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.
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.
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:
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.
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.
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.
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]
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
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.