Our privacy notice tells you how Surrey Police hold, retain, process, disclose and share the information we obtain about you. It also explains the rights you have regarding your personal information. The use and disclosure of your personal information is governed in the United Kingdom by the General Data Protection Regulations, and the UK Data Protection Bill. The Chief Constable, Nicholas Ephgrave is defined as the ‘Data Controller’ for the purposes of the legislation and is required to ensure Surrey Police handles all personal information in accordance with that legislation. Surrey Police takes that responsibility very seriously and takes great care to ensure your personal data is processed appropriately to maintain your trust and confidence in the police.
Why do we process personal information?
Surrey Police have a statutory duty to uphold the law, prevent crime, bring offenders to justice and protect the public. To do this it is necessary for us to process your personal information under the lawful basis of ‘public interest’ and ‘official authority’. This means we process your personal information for carrying out tasks that are laid down in law and collectively described as the administration of justice.
We process some personal information under the lawful basis of ‘legal obligation’ for example when we provide salary information for tax purposes, or use ethnicity data for equality legislation purposes.
Some personnel information is used by us under the lawful basis of ‘legitimate interests’ when processing information to manage the human resources of all our employees such as their professional development, and to protect our network and information security such as vetting.
We also have a public interest, legal obligation or legitimate interest to carry out user satisfaction surveys to evaluate our performance and effectiveness and improve the service we deliver. We may contact you if you have been a victim of crime or reported an incident to us to ask for your opinion about the service you have received. Sometimes, like many police services, we may use a private company to undertake these surveys. The information we obtain from the surveys are used wherever possible to help us improve. Surrey Police will only use the minimum amount of personal information necessary to carry out a particular activity, such as your name and address and the offence type. We obtain, hold, use and disclose personal information for these purposes:
For the administration of justice – which includes the prevention and detection of crime; apprehension and prosecution of offenders; protecting life and property; preserving order; maintenance of law and order; assisting the public in accordance with force policies and procedures; national security; defending civil proceedings and any duty or responsibility of the police arising from common or statute law.
The provision of services to support the administration of justice, our legal obligations and legitimate interests – this includes staff administration; occupational health and welfare; management of public relations, journalism, advertising and media; management of finance; internal review; accounting and auditing; training; property management; insurance management; vehicle and transport management; payroll, pensions and benefits management; management of complaints; vetting; management of information technology systems; legal services and defending ourselves in civil proceedings; information provision; licensing and registration; pensioner administration; research, including customer surveys; performance management; sports and recreation; management of safety and health; procurement; planning; system testing and security.
Whose personal information do we hold?
In order to carry out the purposes described above Surrey Police may obtain, use and disclose personal information relating to a wide variety of individuals including:
Our staff, officers, volunteers, agents, temporary and casual workers; Suppliers; Complainants, correspondents, litigants and enquirers; Relatives, guardians and associates of the individual concerned; Advisers, consultants and other professional experts; Offenders and suspected offenders; Witnesses; Individuals passing information to Surrey Police; Victims (current, past and potential); Former and potential members of staff, pensioners and beneficiaries; Other individuals necessarily identified in the course of our police enquiries and activity.
We will use the minimum amount of personal information necessary to fulfill a particular purpose or purposes. Personal information can be information that is held on a computer, in a paper record such as a file or images, but it can also include other types of electronically held information such as CCTV images.
What type of personal information is it?
The type of personal information we hold will vary depending upon the reason you have had contact with us but it may include:
Your name and address; Fingerprints, DNA or photograph; Family, lifestyle and social circumstances; Education and training details; Employment details; Financial details; Goods or services provided; Racial or ethnic origin; Political opinions; Religious or other beliefs of a similar nature; Trade union membership; Physical or mental health or condition; Sexual life; Offences and alleged offences; Criminal proceedings, outcomes and sentences; Cautions; Physical identifiers including DNA, fingerprints and other genetic samples; Sound and visual images; Licenses or permits held; Criminal Intelligence; References to manual records or files; Information relating to safety and health; Complaint, incident, civil litigation and accident details.
We will use the minimum amount of personal information necessary to fulfill a particular purpose. Your personal information may be held on a computer system, in a paper record such as in a physical file or a photograph but it can also include other types of electronically held information such as CCTV or body worn video.
Where do we get the personal information from?
To carry out the purposes we have described we may obtain personal information from a wide variety of sources, including:
Other law enforcement agencies; HM Revenue and Customs; International law enforcement agencies and bodies; Licensing authorities; Legal representatives; Prosecuting authorities; Solicitors; Courts; Prisons and Young Offender Institutions; Security companies; Partner agencies involved in crime and disorder strategies; Private sector organisations working with the police in anti-crime strategies; Voluntary sector organisations; Approved organisations and people working with the police; Independent Office for Police Conduct; Her Majesty’s Inspectorate of Constabulary; Auditors; Police and Crime Commissioners; Central government, governmental agencies and departments; Emergency services such as the Fire Brigade, National Health Service or Ambulance; Persons arrested; Victims; Witnesses; Relatives, guardians or other persons associated with the individual; Current, past or prospective employers of the individual; Healthcare, social and welfare advisers or practitioners; Education, training establishments and examining bodies; Business associates and other professional advisors; Employees, officers and agents of Surrey Police; Suppliers, providers of goods or services; Persons making an enquiry or complaint; Financial organisations and advisors; Credit reference agencies; Survey and research organisations; Trade union, staff associations and professional bodies; Local government; Voluntary and charitable organisations; Ombudsmen and regulatory authorities; The media; Data Processors working on behalf of Surrey Police; CCTV systems; Body worn video and from correspondence sent to us.
Surrey Police work in Partnership in Borough Councils across Surrey and record CCTV on behalf of both parties. Anything can be recorded within 24 hours within sight and all angles of any CCTV camera. CCTV is watched within Force by authorised personnel for the intention of catching crime in process and preventing crime about to happen and supporting prosecution of crime captured. As part of the prevention and detection of crime, we may share this information with other Police Forces or borough councils in Surrey following a justifiable request for information. Information may be shared in the public forum or with newspapers for the purposes of apprehending criminals or concern for safety of vulnerable individuals. Newspapers may publish photographs captured from CCTV in the case of incidents in the public interest. Individuals in CCTV footage will not be identified unless for a specific policing reason. Due to this, any request for removal of data will not include CCTV footage where the individual has not been identified. There may be times where we obtain personal information from sources such as other police services and our own police systems such as the Crime Reporting System known as Niche RMS.
How do we handle your personal information?
We handle personal information according to the requirements of the UK Data Protection Bill and General Data Protection Regulations (GDPR). Your personal information held on our systems and in our files is secure and is accessed by our staff, police officers, contractors working on our behalf, outsourced providers in accordance with their contract and volunteers when required to do so for a lawful purpose. We will ensure that your personal information is handled fairly and lawfully with appropriate justification. We will only use your information for lawful purposes in connection with our requirement to uphold the law, prevent crime, bring offenders to justice, protect the public, manage our personnel and protect our network infrastructure and information security. We will strive to ensure that any personal information used by us or on our behalf is of the highest quality in terms of accuracy, relevance, adequacy, not excessive is kept as up to date as possible and is protected appropriately. We will regularly review to ensure it is still required and is lawful for us to continue to retain it and when no longer required we will securely destroy it. We will respect your individual rights under the Act.
Who do we share your personal information with?
To carry out the purposes described Surrey Police may disclose personal information to a wide variety of recipients in any part of the world, including those from whom personal data is obtained. This may include:
disclosures to other law enforcement agencies (including international agencies)
partner agencies working on crime reduction initiatives
partners in the Criminal Justice arena
to bodies or individuals working on our behalf such as IT contractors or survey organisations
authorities involved in offender management
ombudsmen and regulatory authorities
international agencies concerned with the safeguarding of international and domestic national security
third parties involved with investigations relating to the safeguarding of national security
to other bodies or individuals where necessary to prevent harm to individuals
Disclosures of personal information are made on a case-by-case basis, using the personal information appropriate to a specific purpose and circumstances, and with necessary controls in place. Some of the bodies or individuals to which we may disclose personal information are situated outside of the European Union - some of which do not have laws that protect data protection rights as extensively as in the United Kingdom. If we do transfer personal data to such territories, we undertake to ensure that there are appropriate safeguards in place to certify that it is adequately protected as required by the legislation. Surrey Police will also disclose personal information to other bodies or individuals when required to do so by, or under, any act of legislation, by any rule of law, and by court order. This may include:
Serious Fraud Office
Child Maintenance Service
National Fraud Initiative
General Medical Council
Nursing and Midwifery Council
Surrey Police may also disclose personal information on a discretionary basis for the purpose of, and in connection with, any legal proceedings or for obtaining legal advice.
How do we keep your personal information safe?
Surrey Police takes the security of all personal information under our control very seriously. We will comply with the relevant parts of the legislation relating to security, and seek to comply with the College of Policing Information Assurance authorised practice, and relevant parts of the ISO27001 Information Security Standard. We will ensure that appropriate policy, training, technical and procedural measures are in place. These will include, but are not limited to, ensuring our buildings are secure and protected by adequate physical means. The areas restricted to our police officers and staff are only accessible by those holding the appropriate identification, and have legitimate reasons for entry. We carry out audits of our buildings security to ensure they are secure. Our systems meet appropriate industry and government security standards. We carry out regular audits and inspections, to protect our manual and electronic information systems from data loss and misuse, and only permit access to them when there is a legitimate reason to do so. Our standard operating procedures and policies contain strict guidelines as to what use may be made of any personal information contained within them. These procedures are reviewed regularly to ensure our security of information is kept up-to-date.
What are my rights?
Right of access
The legislation allows you to request access to your personal information free of charge and requires us to provide you with access to it normally within one month of receipt of your request unless an exemption from doing so can be lawfully applied. Should you wish to request access to the personal information we may be holding about you please contact us on firstname.lastname@example.org.
Right to be informed
This places an obligation upon Surrey Police to tell you how we obtain your personal information and describe how we will use, retain, store and who we may share it with. We have written this privacy notice to explain how we will use your personal information and tell you what your rights are under the legislation.
Right to rectification
If the personal information Surrey Police is holding about you is inaccurate or incomplete you have the right to request us to correct it. If you need to tell us your information is not correct, you should raise your concern by contacting our Information Access Team using the details in the contact us section below. We will respond to you within one month unless the request for amendment is complex.
Right to erasure – also known as ‘the right to be forgotten’
Under certain circumstances, you have the right to have your personal information deleted to prevent its continued processing where there is no justification for us to retain it. Circumstances that are likely to require us to delete your information include:
where your personal information is no longer necessary in relation to the purpose for which it was originally collected and processed
when an individual withdraws consent if we are relying on your consent to hold it
if we are relying on the legitimate interests as our basis for processing and you have objected and there is no overriding reason for us to continue processing
when an individual has objected to its processing and Surrey Police is processing it for direct market research
the personal data was unlawfully processed by us in breach of the 1st principle of the legislation
the personal information has to be deleted to comply with a legal obligation
the personal information is processed in relation to offer information society services to a child
The right of erasure does not apply if your personal information is being processed by us:
to comply with a legal obligation
for the performance of a task carried out in the public interest or in the exercise of official authority
for the establishment, exercise or defence of legal claims
to exercise the right of freedom of expression and information
for archiving purposes in the public interest, scientific research, historical research or statistical purposes where erasure is likely to make it impossible to carry out or seriously impair that processing
If you wish to request your information is deleted you should raise a request by contacting our information management team whose contact information is below. We will respond to you within one month unless the request is complex.
Right to restrict processing
Under certain circumstances you have the right to ask us to restrict the processing of your personal information. This may be in cases where:
you are contesting the accuracy your information and while we are verifying the accuracy of it
your information has been unlawfully processed and you oppose its erasure and have requested a restriction instead
you have objected to us processing your information under article 21(1) and we are considering whether our legitimate grounds override those of yourself
where Surrey Police no longer requires your information but you need it to establish, exercise or defend a legal claim
If you wish to tell us to restrict the processing of your information you should raise your concern by contacting our Information Management Team whose contact information is below. We will respond to you within one month unless the request for is complex.
Right to data portability
The right to data portability allows you to obtain and reuse your personal information for your own purposes from one environment to another. This right only applies to personal information provided by an individual, where the processing is based on their consent or for the performance of a contract and when that processing is carried out by automated means. The processing of personal information within Surrey Police is necessary for the purposes we have described as the basis of public interest and official authority and are required by statute to upload the law, prevent crime, bring offenders to justice and protect the public. Please note article 20(3) and Recital 68 say this right shall not apply to processing necessary for the performance of a task carried out in the public interest or in exercise of official authority.
Right to object
You have the right to object to:
processing based on legitimate interests or performance of a task in the public interest and or exercise of official authority
processing of your information for scientific and historical research and statistics
Any objection must be on grounds relating to your particular situation. Should you wish to object you can raise your concern by contacting our information management team whose contact information is below. Where article 21(6) processing of personal information for research or statistical purposes is necessary for the performance of a task carried out for reasons of public interest we are not required to comply with an objection to the processing. An example of this is crime mapping where we use information to identify areas of specific criminality.
Rights related to automated decision making and profiling
Under the legislation you have the right not to be subject to a decision when it is based on solely automated processing, including profiling and which produces a legal effect or similar significant effect on you. This right does not apply if the decision is authorised by law, is necessary for entering into or performance of a contract or is based on your consent. Surrey Police is unlikely to carry out automated decision making because our processes involve some type of human interaction and decision making. In the legislation profiling has been described as any form of automated processing of personal data intended to evaluate certain personal aspects about you to predict things about you such as your behaviour, interests, movements or performance at work. We do not carry out automated profiling If you have any concerns about automated decision making or automated profiling you should contact our Information Management Team whose details are below.
How long will you keep my personal information?
Surrey Police keeps your personal information as long as is necessary for the particular purpose or purposes for which it is held. Personal information which is placed on the Police National Computer is retained, reviewed and deleted in accordance with the Retention Guidelines for Nominal Records on the Police National Computer. Other records that contain your personal information relating to criminal investigations; digital-media; custody; contracts; firearms; employment; domestic violence are retained in accordance with the College of Policing guidance on the Management of Police Information and the Retention and Disposal Schedule [NOTE: have asked on Taiga if this document will be brought across and available on SOH]. In broad terms these are structured according to the offence type or category, i.e serious offences against a person, firearm licences or staff administration records.
Monitoring of communications
Surrey Police may monitor or record and retain telephone calls, texts, emails and other electronic communications to and from the force in order to deter, prevent and detect inappropriate or criminal activity, to ensure security, and to assist the purposes we have described. Surrey Police does not place a pre-recorded ‘privacy notice’ on telephone lines that may receive emergency calls (including misdirected ones) because of the associated risk of harm that may be caused through the delay in response to the call. You may view it on our web site at any time of ask for a copy by contacting to our Data Protection Officer.
To contact our data protection officer by email or write to:
Data protection officer Surrey Police PO Box 101 Guildford Surrey GU1 9PE
Tel: 01483 63007
To contact our information management team by email or write to:
Information Management Team Surrey Police PO Box 101 Guildford Surrey Police GU1 9PE
Tel: 01483 630729
If you want to raise a concern with the supervisory authority
The Information Commissioner is the independent authority responsible within the UK for ensuring we comply with data protection legislation. If you have a concern about how we have used your personal information or you believe you have been adversely affected by our handling of your data you may wish to contact them using the information below:
The Information Commissioner’s office Wycliffe House Wilmslow Cheshire SK9 5AF
Further information about the ICO can be found here. The data controller is registered with the ICO under the reference Z4895085, which is renewed annually.
Changes to our privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 24 May 2018. If we plan to use your personal information for a new purpose we will update our privacy notice and communicate the changes before we start any new processing.