Renfrewshire Council

Why we need your personal information

We need your personal information for your role as an elected member with the Council.

We also may need to share information with other organisations because we are under a legal obligation to do so.

The information we collect and what it's used for

We need your personal details to identify you and communicate with you, including your:

• name
• national insurance number (NI)
• contact details, including your home address, telephone numbers and email addresses.

We need your personal banking details to process all payments due to you for your tenure with the Council.

Your information will also be used to check your eligibility to work in the United Kingdom.

We may need your employment history, qualifications, training certification and licenses, like a driving license, to:

• validate you are qualified for your role
• calculate any allowances or statutory payments you are entitled to in your tenure.

We may need to do Disclosure, Protecting Vulnerable Groups (PVG) or Violent and Sex Offender Register (ViSOR) checks.

Council Tax Records

Councillors are obliged, under the Councillors' Code of Conduct, not to vote on certain matters in relation to council tax if in council tax arrears of two months or more. We will check your council tax records to ensure you are eligible to vote.

We may also check your Council tax records in response to freedom of information (FOI) requests received by the Council. The Council is subject to FOI legislation. Often requests are received which seek disclosure of information held by the Council about Councillors. 

Such requests are carefully assessed, and we will only release personal information in response to FOI requests if this complies with data protection law. We are regularly asked for details of Councillors with council tax arrears. Current decisions of the Scottish Information Commissioner, the FOI Regulator, mean that we may be obliged to disclose the identities of elected members who have had reminders sent or are in arrears with council tax. 

Such requests are, however, dealt with on a case-by-case basis and if there are particular personal circumstances relating to the council tax payment history then it may be possible to withhold identities on the basis of the personal data exemption. 

This is, however, subject to the ultimate decision of the Scottish Information Commissioner and no guarantee of anonymity can be given even if there are relevant personal circumstances. In the absence of such personal circumstances, we are unable to withhold identities.

Any elected member whose identity could potentially be released in relation to requests for council tax payment information will be notified of the request by the Head of Corporate Governance and their views sought on whether they object to disclosure and whether there are any personal circumstances they wish to discuss relevant to the arrears. 

However, the ultimate decision on releasing information must necessarily be taken by officers (or ultimately by the Commissioner) and information may need to be released even where the member objects.

Other data we may need to collect

During your tenure as a councillor, we may also collect data about your use of council premises, equipment, work laptops or work phones, including:

• telephone numbers you have called and the date, time, and duration of incoming and outgoing calls
• websites you have visited, including the date and times you visited the website
• emails you have sent and received, including dates, times, subject, sender and recipient
• details of media files stored on our network
• use of unencrypted USB devices
• entry and exit of automated door systems
• CCTV footage.

This information may be used in line with the Council's ICT Acceptable Use Policy.

Some councillors may also use Renfrewshire Council services. We process information on service users, including service users who are members of staff, in accordance our main privacy policy

Who we share your information with

For financial and pay related purposes

We will share essential payroll information and data:

• with other public bodies such as HMRC, where the law requires this.
• to make pension benefit calculations and contributions if you are a member of the local government pension scheme.
• to make payroll deductions or salary sacrifice contributions, such as charitable giving, additional voluntary (AVC) contributions towards your pension, trade union subscriptions, credit union contributions or payments toward court orders.

For Fraud Prevention Purposes

The Council is legally obliged to safeguard public funds so details held are, from time to time, checked internally for fraud prevention and verification purposes and may be shared with other public bodies for the same purpose. 

As well as sharing certain data with other public bodies such as HMRC when the law requires this, the Council will also generally comply with requests for specific information from other regulatory and law enforcement bodies where this is necessary and proportionate.

The Council must participate in the National Fraud Initiative in Scotland and so, passes information on request about staff and councillors (primarily payroll data) to Audit Scotland for data matching to detect fraud or possible fraud.

For duties or requirements of your role

We need to process your personal information when you are required, as part of your duties, to attend or speak at council boards, committees, or sub-committees. If these meetings are broadcast online, the recording or images of the meeting, including the attendance or contribution of councillors, will be published on our website.

For meeting standards and codes of conduct

We may need to share your information with public bodies including the Standards Commission for Scotland for the promotion and enforcement of the councillor's codes of conduct.

Register of Interests

The Council is obliged to set up and make available for public inspection a register of councillors' interests.

These interests relate to:

• remuneration
• other roles such as unremunerated directorships
• contracts
• election expenses
• houses, land, and buildings
• interest in shares and securities
• gifts and hospitality
• non-financial interests
• close family members who have transactions with the Council or are likely to do business with it.

The Council will publish an online version of the Register, which can be viewed by any member of the public through the Committee Management Information System (CMIS). 

While the electronic version of the Register of Interests need not include personal address information, the Council is required to make available the full version of the Register of Interests for public inspection.

For your health and safety

We may need to share information in relation to an accident at a Council premises or workplace with the Health and Safety Executive (HSE).

Legal basis for using your information:

Processing your personal information is necessary for the performance of Council public functions in the public interest.

Consent

We will not ask for consent in cases where we need to process your information to carry out our public functions. If we ask for your consent to process your information for a particular purpose, you have the right to withdraw this, in whole or in part, at any time. We will explain any consequences of this to you, including any impact on the service being delivered.

Transferring your information outside the UK or the European Economic Area (EEA):

Information published on the Council's website (including video footage of webcast meetings and committee reports) can be accessed from anywhere in the world.

How long we keep your data for

The council maintains a records retention and disposal schedule which sets out how long we hold different types of information for.

Your rights under data protection law

You have a right to:

• access to your information - you have the right to request a copy of the personal information that we hold about you.
• have your information corrected - we want to make sure that your personal information is accurate, complete, and up to date. You can ask us to correct any personal information about you that you believe is not accurate.
• have your information deleted - you have the right to ask us to delete personal information about you if:
  • you think we no longer need the information for the purposes for which it was originally intended
  • you have validly objected to our use of your personal information - see restricting how we use your information below.
  • our use of your personal information is not legal or not for our legal obligations.
• ask us to stop using your personal information for direct marketing purposes.

Restricting use of your information

You may ask us to restrict how we use your personal information.

This may apply if we need to:

• check the accuracy of personal information that we hold about you
• assess an objection you have made about the use of your information.

You may also ask to restrict the use of your personal information if we no longer have a basis for using it, but you don't want it to be deleted.

In this case, we may only use the relevant personal information with your consent for legal claims or where it is in the public interest to do so.

Corrections and complaints

You can email the Council's Data Protection Officer, Allison Black at dataprotection@renfrewshire.gov.uk if you:

• want us to correct, delete or restrict your personal data
• make a complaint about how your personal data is handled.

You can also make a complaint about data protection matters to the Information Commissioner's Office.