Privacy policy
We are committed to protecting your privacy when you use our services. This privacy notice explains how we use your information you and how we protect your privacy.
A list of services we provide will be available at the bottom of the page soon. Under each service we’ll include more information about what we do with your data within that service, where it is different to the main policy below. We’ll also provide information about who we may share your information with and why.
If you have any concerns or questions about how we look after your personal information, please contact us at dataprotection@stepforwardluton.co.uk.
*Please note: this email address is for data protection queries and subject access requests only.
Who we are
Step Forward Luton is a partnership among Luton’s civic, voluntary and business organisations working together to promote Luton as a great place to live, work, invest, visit and study. Our website address is: stepforwardluton.co.uk. This policy covers all Step Forward Luton sites including place.stepforwardluton.co.uk and invest.stepforwardluton.co.uk
Data controller
Luton Council
Luton Council, Town Hall, George Street, Luton, LU1 2BQ
Data protection officer
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Luton Council, Town Hall, George Street, Luton, LU1 2BQ
Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can identify you.
We may collect the following types of personal information about you depending on which services you receive from us:
Contact:
Name, address, email, telephone number
General:
Date of birth, gender, marital status, national insurance number, driving license, vehicle identification, passport, languages spoken, immigration status, ethnicity, sexuality, religion
Family relationships:
Details of family relationships, marital status, family breakdown and relationships, next of kin, emergency contact details, child in local authority care
Employment and education:
Occupation, education history, qualifications, references, contact with other educational professionals/services, school exclusion history, special educational needs, school, teacher assessment judgements, attendance and attainment information, application history, CV, Interview notes/scores, proof of right to work documentation, proof of address, proof of identity, references, education and professional qualifications, disciplinary data, DBS number, DBS expiry, HCPC number (Social Work), trade union membership, trade union membership
Financial information:
Income, pensions, benefits and allowances, bank accounts, savings, investments, unique tax reference, property ownership, council tax, debt history, rent history, business activities, landlord details
Criminal history:
Criminal convictions, cautions and restorative justice
Health information:
Dentist and GP contact details, medical conditions including mental health, mental capacity assessments, history of substance abuse, smoking status, disability data, pregnancy data, blue badge number, NHS number, sexual health
Some of the personal information we might collect is more sensitive than others and is known as special category information. This may be information about your:
- criminal history
- ethnicity
- genetic or biometric data
- physical or mental health
- political opinion
- religious or philosophical beliefs
- sexuality
- sexual health
- trade union membership
It’s often information you would not want widely known and is very personal to you. We will ensure this information is well protected and that we only use and share it if we have to.
We may need to use some information about you to:
- deliver services and provide support to you
- manage the services we provide to you
- train and manage the workers who deliver those services
- help investigate any complaints you have
- keep track of spending on services
- check the quality of our services
- help with research and planning of new services
- detect and prevent fraud
There are a number of legal reasons why we need to collect and use your personal information.
Personal data
Consent:
You have given clear consent for us to process your personal data for a specific purpose.
Contract:
The processing is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract.
Legal obligation:
The processing is necessary for us to comply with the law
Vital interests:
The processing is necessary to protect your life
Public task:
The processing is necessary for us to perform a task in the public interest or for our official functions as a public authority.
Special category data
Consent:
You have given clear consent for us to process your personal data for a specific purpose.
Employment, social security / social protection: Your data is necessary for employment or social security purposes
Vital interests: The processing is necessary to protect your life
Not for profit: Your data is processed by a not-for-profit body that you belong to
Public domain: You have already made your information publicly available
Legal defence claims: It is necessary for legal cases or by the courts
Substantial public interest: It is for the benefit of society as a whole
Adult social care: It is necessary to deliver health or social care services
Public interest in public health: It is necessary to protect public health
Scientific/historical research, statistics or public archiving: It is necessary for archiving, research, or statistical purposes
If you want to see more information about the why our services collect data about you please refer to our service privacy notices.
We will only collect and use personal information if we need it to deliver a service or meet a specific requirement.
If we don’t need your personal information we will either keep you anonymous if we already have it for something else or we won’t ask you for it. For example in a survey we may not need your contact details we’ll only collect your survey responses.
If we use your personal information for research and analysis, we’ll always keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.
We will never sell your personal information to anyone else. Electoral registration information is accessible to the public and to specified organisations.
The law gives you a number of rights to control what personal information is used by us and how it is used by us. You are not required to pay any charge for exercising your rights. We have one month to respond to you.
Right of access
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
For example we will not share confidential information about other people, information that a professional thinks will cause serious harm to you or someone else’s physical or mental wellbeing or information that may stop us from preventing or detecting a crime.
Right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure
You have the right to ask us to erase your personal information in certain circumstances.
Right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances.
Right to object to processing
You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.
Right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you.
The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.
Automated decision making and profiling:
You can ask to have any computer made decisions explained to you, and details of how we may have ‘profiled’ you. You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you’ve consented to it.
You also have the right to object if you are being ‘profiled’. Profiling is where decisions are made about you based on certain things in your personal information, for example, your health conditions. If we are carrying out any of these activities we will:
- tell you about the processing
- introduce simple ways for you to request human intervention or challenge a decision
- carry out regular checks to make sure that our systems are working as intended
If we are processing your information for criminal law enforcement purposes, your rights are slightly different.
We may not always be able to change or remove information that we hold about you because in some cases we are required in law to retain it. However, where we can’t delete your data we will correct factual inaccuracies and might, in certain circumstances, include your comments in our record to show that you disagree with it. We will always provide a written response explaining our decision.
We cannot delete your information where:
- we’re required to have it by law
- it’s used for freedom of expression
- it’s used for public health purposes
- it’s for, scientific or historical research, or statistical purposes where it would make information unusable
- it’ is necessary for legal claims
If you would like to access your records or want to use any of the rights outlined above please contact us by emailing hello@stepforwardluton.co.uk
Most of your data is obtained from you when you apply for our services. In addition we might receive information about you from other organisations that work with us to provide services for you. Examples of these organisations are:
- police authorities
- other local authorities
- fire and rescue authorities
- ambulance services
- pension authorities
- residential and nursing care homes and supported living providers
- voluntary sector organisations
- The Care Quality Commission
- Health and Care Professions Council
- Primary Health sector such as GPs
- the courts
- Traffic Penalty Tribunal
- Traffic Enforcement Centre
- appointed enforcement agents
- immigration services
- OFSTED
- Office of National Statistics
- the council’s insurance provider
- NHS trusts and strategic health authorities
- clinical commissioning groups
- passenger transport authorities
- waste authorities
- Greater London Authority and its functional bodies
- Home Office
- Cabinet Office
- housing associations
- probation authorities
- insurance fraud bureau
- other government departments
- domiciliary care agencies
- department for work and pensions
- Vehicle and Operator Services Agency
- Gambling Commission
- National Fraud initiative
- Environment Agency
We use a range of organisations to either store personal information or 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 and our own privacy standards. This is usually through a contract or an information sharing agreement.
We might provide information to other organisations including:
- police authorities
- other local authorities
- fire and rescue authorities
- ambulance services
- pension authorities
- residential and nursing care homes and supported living providers
- voluntary sector organisations
- The Care Quality Commission
- Health and Care Professions Council
- Primary Health sector such as GPs
- the courts
- Traffic Penalty Tribunal
- Traffic Enforcement Centre
- appointed enforcement agents
- immigration services
- OFSTED
- Office of National Statistics
- the council’s insurance provider
- NHS trusts and strategic health authorities
- clinical commissioning groups
- passenger transport authorities
- waste authorities
- Greater London Authority and its functional bodies
- Home Office
- Cabinet Office
- housing associations
- probation authorities
- insurance fraud bureau
- other government departments
- domiciliary care agencies
- department for work and pensions
- Vehicle and Operator Services Agency
- Gambling Commission
- National Fraud initiative
- Environment Agency
- other internal council teams
Data sharing can bring important benefits to both the council and its citizens, making your lives easier and helping us to deliver efficient services. It is important, however, that we have high data protection standards, sharing data in ways that are fair, transparent and accountable.
We will make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them 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). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
- Pseudonymisation: meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of the Council could work on your information for us without ever knowing it was yours. Read our anonymisation and pseudonymisation policy.
- 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 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).
The majority of personal information is stored on systems in the UK. But there are some occasions where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the EU.
We have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with any third party who may transfer it out of the EU.
If we need to send your information to an ‘unsafe’ location we’ll always seek advice from the Information Commissioner first.
There’s often a legal reason for keeping your personal information for a set period of time.
If you have a questions or concern about how we are collecting or using your personal information, we would appreciate an opportunity to deal with your concerns before you contact the Information Commissioner’s Office (ICO).
You can raise your concerns by contacting our Data Protection Officer.
Data Protection Officer
E: dataprotection@stepforwardluton.co.uk
T: 01582 546398
Or write to:
Data Protection Officer
Business Intelligence team
Luton Council
Town Hall
Luton
Beds
LU1 2BQ
If you are not happy with our response or you would like 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
T: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Alternatively, visit ico.org.uk or email casework@ico.org.uk
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We do not collect or store any other personal information (for example your name or address) so this data cannot be used to identify who you are.