The London Borough of Hounslow 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 Public Health and tells you what to expect us to do with your personal information.
If you have any questions about this privacy notice or any concerns about how we process your data, please contact publichealth@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
We currently collect and process the following information:
- Address and postcode
- Name
- Email address
- Date of birth
- Age group
- Disability
- Sex and gender identity
- Marriage status
- Religion
- Ethnicity
- Pregnancy status
- Sexual orientation
- Occupation
- Health-related data (e.g. smoking habits)
How do we get your information?
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- You may provide personal data when you complete a survey or give us feedback.
The Public Health service will access this data and health-related information to determine your eligibility for the Swap to Stop scheme and send you your unique voucher code to redeem on the Totally Wicked website. We will analyse aggregate data to monitor the uptake of the Swap to Stop scheme.
Our Lawful basis for processing your information
The lawful basis we rely on for processing this information is
- Public task - The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law. Article 6 - 1(e)
If the information you provide us contains special category data, such as health, religious or ethnic information the legal basis we rely on to process is
- Reasons of public interest in the area of public health, Article 9(2)(i).
The relevant legislative provisions come from the Health and Social Care Act 2012, as follows:
Section 12
(1) Each local authority must take such steps as it considers appropriate for improving the health of the people in its area.
(3) The steps that may be taken under subsection (1) include—
(a) providing information and advice;
(b) providing services or facilities designed to promote healthy living (whether by helping individuals to address behaviour that is detrimental to health or in any other way)
It is completely optional to take part in the Swap to Stop scheme.
If you would like to withdraw from the programme, or update your information, you may request this as follows:
- write to us at the address below
- email: dataprotection@hounslow.gov.uk
- phone: 020 8583 5211
Customer Relations
London Borough of Hounslow
Hounslow House
7 Bath Road
Hounslow
TW3 3EB
See more guidance on Your rights | Data protection.
Why we need your information (purposes of processing)
The personal data we collect will be used for the following purposes:
- To determine eligibility for the Swap to Stop scheme.
- To ensure only one vape kit is distributed per person.
- To contact you with your unique voucher codes for your vape starter kit and follow-on kits.
- To monitor the uptake of the Swap to Stop scheme.
Who your information may be shared with (internally and externally)
We share your information with:
- Internal health teams
We share your pseudonymised information with:
- Internal business intelligence teams.
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.
When you redeem your voucher, you will be redirected to Totally Wicked’s website. Totally Wicked is an independent data controller for any data you provide during redemption and age verification. Please refer to their privacy notice for details.
We do not use your data for marketing purposes or profiling beyond what is necessary for public health and service planning.
How long we keep your information
We will keep your date of birth, age group, disability, sex and gender identity, ethnicity, marital status, religion, sexual orientation, pregnancy status, occupation, and health-related data (e.g. smoking habits) for 6 months after the scheme ends (ends on 31 March 2026).
We will keep your address and postcode, name, and email address for 6 years, as per the Council data retention policy. This is to ensure that residents do not apply for the Swap to Stop scheme more than once, should the scheme be extended. The scheme is strictly limited to one free vape kit per person.
We will then dispose of your information in the most secure manner possible.
If the scheme ends permanently, all personal data will be securely deleted after 6 years in line with the Council’s retention policy, except where required for statutory audit purposes.
Transfers to third countries
All the information you provide us is held within the UK & European Economic Area.
Business Intelligence, Profiling and Analysis
We may analyse your personal information to improve the council’s services for the following purposes:
- undertake statutory functions efficiently and effectively
- service planning by understanding your needs and your community's needs and to provide the services that you or your community request
- understanding what we can do for you and your community and inform you of other relevant services and benefits
- help us to build up a picture of how we are performing at delivering services to you and what services the people of Hounslow need
- analysis of costs and spend of services we provide so that we can ensure better and efficient use of public funds
The council is committed to using pseudonymised or anonymised information where practical, and in many cases this will be the default position.
Pseudonymisation is a procedure by which the most identifying fields within a data record are replaced by one or more artificial identifiers, or pseudonyms. There can be a single pseudonym for a collection of replaced fields or a pseudonym per replaced field. An example of this is your National Insurance number or Council Tax Reference number.
Anonymisation is the process of removing identifying particulars or details. This means that the data cannot be linked back to identify you.
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
The Council 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:
Complaints Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB
Data Protection Officer
The Council’s Data Protection Officer can be contacted on:
InformationGovernance@hounslow.gov.uk
Information Governance Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB
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: Information Commissioner's Office
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
Wycliffe House
Water Lane
Wilmslow Cheshire
SK9 5AF
Telephone: 0303 123 1113 or 01625 545 745
Email: casework@ico.org.uk
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.
