The City of London Corporation (“the City Corporation”) is committed to protecting your privacy when you use any of our services. This Privacy Notice explains how we use information about you and how we protect your privacy.
If you have any concerns or questions about how we look after your personal information, contact the City Corporation’s Data Protection Officer, also the Comptroller and City Solicitor, Michael Cogher. You can email the Information Officer or write to PO Box 270, Guildhall, London EC2P 2EJ.
1. Your personal information
Personal information is anything that directly or indirectly identifies and relates to a living person, such as a name, address, telephone number, date of birth, unique identification number, photographs, video recordings (including CCTV) etc.
Some personal information is ‘special category data’ and needs more protection due to its sensitivity. This includes any information about an identifiable individual that can reveal their sexuality and sexual health, religious or philosophical beliefs, racial origin, ethnicity, physical or mental health, trade union membership, political opinion, genetic/biometric data. Personal information relating to criminal offences and convictions, although not ‘special category data’, is still sensitive in nature and merits higher protection.
2. Why do we need your personal information?
We may need to use some information about you to:
- deliver Local Authority services required by law and other services which extend beyond our statutory duties
- achieve the objectives set out in our Corporate Plan 2018-23 ie to contribute to a flourishing society, support a thriving economy and shape outstanding environments
- support and promote the City of London, London and the UK
- contact you about our services to get your views, which helps us to manage them
- help investigate any concerns or complaints you have about our services
- keep track of spending on services
- check the quality of services; and
- to help with research and planning of new services
3. How the law allows us to use your personal information
There are a number of legal reasons why we will need to collect and use your personal information in different circumstances.
Generally, we collect and use personal information where:
- you, or your legal representative, have given consent
- you have entered into a contract with us
- it is necessary to perform our statutory duties or other legitimate purposes
- it is necessary to protect someone in an emergency
- it is required by law
- it is necessary for employment purposes
- it is necessary to deliver health or social care services
- you have made your information publicly available
- it is necessary for legal cases
- it is to the benefit of society as a whole
- it is necessary to protect public health
- it is necessary for archiving, research, or statistical purposes
This privacy notice is provided in a layered format, ie the following sit underneath this main notice, and the links below will provide you with more detail in relation to the collection and use of personal information, for specific City Corporation services.
For more information in relation to the collection and use of personal information for events and strategic engagement at the City Corporation please download the Strategic Engagement and Events privacy notice below.
For further information in relation to the collection of personal data regarding the Test and Trace scheme, please download the Test and Trace privacy notice below.
If you are unable to identify any specific service or have any queries regarding any of the information provided in the links, email the Information Officer.
If we have consent to use your personal information for any particular reason, you have the right to remove your consent at any time. If you want to remove your consent, contact the Information Officer and tell us which service you are using, so we can deal with your request.
5. Your rights regarding your personal information
The law gives you a number of rights in relation to what personal information is used by the City Corporation, and how it is used. These rights are listed below, and full details can be found in the City Corporation’s Data Subject Rights Policy.
You can ask us to:
- provide you with a copy of the personal information that we hold about you
- correct personal information about you which you think is inaccurate
- delete personal information about you if you think we no longer should be using it
- stop using your personal information if you think it is wrong, until it is corrected
- transfer your personal information to another provider in a commonly used format
- not use automated decision-making processes to make decisions about you
6. With whom do we share your personal information?
In some circumstances, we use other organisations to either store personal information or use it to help deliver our services to you. Where we have these arrangements, there is always an agreement in in place to make sure that the organisation complies with data protection law.
Sometimes we have a legal duty to provide personal information to other organisations.
We may also share your personal information when we consider/believe that there is a good reason to do so, which is more important than protecting your privacy. This doesn’t happen often, but in these circumstances we may share your information:
- to find and stop crime and fraud; or
- if there are serious risks to the public, our staff or to other professionals
- to protect a child; or
- to protect adults who are thought to be at risk, for example if they are frail, confused or cannot understand what is happening to them
For all these reasons, the risk must be serious before we can override your right to privacy.
If we are worried about your physical safety or feel we need to take action to protect you from being harmed in other ways, we will discuss this with you and, if possible, get your permission to tell others about your situation before doing so.
We may still share your information if we believe the risk to others is serious enough to do so.
If this is the case, we will make sure that we record what information we share and our reasons for doing so. We will let you know what we have done and why, if we think it is safe to do so.
7. How do we protect your personal information?
We have a legal duty to make sure we hold your personal information (on paper and electronically) in a secure way, and to only make it available to those who have a right to see them. Examples of our security include:
- Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password)
- Pseudonymisation, meaning that we will use a different name or identifier to hide parts of your personal information from view. This means that someone outside of the City Corporation could work on your information for us without ever knowing it was yours
- Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
- Training for our staff allows us to make them aware of how to handle personal information, and how and when to report when something goes wrong
- Regular testing of our technology and ways of working, including keeping up to date on the latest security updates (commonly called patches)
You can find more details of our Information Security expectations in our IT Security Policy.
8. Information outside of the European Union
The majority of personal information is stored on systems in the UK or EU. However, there are some occasions where your information may leave the UK/EU either to get to another organisation, or where it is stored in a system outside of the EU.
We have additional protections on your personal information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.
9. How long do we keep your personal information?
We will only hold your personal information for as long as it is necessary to fulfil our legal duties or business purposes.
There’s often a legal reason for keeping your personal information for a set period of time, and we will include information about retention periods in the layered privacy notices provided above (at section 3).
10. Further advice?
For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at:
Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
0303 123 1113 (local rate) 01625 545745 (national rate number) Information Commissioner's Office website