004, Welfare Reform Act 2012, Localism Act 2011, Local Government Act 1972 and other relevant legislation.

How long do we keep your information? 

Records are archived and stored on the Bi-Borough’s integrated young person’s support system until the young person reaches the age of 25. Access arrangements for suppliers commissioned to act on behalf of the Councils will end once the contract expires, at which point the supplier will no longer have access to the data that is held.

Your rights and access to your information

You have the right to request a copy of the information that we hold about you. The new Data Protection Act 2018 also gives you additional rights that refer to how the council holds and uses your information. Consequently, under certain circumstances, by law you have the right to:

• object to and restrict further processing of your data; however, this may affect service delivery to you
• request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it
• request your data to be rectified if it is inaccurate or incomplete
• have your data transferred or copied should you move to another authority
• not be subject to automated decision-making including profiling​

Information about how to submit a Subject Access Request can be found here.

Please visit our web pages for further details on how the council complies with the new Data Protection Act 2018.

If you have any concerns

Please contact dpo@westminster.gov.uk if you would like to know more about the information we hold about you and how we use it.

You have a right to complain to us if you think we have not compiled with our obligation for handling your personal information; please visit our complaints page.  

If you are not satisfied with the council’s response you have a right to complain to the Information Commissioner’s Office (ICO). You can report a concern by visiting the ICO website

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.

4. Bessborough Family Hub

Purpose for processing your information

The council is developing three new Family Hubs, endorsed by the Health and Wellbeing Board in September 2016, that will improve access to preventative services (both universal and targeted) for children and their parents or carers. The services provided from these hubs will support families to understand and make effective changes that ultimately improve their health and wellbeing. The Bessborough Family Hub has been open in the south of Westminster since July 2018. The overall objectives of the Family Hubs are to:

• reduce referrals to higher level services, including Child and Adolescent Mental Health services, social care, GP consultations, youth justice, and Housing Options, by reaching families earlier and working with them to make lasting change
• promote school readiness and prevent school exclusions
• prevent family breakdown that results in children and young people being received into care or entering the criminal justice system
• promote strong and resilient parents, with support to gain employment
• improve health and wellbeing outcomes for children and young people - these will include obesity, breastfeeding rates, oral health, immunisations, emotional well-being of adolescents

We will use our existing children’s centre hub buildings to strengthen this integration and partnership working across commissioned and directly delivered services provided by:

• Westminster Children’s Services
• Central London Community Healthcare - Health Visiting team
• Central North West London Foundation Trust - School Nursing team
• Voluntary sector organisations – in the south locality these are St Vincent’s Family Project and the Cardinal Hume Centre
• Family Lives

As well as a number of other services providing support to families with a range of needs living in the locality.

This will provide the opportunity to bring families into a physical building, a focal point in the community where they can access advice, information, signposting to the right service and direct family support. The centre will also provide a space to co-ordinate a range of services which will be delivered at venues across the locality.

The aim will be, through the network, to identify families with multiple needs as early as possible, no matter what service they first come into contact with.

If you and your family could benefit from early help support, the Family Hub will gather information about your family to ensure you receive the right support at the right time.

We collect the following information

If you require further information or advice from the Family Hub you can complete the form ‘What Can We Help You With?’ providing your name and contact details which will result in a practitioner from the Family Hub contacting you. Parents can get a copy of the form from the Family Hub, by telephoning 02076415676 or from any of the partner organisations working as part of the Integrated Leadership Team (as mentioned below).

If, after talking to you, we feel you would benefit from further early help support and you agree, you will be asked to complete a more detailed form sharing your family’s personal details; this would include full names of everyone in your household, dates of birth, gender, full address and contact details (telephone and email), your ethnicity, housing and employment status, disability and additional health needs, whether you are in receipt of benefits, contact details of your GP, Health Visitor and any other service supporting your family, relationship status and languages spoken. This form will also ask you to describe your family’s needs and the help you would benefit from. If you would like help with completing this form please contact the Family Hub and a Family Navigator will arrange an appointment to support you with this.

If you do not wish to complete this form or do not wish your information to be shared with any other service then you can still receive a service without doing so but you may have to repeat your information if you require support in the future.
We will not collect any additional information about you without your agreement. If we intend to use information for any other purpose; we will normally ask you first. In some cases, the Council may use your information for another purpose if it has a legal duty to do so, such as to provide further services to you, or if there is a risk of serious harm or threat to life.

We may also anonymise some personal data you provide to us to ensure that you cannot be identified and use this data to allow the council to effectively target and plan the provision of services.
For example, we may use statistics/numbers relating to ethnicity of families to measure reach of services to ensure we are reaching the whole community.

How we collect your information

We collect your information with your agreement when you request support from the Family Hub, via paper forms (these will be available for completion online in the future):

• ‘What Can We Help You With’ form where you provide your name and contact details to enable somebody from the Family Hub to contact you
• ‘About My Family’ registration form which gathers detailed information about you and your family to ensure you receive the right service for your family

We may also gather information about your family through telephone contact with you or face to face in a meeting with you. If another service is contacting the Family Hub on your behalf then they may share your details by secure email.

When your family receive support from one of the Family Hub services we will produce with you a Family Plan, this plan will detail the support that you need and who will help you with your needs. This plan is your family plan to keep but will be shared with your agreement with all of the services that are supporting you and your family and stored securely as part of your records.

If you already receive support from a service and it is felt you would benefit from receiving support from further services your support worker may talk to you about the Early Help panel which takes place at the Family Hub. With your agreement your information could be shared with a number of services attending the Early Help panel in order to get the best possible support for you and your family.

The Family Hub also receives information from other services, these are:

• information of a new birth when you have agreed for Health Visiting to share these details
• information from the Department for Work and Pensions (DWP) regarding families who may be eligible for the 2 year old childcare offer
• the outcomes of child development reviews undertaken at 8 months and 2 years where you may benefit from further services to support child development and when you have agreed to this
• information from school nursing of any identified children who may benefit from further support, with your agreement
• Early Years Foundation Stage of numbers of children with school places in the area
• information from Supporting Families (within Westminster City Council) of families who may benefit from further support from the Family Hub app
• If appropriate your family may be contacted by letter offering further information of the services that are available at the Family Hub

Who the information is shared with

Your information will be held on our secure database system and with your agreement will be shared with the services that make up the Integrated Leadership team at the Family Hub, these are:

• Westminster Children’s Services including Early Help, the Children’s Centre and Social Work team
• Central and North West London Foundation Trust School Nursing Service
• Central London Community Healthcare NHS Trust Health Visiting Service
• Family Lives
• St Vincent’s family project
• Cardinal Hume Centre

Any details recorded on our database will only be accessed by those working as part of the Family Hub for the purposes of supporting your family.

How long do we keep your information?

We will only keep your information for as long as is required by law and to provide you with the necessary services in line with our stated retention policy. In general information related to the Family Hub providing a service to the family, recorded data (family’s personal details and contact information) will be retained up until December 2021, or up to three years from point of the last contact with the family.

Each participating organisation working as part of the Family Hub have their own data retention policy and will ensure information is held in line with their own retention policies and legal requirements.

Your rights and access to your information

You have the right to request a copy of the information that we hold about you.

The Data Protection Act 2018 also gives you additional rights that refer to how the council holds and uses your information.

Consequently, under certain circumstances, by law you have the right to:

• withdraw your agreement and object to and restrict further processing of your data; however, this may affect service delivery to you
• request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it
• request your data to be rectified if it is inaccurate or incomplete
• have your data transferred or copied should you move to another local authority area
• not be subject to automated decision-making including profiling

How to submit a Subject Access Request

If you have any concerns

Please contact us if you would like to know more about the information we hold about you and how we use it by contacting the Bessborough Family Hub manager by phoning: 020 7641 5676.

If you have any questions regarding your Data Protection rights, such as accessing your personal information, etc. or if you have a concern over the handling of your information. You can email the Council’s Information Management Team at dataprotection@westminster.gov.uk

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information.

If you are not satisfied with the council’s response you have a right to complain to the Information Commissioner’s Office (ICO).

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.

5. Children's Centres

Purpose for processing your information

Personal information can be anything that identifies and relates to a living person.Westminster City Council is the Data Controller for the personal information you provide to the council’s Children’s Centres. As the Data Controller, the City council will use your information for monitoring and evaluation purposes and to inform you about Children’s Centre activities:

We collect personal information to help us to provide services and support for parents and children. Knowing who is accessing different types of support available enables us to manage the services we provide including making sure our workers receive appropriate training and management. It also helps us to check if our services are effective and of high quality and the degree to which children and families are supported in a coordinated way. This enables us to plan for the services we provide in the future.

Legislation including the Children Act 2004, The Childcare Act 2006, The Children and Families Act, and the Education Act 1996 provide a legal basis for needing to collect personal information:

The legal reason for us to collect and use this personal information is:

• you, or your representative, have given explicit consent
• it is necessary to perform our statutory duties or it is required by law (see above legislation) or it is necessary for employment purposes
• it is necessary to protect someone in an emergency
• it is necessary to deliver health or social care services or it is necessary to protect public health
• it is necessary for archiving, research, or statistical purposes
•  We do not collect information we do not need or will not use. This Privacy Notice covers information you have provided to the Children’s Centre and information which has been shared with the Children’s Centre by other organisations.

How we collect your information

We collect information in a number of ways. This mainly takes place through our registration process but we may also collect it by letter, email, face-to-face or telephone. We also receive details of children who are born in Westminster to enable us to offer services to parents. We receive personal information (names and addresses) from the Department for Work and Pensions to enable us to contact and offer support to parents who meet the criteria to access the two year old offer. We receive additional information through the two year old offer online portal (dates of birth, National Insurance or NASS number, and contact details) if parents provide this information (which must be provided when applying for a 2 year old place).

We collect the following information:  

• names, addresses and contact details of parents (including pregnant parents) and carers and their relationship to children using the centres
• names, dates of birth, gender and any disability of children using the centre
• ethnicity, first language spoken and any interpreting needs
• details of any disabilities
• education and employment status of parents and carers including any benefits received
• details of nurseries or schools that children attend
• health details including registration with a GP, dentist and allocated health visitor (for parents and carers). Details of immunisations and dates of developmental checks (for children).

This information is only used for the intended purpose but if we intend to use it for any other purpose; we will normally ask you first. In some cases, the council may use your information for another purpose if it has a legal duty to do so, to provide a complete service to you, or if there is a risk of serious harm or threat to life.

Who the information is shared with

We work with a range of organisations which might provide services to you. We may also share your personal data with:

• The Bi-Borough (Westminster & RBKC) Early Years Service
• childminders (if we are assisting with supporting a two year old child to be placed with a childminder)
• The Family Information Service
• nurseries and pre-schools
• midwives, health visitors and speech and language therapy
• Special Educational Needs service
• Other council services such as the Supporting Families programme
• Other specialised providers who provide services for families.

We occasionally have a legal duty to provide personal information regarding safeguarding to organisations such as children’s social care or the police. Otherwise, your information will not be disclosed to other organisations unless we are required and permitted to do this by law. 

If we believe other services may be of benefit to you, we will seek consent from you and will only share your personal data if you give consent.

How long do we keep your information?

The data that we collect can be in relation to current or previous users of our services. We continue to hold data about you and your family until the end of the academic year in which your youngest child turns 6 years of age.This is so we can provide support with the transition to primary school if needed.

Your rights and access to your information

You have the right to request a copy of the information that we hold about you.  

The general data protection regulation also gives you additional rights about the information we hold about you and how we use it.

• You have a right to withdraw consent and the right to object and restrict further processing of your data; however, this may affect service delivery to you.
• You have a right to request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.
• You have a right to request your data to be rectified if it is inaccurate or incomplete
• You have a right to have your data transferred or copied should you move to another local authority area
• You have a right not to be subject to automated decision-making including profiling

If you want to see information stored about you, you will need to submit a ‘Subject Access Request’. Please send an email to this address for further details:

dataprotectionact@westminster.gov.uk

If you have any concerns

If you have any questions about this privacy statement or data protection issues generally, you can contact DPO@westminster.gov.uk

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information. If you wish to do this, lease send an email to this address:

DPO@westminster.gov.uk

Should you remain dissatisfied with the City Council’s response you have a right to lodge a complaint with the Information Commissioner’s Office if think we may not have complied with our obligation for handling your personal information.

Report a concern by visiting the ICO website

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details in order for us to maintain an accurate and up to date record of your information.

6. Youth Offending Team

Purpose for processing your information

The Westminster Youth Offending Team (YOT) works with children and young people aged 10-17 years who have attended court and been given a statutory court order. We have legal obligations to support young people (and their families) within the criminal justice system and reduce youth offending, as well as to address problems and factors that lead to criminal offending behaviour. 

The YOT is a multi-agency team which is provided to meet the requirements of the Crime and Disorder Act 1998. The team is based in the council's Children’s Service Department and includes representatives from Children’s Services, police, probation, education and health who are seconded into the team.

In order to meet our legal obligations, we need to collect personal data. This help us work with you and to understand and plan services through an offending prevention programme as part of a voluntary arrangement or a statutory order. The team assesses the young people and their families referred to them and will either work directly with them or link them to other services, should they need more specialist help or interventions.

The Data Protection Act 2018 states that before we collect your personal data we must have a lawful basis or reason. There are only 6 permissible reasons and we must have at least one of these reasons. For the YOS we are relying on GDPR 6(1)(c) where processing is necessary for compliance with a legal obligation to which the council must comply. 

The YOT is committed to ensuring privacy and security of data collected, stored and processed.  This Privacy Notice explains:

• the data we collect and its purpose
• who will see your data
• how long your data is kept
• how we store your data
• your rights

We collect the following information

We work closely with partner organisations and share information with them so that we can identify and support young people who are experiencing difficulties, ensuring they receive coordinated help and support. We collect your information in a number of ways including by email, letter, telephone and face to face interviews or meetings. We collect and hold the following information in relation to young people and their families, including that of parents/carers, siblings and any close relatives:

• Personal data (names, dates of birth, addresses, telephone and email contact details, NHS numbers, unique pupil numbers)
• Characteristics (gender, ethnicity, languages spoken, religious beliefs), health needs or problems (physical and emotional), medical history, any disabilities, immigration status.
• Educational data including schools attended, levels of attendance, attainment and achievement, details of any special educational needs and any exclusions
• Data regarding criminal offences and court appearances and outcomes.
• Details of witnesses or victims of crime.
• Information regarding young peoples’ needs and support provided (referrals and assessments, details of any statutory plans such as Child Protection Plans and/or being “looked after”.
• Details of any wider health or social care help that family members receive.
• Documents received by the YOT including referrals and reports from other professionals.

Some of the data that we collect is known as “special category”. We need an additional lawful basis to collect this information. This might include information about your ethnicity or sexuality and may be used for equality monitoring in accordance with the Equality Act 2010. We rely on GDPR Article 9(2)(i) “processing is necessary for reasons of public interest” to collect this aspect of your data.

The nature of our services means that we need to collect data about criminal offences. In order to collect this we must comply with GDPR Article 10. The Council meets this requirement.
This data is used to assist the YOT to carry out its statutory functions and duties to prevent and reduce offending and re-offending as well as to increase levels of confidence of victims and the wider community that youth offending is being effectively addressed. The data is needed to work effectively with young people and to prevent them from offending. It enables the provision of support for those who are:

• Bailed from courts
• Supervised on formal Court Orders, pre-Court Orders or out of court disposals
• Remanded into youth detention accommodation
• Given custodial sentences

Data is also needed to enable the YOT to comply with the requirements to provide statistics regarding levels of activity and effectiveness in addressing and reducing youth offending for Government departments such as the Home Office and Youth Justice Board. The YOT is required to provide and contribute to reports for local agencies and Council boards such as the Youth Crime Prevention Partnership, Council Scrutiny Committees and the Public Health department. This is to inform evaluations of current services and to help plan for future services to meet local need.

Your personal information is only used for a specified purpose(s) (see “Purpose for processing your information” above) but if we intend to use it for any other new purposes we will normally ask you first.  For instance in some cases, the Council may wish to use your information for another purpose such as in relation to improving and developing services, or to prevent or detect fraud.  In any event our processing will always have a demonstrable lawful basis.  Where practicable and reasonable we will always seek to inform you of any significant proposed changes to how we process or intend to process your personal data, in order to ensure full transparency over how we handle your information.

Who the information is shared with

We share and request the minimum amount of personal data and personal information to and from the following organisations:

• Other council teams including Family Services, Multi-Agency Safeguarding Hub (MASH), Supporting Families programme, Anti-Social Behaviour/Community Safety teams, Integrated Gangs Unit, Housing, Education and Special Educational Needs teams, Legal Services. This is so that the teams can provide information to assist in YOT assessments of what young people and their families need as well as enabling the teams to carry out specific duties regarding youth offending and wider statutory roles in relation to supporting residents.
• Other Youth Offending Services
• YOT volunteers
• Borough Police and the Metropolitan Police Service
• Crown Prosecution Service
• Youth Justice Board
• Ministry of Justice
• National Probation Service
• HM Courts and Tribunal Service
• Lawyers (for the local authority and also for young people if you have instructed one to represent you)
• The Children and Family Court Advisory and Support Service (CAFCASS)
• Child and Adolescent Mental Health Services
• Drug and Alcohol support services
• Schools and other education providers

The following are the legal bases under the General Data Protection Regulations on which we rely to process your personal and special category data.

• Where the data subject has given explicit consent to the processing of personal data for one or more specific purposes. Where consent to share your information is required, we will specify why the sharing of this information is necessary (GDPR 6(1)(a))
• Where compliance with legal and statutory obligations is required, consent is not needed. 6(1)(c). This will be the case where:
  • the YOT has a statutory responsibility to process personal data as part of its role in preventing and reducing offending or increasing confidence of victims and the wider community that youth offending is being effectively addressed.
  • the behaviour of individuals constitutes a serious risk of harm to the individual or to others (6(1)(d))
  • processing is needed for legal proceedings, advice or for establishing, exercising or defending legal rights. 
• Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (6(1)(e).
• Where there is a contract for the supply of services entered into with partners (6(1)(b))
• We do not share personal or special category data about you or anyone else without agreement unless the law or policies allow this.

Such data sharing enables the YOT to meet statutory obligations resulting from the following and other legislation:

• Crime and Disorder Act 1998
• Children Act 1989 and 2004
• Police and Criminal Evidence Act 1984
• Legal Aid and Sentencing of Offenders Act 2012
• Health and Social Care Act 2012
• Health and Social Care (Safety and Quality) Act 2015
• Education Regulations 2015
• Children and Social Work Act 2017
• Care Act 2014
• Mental Capacity Act 2005
• Mental Health Act 1983
• Local Safeguarding Childrens and Adults Boards Regulations 2006
• Localism Act 2011
• Welfare Reform Act 2012
• Childcare Act 2006
• Equality Act 2010

How long do we keep your information?

Your personal data will not be retained for any longer than is necessary in relation to the purposes for which it was collected. Data will generally be held for a range of periods of time depending on the nature of the information and the need to retain more sensitive data for longer periods. Retention periods are informed by policies of the Youth Justice Board.

However, under the current restrictions of the Goddard Enquiry no children’s records should be deleted from systems until further guidance has been issued by the Enquiry.

Once the restriction has been removed Westminster City Council will ensure a retention period is agreed and implemented.

Data will be held on paper or electronically in a secure way and will only be available to those who have a right to see this information.

Your Rights and Access to your information

You have the right to request a copy of the information that we hold about you. 

General Data Protection Regulations also give you additional rights about the information we hold about you and how we use it. You have a right to:

• object to and restrict further processing of your data; however, this may affect service delivery to you
• request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it
• request your data to be rectified if it is inaccurate or incomplete
• have your data transferred or copied should you move to another authority
• not to be subject to automated decision-making including profiling

The Youth Offending Team are legally processing your data under the requirements of the Crime and Disorder Act 1998 and the Offender Management Act 2007.  As such there is no legal right to refuse processing as we are legitimately required to do so by UK law.

Information about how to submit a Subject Access Request

If you have any concerns

If you have any questions about this privacy statement or data protection issues generally, you can email: DPO@westminster.gov.uk.

If you think we may not have complied with our obligations regarding the handling of your personal information and should you remain dissatisfied with the Council’s response, you have a right to lodge a complaint with the Information Commissioner’s Office.

Report a concern by visiting the ICO website

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details in order for us to maintain an accurate and up to date record of your information. 
 

7. Multi Agency Safeguarding Hub (MASH)

The Multi Agency Safeguarding Hub (MASH) is made up of representatives from children’s social care co-located with professionals from the Met Police and the NHS. The MASH also has virtual links with other partner agencies such as education, housing, probation, the youth offending team and the UK Boarder Agency. If there are any other agencies working with a family, for example domestic violence services, alcohol and drug services, or another relevant agency the MASH may contact these agencies for information.

The purpose of the Multi Agency Safeguarding Hub (MASH) is to improve the quality of information that is shared between professionals in order to make timely and informed decisions about risk based on accurate and up to date information. The MASH sits separate but alongside the front door services in each respective local authority. The “front door” refers to the separate teams that each local authority has to receive referrals when there are worries about a child. The MASH is able to provide a brief risk assessment and recommendation to the front door services in Hammersmith and Fulham, Kensington and Chelsea, and Westminster. This is to assist in improving the quality of safeguarding decisions for children and their families in order to provide them with the most appropriate support and services as soon as possible. 

The MASH processes personal and sensitive information in relation to child sexual exploitation (CSE) data collection, recording and sharing in order to:

• to identify areas where development or a different approach is required
• to find and implement risk assessed improvements
• to streamline data collection and sharing amongst key stakeholders of MASE

This includes the Multi Agency Sexual Exploitation (MASE) panel which is a multiagency, cross borough collaboration between Westminster City Council (WCC), The Royal Borough of Kensington and Chelsea (RBKC), London Borough of Hammersmith and Fulham (LBHF) and police, to capture and tackle child sexual exploitation (CSE) and safeguard children who are at risk of it.  

We may collect information from the following agencies either by email, face to face meetings and within electronic forms.

Personal demographic information, for example your name, address, gender, date of birth, ethnicity, and relationships may be collected.

MASH may request multiagency information from relevant agencies including: health, education, police, probation, the youth offending team, the UK Border Agency, and any relevant agency known to be working with the family who will provide information regarding a child/parent/carer relevant to safeguarding. This information is used for MASH risk assessment purposes only and is not to be used for subsequent assessments outside the MASH. Not all agencies are contacted, each situation is considered individually, and only relevant and proportionate checks are undertaken.

Some of the agencies we may contact are:

Health

we may collect information from your child's GP or other health organisations, including: health visitors, school nurses and the child and adolescent mental health team. Only relevant information will be shared as a way of understanding whether an offer of support to you or your family is required.

Education

We may contact your child’s school for information about their education. We may ask about their school attendance, academic achievement and whether there are any concerns about their wellbeing. Only relevant information about your child will be shared as a way of understanding whether an offer of support to you and your family needs to occur.

Police

We may request information from the police when making our enquiries. The police will check whether individuals in the family have previously been in contact them. They will share any relevant information with children’s services as a way of understanding whether an offer of support to you and your family needs to occur.  

Probation 

We may request information from the probation service if tf they are supporting you or your family. We will ask why probation is involved, what support they are providing and whether they believe there to be any risks posed to children by the individual known to them. Only relevant information will be shared as a way of understanding your family’s circumstances and whether additional support is needed.

Youth Offending Team (YOT)

We may request information from the Youth Offending Team if they are supporting your family. If a young person is known to the YOT, we will ask why they are involved, what support they are providing and if they believe there to be any risks posed to the young person or to other members of the family. Only relevant information will be shared as a way of understanding your family circumstances and whether additional support is needed.

UK Border Agency (UKBA)

We may request information from the UKBA if we have reason to believe that you or family have a pending application with the Home Office. If the information is relevant, children’s services will use this information to better understand your family’s circumstances and whether an offer of support needs to occur.

Who we share the information with

The nature of the information that will be shared will often fall below a statutory threshold of S.47 (child protection investigation) or even S.17 Children Act 1989 (Child in Need). If they do fall within these sections of the 1989 Act, then these will be the main legal gateway. However, in addition the London Child Protection Procedures provide guidance and a legal gateway to share without agreement/consent under ‘legal obligation’ or public task.

Sections 10 and 11 of the Children Act 2004 place obligations upon the police, local authorities, NHS bodies and others to co-operate with other relevant partners in promoting the welfare of children and ensuring that their functions are discharged having regard to the need to safeguard and promote the welfare of children. This piece of legislation gives the statutory power to share information for the purposes of this agreement. 

The MASH brings together all of the information received in a brief risk assessment, analysis and recommendation about what happens next. The MASH may recommend that no further action is taken or may signpost you to community supports. If further social work support is required, the risk assessment, analysis and recommendations are shared with the relevant front door teams in Hammersmith and Fulham, Kensington and Chelsea, and Westminster. The "front Door” refers to the separate teams that each local authority has to receive referrals when there are worries about a child.    

The information provided by partner agencies is generally a brief snapshot of the current situation and if social work assessments are required, it is expected that updating information is obtained first hand by the assessing social worker. The information provided by MASH partners is for immediate risk assessment purposes only and is not used for any subsequent assessments outside the MASH process.

How long will we keep your information? 

We will only keep your personal information in accordance with the formalised council retention schedule to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once your personal information is no longer required it will be securely deleted. 

We may also anonymize some personal data you provide to us to ensure that you cannot be identified and use this data to allow the council to effectively target and plan the provision of services.

Your rights and access to your information 

You have the right to request a copy of the information that we hold about you. Data must be processed lawfully and fairly in a transparent manner. 

The new Data Protection Act 2018 (DPA’18) also gives you additional rights that refer to how the council holds and uses your information. 

Consequently, under certain circumstances, by law you have the right to:

• object to and restrict further processing of your data; however, this may affect service delivery to you.
• request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.
• request your data to be rectified if it is inaccurate or incomplete
• have your data transferred or copied should you move to another authority
• not be subject to automated decision-making including profiling

Information about how to submit a subject access request can be found on the RBKC website.

Please visit our web pages for further details on how the council complies with the new DPA’18 .

For further information on how we comply with the new DPA'18 please read our data protection notice.

If you have any concerns 

Please contact us if you would like to know more about the information we hold about you and how we use it:

Email: accesstochildrensservices@westminster.gov.uk

Phone: 0207 641 4000

You have a right to complain if you think we have not complied with our obligation for handling your personal information. Please email: DPO@westminster.gov.uk

If you are not satisfied with the council’s response you have a right to complain to the Information Commissioner’s Office (ICO). You can report a concern by visiting the ICO website.

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details in order for us to maintain an accurate and up to date record of your information.

8. Special Educational Needs and Disabilities (SEND) privacy notice

This notice explains what personal data (information) we hold about you, how we collect it and use it and who we may share your information with. We are required to give you this information under data protection law.​

Purposes for processing your information

The Special Education Needs and Disabilities (SEND) service is responsible for carrying out duties under the Children and Families Act 2014 in relation to statutory assessment processes, and the ongoing monitoring of children and young people who have Education, Health and Care (EHC) Plans. This includes information and advice sought for annual review, tracking information, disagreement resolution or mediation processes and processes relating to appeals to the Special Educational Need and Disability Tribunal (SENDT).

We work in a coordinated way with other children and young people’s services in Westminster City Council (WCC) and with partner organisations to ensure that we deliver the best possible outcomes for children and young people with SEND and to ensure we are fully compliant with the Children and Families Act 2014. The Data Protection Act 2018 states that before we collect your personal data we must have a lawful basis or reason. There are only 6 permissible reasons and we must have at least one of these reasons. For the SEND data we are relying on GDPR 6(1)(c) where processing is necessary for compliance with a legal obligation to which the council must comply.

We collect and use pupil information to comply with our legal obligations as outlined in the Children and Families Act 2014, and to carry out tasks in the public interest.

What information do we collect?

We collect information from parents or carers for children and young people below and within statutory school age, and from young people themselves if they are aged 16 or over and no longer in compulsory education.

In the course of assessing and planning SEND support and providing the most suitable educational provision, we collect the following personal information when you provide it to us:

• personal information (such as name, address, contact details, date of birth, parent/carer name(s) and contact details, gender)
• details of special educational needs and disabilities
• ethnicity
• information about physical or mental health

We also obtain personal information from the following other sources:

• other organisations or teams that can provide us with advice and information (such as Adult or Children’s Social Services, educational psychologists, mental health services, doctors, General Practitioners (GPs), school nurses and other NHS providers)
• schools or post-16 settings currently or previously attended
• early education providers currently or previously attended (such as nurseries, pre-schools and childminders)

Your personal information is only used for a specified purpose(s) (see “purpose for processing your information” above) but if we intend to use it for any other new purposes we will normally ask you first. For instance, in some cases, the local authority may wish to use your information for another purpose such as in relation to improving and developing services, or to prevent or detect fraud.  In any event our processing will always have a demonstrable lawful basis.  Where practicable and reasonable we will always seek to inform you of any significant proposed changes to how we process or intend to process your personal data, in order to ensure full transparency over how we handle your information.

​How we use your personal information

We use your personal information to:

• identify your child’s SEND needs
• clarify the child or young person’s needs
• identify the support they require which will help them to achieve their outcomes
• know who we need to speak to, so we can ask them to send us information and advice relating to your child
• make decisions about whether to conduct a statutory needs assessment or issue an Education, Health and Care (EHC) Plan
• make decisions about the content of an EHC Plan including outcomes, placement and provision
• support the ongoing monitoring of the provision specified in an EHC Plan where one is issued
• inform the EHC Plan annual review and monitor your child’s progress
• support disagreement resolution or mediation processes and processes relating to appeals to the Special Educational Need and Disability Tribunal (SENDT)
• help to resolve any disagreements
• enable coordinated working with other teams and organisations
• evaluate and quality assure the services we provide
• assess for specialist equipment
• inform future commissioned services and educational placements requirements

How long your personal data will be kept

We keep children and young people’s information from their date of birth until they reach the age of 25. Additionally, the SEND and educational psychology services keep information for six years after the date of last involvement, which will go beyond the age of 25 for those young people supported between the ages of 20 and 25. After this time the information is archived or securely destroyed.

Who we share your personal information with:

• teams within WCC working to improve outcomes for children and young people
• commissioned providers of local authority services (such as education or health services)
• schools, colleges and early years providers as well as wider education or training providers
• local multi-agency forums which provide SEND advice, support and guidance
• educational psychologists
• other local authorities and social care or health providers outside of the Local Authority
• Department of Education
• providers of independent advice and guidance (such as contracted SEND consultants)
• mediation services

We share information that we have gathered as part of a statutory needs assessment to identify the setting to be named in ‘Section I’ of a child or young person’s EHC Plan (this includes consulting in accordance with parental or young person choice as well as with those providers we feel would be suitable). We share information to resolve disagreements as part of formal and informal processes in relation to mediation, or formal appeals through the Special Educational Needs and Disability Tribunal

We will share personal information with law enforcement or other authorities if required by applicable law.

​Your rights and access to your information

You have the right to request a copy of the information that we hold about you. 

General Data Protection Regulations also give you additional rights about the information we hold about you and how we use it.

You have a right to:

• object to and restrict further processing of your data; however, this may affect service delivery to you
• request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it
• request your data to be rectified if it is inaccurate or incomplete
• have your data transferred or copied should you move to another authority
• not to be subject to automated decision-making including profiling​

Information about how to submit a subject access request

If you have any concerns

If you have any questions about this privacy statement or data protection issues generally please email: dpo@westminster.gov.uk

If you would like to know more about SEND please contact us at:

• Email address: sen@rbkc.gov.uk
• Phone number: 020 7361 3311

You have a right to complain to us if you think we may not have complied with our obligations as to how personal information should be handled; please see our Fair Processing Notice or our complaints section.

If you think we may not have complied with our obligations regarding the handling of your personal information and should you remain dissatisfied with the council’s response, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). Report a concern by visiting the ICO website.

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details in order for us to maintain an accurate and up to date record of your information.

9. County Lines, Rescue and Response and the Community Safety Partnership

Purpose for processing your information

We collect and process information about you, so that we can carry out our public task functions as a Local Authority and to deliver public services.

The London Rescue and Response County Lines project will develop and deliver a support service for young people who are vulnerable and involved in county lines drug distribution networks across London. A county lines enterprise almost always involves exploitation of vulnerable persons; this can involve both children and adults who require safeguarding. RBKC residents can be referred to services and access support for:

• 1 to 1 support for young people exploited from London
• specialist support for young women
• help to manage risk and safeguarding
• support to move away from criminal exploitation
• family support
• identifying young people who are being exploited through county lines
• better understanding of the problem and networks across London​

What information do we collect?

For the referral to be accepted by the Rescue and Response service RBKC services will need to share personal data with the Rescue and Response team. The data subjects will be residents of RBKC who are already known to family and children’s, adults and/ or housing services. Only information relevant for the referral and to obtain access to the service will be shared.

Your personal information is only used for a specified purpose(s) but if we intend to use it for any other new purposes we will normally ask you first. For instance in some cases, the council may wish to use your information for another purpose such as related to improving and developing services, or to prevent or detect fraud. In any event our processing will always have a demonstrable lawful basis. Where practicable and reasonable we will always seek to inform you of any significant proposed changes to how we process or intend to process your personal data, in order to ensure full transparency over how we handle your information.

​​How we collect your information

No new information will be collected by the council for the specific purpose of this project. Only data already held by the council that is relevant to the referral form will be shared.

Who the information is shared with

Information will be shared with the Rescue and Response Project via Brent council. The service providers for the Rescue and Response project include:

• Abianda
• St Giles Trust
• Safer London
• MET Police and National Police Services
• Community Rehabilitation Company
• Probation

Details for Transfers

There will be no overseas transfers.

How long do we keep your information?

We will only keep your information for as long as is required by law and to provide you with the necessary services in line with our stated records retention policy.  In general information will be held for seven years.

We may also anonymise some personal data you provide to us to ensure that you cannot be identified and use this data to allow the council to effectively target and plan the provision of services.

Your rights and access to your information

You have the right to request a copy of the information that we hold about you. 

The Data Protection Act 2018 also gives you additional rights that refer to how the council holds and uses your information.

Consequently, under certain circumstances, by law you have the right to:

• withdraw consent and the right to object and restrict further processing of your data; however, this may affect service delivery to you.
• request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.
• request your data to be rectified if it is inaccurate or incomplete
• have your data transferred or copied should you move to another authority
• not be subject to automated decision-making including profiling

Find information about how to submit a Subject Access Request.

Please visit our web pages for further details on how the council complies with the Data Protection Act 2018

If you have any concerns

Please contact us if you would like to know more about the information we hold about you and how we use it by emailing: dataprotection@rbkc.gov.uk

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information.

If you are not satisfied with the council’s response you have a right to complain to the Information Commissioner’s Office (ICO).  You can report a concern by visiting the ICO website.

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.