Privacy notice for Equality Monitoring

What do we use the information for?

As a policy team, we contribute to and / or lead on needs assessments which may require consultation through our East Riding Equality Network or Disability Advisory Group and with local community groups. 

• To develop a clearer picture of who does and doesn’t use the service
• To establish how service delivery can be improved in order to remove barriers and advance opportunity.

We recognise that your personal information is important to you, and we take our responsibilities for ensuring that we collect and manage it proportionately, correctly and safely very seriously.

What information do we hold and use?

It is the responsibility of any service area, within the council, that carries out monitoring to provide a clear rationale for the collection of data. Service areas may collect and process the following information:

• Personal information (including full name, full residential address)
• Contact details (such as email address)
• Location data (including postcode)
• Characteristics (such as ethnicity, sex, religion).

Please note that the above information is only collected if it is relevant to the purpose of the survey / consultation taking place. Any personal data collected as part of a survey / consultation process will not be used to identify responses and will be stored appropriately.

On what grounds do we use the information?

We collect and lawfully process your personal information under the following: 

• Equalities Act 2010
• Public Sector Equality Duty 2011.

We process personal data for the following reasons:

• GDPR Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subject
• GDPR Article 6(1)(e) - processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

We process special category data for the following reasons:

• GDPR Article 9(2)(a) - the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject
• GDPR Article 9(2)(b) - processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.

How do we collect this information?

We may collect information in the following ways:

• Paper, electronic or online forms
• Email
• Telephone.

Please note that the above is not an exhaustive list and it is down to individual service areas how information is collected. 

Who do we share your information with?

Equality data (i.e. anonymous data on numbers or percentages relating to each protected characteristic) is captured corporately for publishing on the council’s website, in order to comply with our legal obligations, under the Equality Act 2010 and Public Sector Equality Duty 2011. There are no personal identifiers contained within the data published.

Needs assessments are often carried out in partnership with other public sector bodies. This is made clear in any surveys/consultations that are a part of this assessment process. Therefore, we may disclose your information to others, but only where this is necessary either to comply with our legal obligations or as permitted by Data Protection legislation. We may share it with other public service bodies including the NHS, social care, the police and other local authorities.

The reasons why we may share your data with other public bodies are as follows:

• To review and improve our performance and delivery of services
• For the prevention and or detection of crime
• Where necessary to protect individuals from the risk of harm or injury
• Where otherwise permitted under the General Data Protection legislation.

The council has a contract with AA Global Language Services Ltd to provide translation and interpretation services to ensure those who do not speak English can still access our services.  The provider covers over 400 languages, including British Sign Languages and Braille and they offer face, to face, video and telephone interpreting, along with written translation services. Information will be shared as appropriate with the provider to enable these services to be delivered, such as, for example,  documents to be translated. You can find out more about AA Global Language Services Ltd on their website.

AA Global (external website)

We will only disclose your sensitive or confidential information, such as medical details to a third party, if we are legally required to do so, or where we have good reason to believe that failing to share the information would put you or someone else at risk of harm.

We will not pass your personal information to external organisations for marketing or sales purposes or for any commercial use without your prior expressed consent.

How long do we store it and is it secure?

The equality monitoring team has retention schedules in place to ensure that information is only held for as long as it is needed. We will not keep your information for longer than is required to by law.  Your information will be disposed of in a controlled and secure manner in accordance with the council’s Records Management and Data Quality Policy. The council’s IT security and confidentiality policies ensure that your information is protected, and accessed only by staff directly involved in your case.

For information on how long your information will be held visit the retention page

What rights do you have?

The rights that you have depend upon the grounds upon which we collected your information. All of the rights you could have outlined upon the data protection rights page. 

In most cases, people who have been involved with equalities monitoring will have the following rights:

• The right of access - you are entitled to see the information the service holds about you 
• The right to rectification - we will amend the information accordingly, if any of the information that the service holds about you is incorrect
• The right to restrict processing - you may wish to limit how we use your data 
• The right to object - in addition to the right to limit the use of your data, you also have a right to object to the use of your data for certain actions
• The right to erasure/right to be forgotten - in certain circumstances, you may be able to ask for some of the information we hold to be deleted. The service has determined that all requests to permanently delete a service user record will be dealt with on an individual basis. 

To exercise any of your above rights, please visit the data protection rights pages for more information.

Where can I find out more?

If you would like to know more about how the council uses information, your rights or have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance; contact details are available on the general privacy information page. Alternatively, you can contact the Information Commissioner’s Office (ICO). The ICO is the UK’s independent authority set up to uphold information rights in the public interest and they handle public concerns regarding organisations information rights practices. 

Information Commissioner’s Office (external website)

When was this privacy notice last updated?

We will continually review and update this privacy notice to reflect any changes in our services, feedback from customers, and to comply with any changes in the law. This privacy notice was last updated on 25 May 2021.