Business Intelligence, Profiling and Analysis
The London Borough of Hounslow (LBH) is committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.
This privacy notice applies to services provided by the Business Intelligence, Profiling and Analysis Function and tells you what to expect us to do with your personal information.
This Privacy Notice should be read in conjunction with the Council’s Privacy Notice at Privacy notice | Privacy notice | London Borough of Hounslow
If you have any questions about this privacy notice or any concerns about how we process your data, please contact InformationGovernance@hounslow.gov.uk. The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.
What type of information we have
To provide you with support and services, LBH needs to collect and process information about you. This is your personal information. The Business Intelligence Analysis and Profiling function work on information collected from across LBH; we currently process the following information:
- Your name
- Date of birth
- Mobile telephone number
- Landline telephone number
- Unique property reference number
- Unique pupil number
- National Insurance number
- National Health Service number
- Special category personal information
- Sometimes we collect and process more sensitive information which needs more protection. This is likely to include anything that can reveal your:
- Religious or philosophical beliefs
- Physical or mental health
- Sexual orientation and sex life
- Political opinion
- Criminal history
How do we get your information?
Most of the personal information the Business Intelligence Profiling and Analysis function processes is provided to LBH directly by you for one of the following reasons:
- You may give LBH and its service providers your personal data by filling in forms or by correspondence (e.g., post, phone, email)
- You may provide personal data when you sign up to enquire about LBH provided services, interact with one of LBH’s services, request information, complete a survey, give us feedback, or make a compliant
We also receive personal information indirectly, in the following scenarios:
- LBH partners, central government departments, NHS organizations, external service providers (who may be processors for LBH), schools, voluntary and community groups.
- When someone is concerned about you and provides your details.
The information we collect is limited to what is necessary to provide you with equitable services and/or support. In some circumstances where it is optional for you to provide certain information, this will be explained to you.
If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information.
Our Lawful basis for processing your information.
The business intelligence team do not always hold personal information in their own right. The legal basis for processing will be whatever the legal basis is for the service holding the information.
The lawful bases we rely on for processing this information are: Legal obligation – we need to process your information to comply with the law:
- Public task – we need to process your information to provide you with certain LBH services
- Contract – we need to process your information as part of a contract
- Vital interest – we need to process your information to protect someone’s life in an emergency
- Consent – we need your permission to use your personal data
- Legitimate interest – we need to process this information for legitimate interests e.g., when we investigate for fraud, for employment purposes, or when we hold festivals and publish photos of crowds.
Where LBH relies on your consent to process your personal data, you have the right to withdraw your consent at any time. If you are unsure how to withdraw your consent please contact the Data Protection Officer at InformationGovernance@hounslow.gov.uk. You do not have the right to withdraw consent if LBH does not need to rely on your consent to process your data.
In addition to a UK GDPR Article 6 basis for processing, we will only process special category data if we can meet one of the specific conditions in Article 9. The conditions most frequently relied upon are:
(a) Explicit consent (c) Vital interests (e) Made public by the data subject (g) Reasons of substantial public interest (with a basis in law)
(h) Health or social care (with a basis in law) (i) Public health (with a basis in law) (j) Archiving, research and statistics (with a basis in law).
When relying on conditions (h), (i) or (j), we also need to meet the associated condition in UK law, set out in Part 1 of Schedule 1 of the DPA 2018.
When relying on the substantial public interest condition in Article 9(2)(g), we also need to meet one of 23 specific substantial public interest conditions set out in Part 2 of Schedule 1 of the DPA 2018 Schedule 1 of the DPA 2018.
Why we need your information (purposes of processing)
The personal data collected will be used by the Business Intelligence Analysis and Profiling function to produce insight across LBH and partner service areas (e.g., health, financial, education, housing, environment,) in order to:
- Undertake statutory functions efficiently and effectively
- Develop an understanding of resident and community needs
- Provide services requested by the community
- Provide insight to service areas
- Inform residents of relevant services and benefits
- Monitor performance of service delivery
- Analyse cost of services to ensure efficient use of public funds.
The Business Intelligence Profiling and Analysis function creates insight together with summary statistics (where data is aggregated appropriately to a sufficiently high level). Our aim is to be open in the work we do and to share insight reports and summary statistics on the public facing website, so that we are able to inform teams across LBH, partner services and also to inform residents and external organisations about our understanding of the borough, the place and the population.
We need to collect information so that it can be linked at the most granular level possible, which ensures that when aggregations are produced, we are more confident in the accuracy of the summary statistics. Aggregates that are produced only from aggregate level data mask needs and support that may be required by smaller cohorts in the population.
LBH is committed to using pseudonymised or anonymised information as much as is practical, and in many cases this will be the default position.
Automated Decision Making and profiling
‘Automated decision making’ is where decisions are made about an individual by a computer, without any human involvement.
‘Profiling’ means that personal data is processed in an automated way to evaluate a person’s health, reliability, preferences, interests, etc…, and to analyse or predict behaviour.
We do on occasions carry out profiling on behalf of service areas to enable Hounslow Council, as a local authority, to target services to those in society who are in need of help and support and who may suffer harm without the Council’s assistance, where the Council has a statutory obligation or where it is allowed in law.
We may also combine all the information you give us into one profile. This will help us better understand your needs and ensure we offer you the right services. It means we have an accurate record of your basic personal data, like your name, date of birth, address, etc…
If any of the Council’s services asks us to carry out any automated decision making and profiling using your personal information, this will be explained in the service specific privacy notice.
Who your information may be shared with (internally and externally)
Externally: we do not share personal information externally unless there is a legal duty
Internally: if required by service areas then personal information that has been linked and analysed may be shared back with the service area that had made the original request for an insight report. Note that in almost every case the Business Intelligence Analysis and Profiling function only shares aggregated information about cohorts of the population and not individual record level data.
There will be times when we are under a legal duty to share information. This includes, but is not limited to:
- Disclosure under a court order
- Sharing with the Ministry of Justice for inspection purposes
- Sharing with the police for the prevention or detection of crime
- Where there is an overriding public interest to prevent abuse or serious harm to others
- Disclosure to a Regulator if we identify a situation of potential misconduct or if the information is requested.
We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.
How long we keep your information
The record level data used in the analyses we carry out on behalf of service areas are reviewed every December; we keep data up to three years following the production of any summary report.
The record level data used in analyses we carry out as part of the scrutiny function of local councillors is retained for a four-year period (the length of an administration’s term in office).
The record level data used in the analyses we carry out to monitor health outbreaks will be retained until the outbreak ceases.
We will then dispose your information in the most secure manner possible.
Transfers to third countries
All the information you provide us is held within the UK & European Economic Area.
Data Matching and Auditing
We are required by law to protect the public funds we administer. We may use the information you provide to us for the prevention and detection of crime. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Department for Work and Pensions, other local authorities, HM Revenue and Customers and the Police.
LBH uses data matching as a way of processing large volumes of information. While this can be a useful way of detecting fraud, it also enables us to identify information that is inaccurate or out of date, helping us comply with Data Protection law, while improving service provision.
As part of LBH’s fraud prevention and detection activities, LBH participates in the National Fraud Initiative (NFI). The data matching exercise is run by the Cabinet Office.
Your data protection rights
The rights available to you depend on our reason for processing your information. For further information about your data protection rights and how to make a request, please see ‘Your rights’
Your right to make a complaint
LBH tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
If you want to make a complaint you can contact us on:
London Borough of Hounslow
7 Bath Road
Data Protection Officer
LBH’s Data Protection Officer can be contacted on: InformationGovernance@hounslow.gov.uk
Information Governance Team
London Borough of Hounslow
7 Bath Road
Information Commissioner’s Office
The Information Commissioner is the UK's independent body set up to uphold information rights.
If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website: https://ico.org.uk/
If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:
Information Commissioner's Office
Telephone: 0303 123 1113 or 01625 545 745 Email: firstname.lastname@example.org
A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176. You can view our registration on the Information Commissioner's website.