Vetting Privacy Notice
This privacy notice applies to vetting checks undertaken by Gloucestershire
Constabulary. It explains how we intend to collect, store and handle your
personal data and that of third parties in the course of conducting police
vetting checks.
Data Controller
The Chief Constable of Gloucestershire Constabulary is the “Data Controller”
and as such has overall responsibility for the lawful processing of all personal
data processed by the force.
Address:
Gloucestershire Constabulary
Police HQ
1 Waterwells Drive
Waterwells
Quedgeley
GL2 2AN
What is Vetting and Why Do We Collection Information?
Vetting is a risk management process. It is used to assess any potential risk
posed to a police force or wider service and, where appropriate, assist in the
identification of proportionate and realistic risk mitigation measures.
Lawful Basis for Processing
We will process your personal data and that of any third parties (such as
family members, relatives, associates) in accordance with the College of
Policing Vetting Code of Practice, associated Authorised Professional
Practice (APP) and the Police Act 1996.
The lawful bases we rely upon for processing this information are:
a) To allow us to perform our public task
b) The performance of a contract with those who wish to work with Gloucestershire Constabulary or the Office of the Police and Crime
Commissioner and any employee of contractors procured by Gloucestershire Constabulary.
c) To meet a legal obligation to secure the maintenance of an efficient and
effective Police Force
What Information Is Collected?
Depending on the level of clearance required, we will collect the following
information:
- As a minimum, we will collect your personal information i.e. name, home
address (including previous address where necessary), date of birth and
national insurance number - Depending on the vetting level, we may collect information in relation to
your family members (including your partner/children) and potentially, your associates. It is the responsibility of the applicant to inform those named on the vetting form that their details have been provided for the purpose of the vetting process. - Social media information (once extracted, data is stored and retained)
Financial records including credit checks (once extracted, data is stored
and retained) - Alleged or actual criminal offences
Special Category Data
As part of the vetting process, Special Category Data may be collected.
Special Category Data includes information about your:
- Race
- Ethnic origin
- Religion
- Biometric data
- Sexual orientation
Protected Characteristics
The vetting form requires the disclosure of sensitive data, including data
relating to protected characteristics.
There is no statutory protection for individuals who fail to disclose this
information, where it is legitimately required.
Vetting of transgender individuals
Within its vetting process Gloucestershire Constabulary recognises its legal
obligations under the Equalities Act 2010 and the Gender Recognition Act 2004 with particular attention paid to Section 22 (GRA 2004) regarding
disclosure of Protected Information. Additionally Gloucestershire
Constabulary acknowledges the government guidelines and the requirements
to secure 'Protected Information' whether it is communicated verbally,
materially or held electronically as required under UK law. Any disclosed
information is managed by these protocols and is not disclosable to any other
parties without explicit written permission from the owner of the Protected
Information. Gloucestershire Constabulary acknowledges its legitimate aim
for requesting disclosure and its legal obligations under these requirements.
Should you have any concerns specifically regarding the disclosure of
information in relation to gender history please make contact with the Equality
and Diversity team on [email protected].
Please be reassured that all information is treated in the strictest confidence
and only used for the purposes of vetting.
Where you are providing details of another individual (Partner, family
members etc.) and this discloses their (Trans) gender history the same
protections are afforded.
The applicant is obliged to provide this information, however it is recognised
that these security checks will seek information that may lead to the
identification of transgender status. This information will remain confidential
and the disclosure of this information will be restricted to those members of
staff involved in the vetting process who will be required to honour that
confidentiality under Section 22 of the Gender Recognition Act (2004).
How Is The Information Processed?
Your personal data and that of third parties will be processed in accordance
with the Vetting Code of Practice and APP dependent on the level of access
required to Police assets, in the form of infrastructure and information assets.
The Vetting form that you are required to complete and provide personal data
is proportionate and necessary for your level of Vetting.
The information you provide will be checked against Police databases (Local
and National systems) and information systems.
Where applicable, it will also be checked against ‘open source’ internet, the
records of Credit Reference Agencies and other third party records. Where Credit Reference Agency records are checked, this will be for the
applicant only and not for any other individuals named on the form.
Any information which is revealed as a result of the vetting process is
reviewed by a vetting practitioner. There is no automated decision making
process.
Whilst you can decline to provide some or all of the information required in
the vetting forms, it will not be possible to conduct a meaningful risk
assessment and clearance cannot be granted.
In cases where roles require National Security Vetting clearance; United
Kingdom Security Vetting Services (UKSV) are the providers of this.
Gloucestershire Constabulary will submit your details to their system and they
will process your application. The UKSV have their own privacy notice.
How Is The Information Stored and For How Long?
The information you provide is stored electronically in secure databases /
paper copy. Access to these databases/ papers is strictly restricted to those
within Vetting and those with an operational ‘need to know’.
Vetting records are kept only for as long as necessary. The retention periods
are documented in the Force Retention and Disposal Schedule.
Is The Information Shared With Anyone?
Your personal information may be shared with the Human Resources (HR)
Department for the purposes of adding you to the HR system. The personal
information of any other individuals named on the form will not be provided to
HR.
The above also applies to any external personnel who require unsupervised
access to force premises, information, systems or other assets.
Risk Mitigation
On rare occasions where a risk has been identified, Gloucestershire
Constabulary may consider that it is possible to mitigate that risk to an
acceptable level by sharing relevant information with someone within your
line management chain. Should this apply to you, we will not share your
personal data without discussing this with you first and obtaining your explicit
consent. If we seek to do this we will give you further explanation of the
reasons why and purpose and also explain your rights with regard to
providing and withdrawing consent.
Personal information provided on the vetting form may, where necessary and
proportionate, be shared with other departments of the force, other police
forces or external agencies. This will be considered on a case by case basis
and be limited to only the information which is necessary, in accordance with
the relevant legislation. (Further information relating to organisations we
share data with can be found in the Constabulary’s Privacy Notice).
Information provided within the vetting form is not normally transferred
overseas unless there is a requirement due to residency and/or checkable
history. Details from your application may be forwarded to ACRO for checks
to be completed. Further details in relation to this process can be found at ACRO Criminal Records Office.
If your clearance is refused or withdrawn and you decide to appeal, we will
provide those conducting the review with relevant personal data to enable
them to consider your appeal.
Statistical Information
Information provided on the vetting form may be used for the purposes of
statistical information. Such data will be fully anonymised.
Your Data Protection Rights
Under data protection law, you have certain rights in relation to how we
process your data. However, these rights will be dependent on why the
information was collected and how it is being used. For more information
about your rights, please refer to the Information Rights sections of the
Constabulary’s full Privacy Notice.
Contact Details
Force Vetting
If you are worried about the confidentiality of Gloucestershire Constabulary’s
vetting process or should you wish to have a confidential conversation about
how any of your personal information is handled and the protection it is
afforded, please contact the vetting unit at [email protected]
Data Protection Officer
By mail:
Data Protection Officer
Gloucestershire Constabulary
Police HQ
1 Waterwells Drive
Waterwells
Quedgeley
GL2 2AN
Or by email: [email protected]
Information Commissioner
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 you can
contact them using the information below:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Review
We keep our vetting privacy notice under regular review.
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.
Full Privacy Notice
A comprehensive Privacy Notice in relation to how personal information is
processed by the Force is available on our website. View the privacy notice.