What personal information is being processed and what for
Hertfordshire County Council has statutory duties under section 36 to 41 of the Counter-Terrorism and Security Act 2015 to provide support for people vulnerable to being drawn into any form of terrorism.
Channel is a programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. The programme uses a multi-agency approach to protect vulnerable people by:
- identifying individuals at risk
- assessing the nature and extent of that risk
- developing the most appropriate support plan for the individuals concerned.
Information we collect
While delivering our responsibilities under the Channel programme, we collect the following relevant personal information about you, either when you provide it to us or from another member of the Hertfordshire Channel Panel:
- name
- address
- date of birth
- contact details
- relevant family member and associate details
- gender
- first language
- criminal records and conviction data.
We also collect the following special category personal data:
- relevant medical information (if applicable)
- religious beliefs (if applicable)
- relevant Social Care information
- ethnicity.
We recognise that personal information concerning criminal convictions and offences is not special category personal data but is a very sensitive type of personal information which can only be shared in narrow circumstances.
How we use your personal information
We use your personal information to provide tailored support at an early stage to you, with the aim of preventing you from being drawn into terrorism.
Why we are allowed to use your information
Hertfordshire County Council collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the UK General Data Protection Regulation (GDPR) and we, together with the Home Office, are responsible as ‘joint data controllers’ of that personal information for the purposes of those laws.
The lawful basis on which we collect and use your personal data is that ‘processing is necessary for the completion of task carried out in the public interest.’ GDPR Article 6(1)(e) applies.
As we may collect and use your special categories of personal data (medical information and religious beliefs) and also details about criminal records and convictions, if relevant, the lawful basis on which we collect and use your personal data is that ‘processing is necessary for reasons of substantial public interest’ namely for preventing and detecting unlawful acts. GDPR Article 9(2)(g) and Schedule 1, Part 2, paragraph 10 of the Data Protection Act 2018 apply.
Who we share your personal information with
As part of the Channel process, personal information is shared securely and only where strictly necessary. Relevant information will be sought from other agencies as appropriate to inform our assessment. Where there is a need, this will be discussed at a multi-agency panel to consider whether intervention support should be offered.
The information will only be shared with relevant agencies. This may include: police, health agencies, Home Office, immigration, probation, school, college, or other relevant agencies.
We will share personal information with law enforcement or other authorities if required to do so by applicable law.
Where we get your information from
Hertfordshire Channel Panel receives information from the police, health services, housing, probation, education and other relevant agencies. The purpose for collating this information is to provide you with a bespoke package to prevent you from being drawn into terrorism.
How long we will keep your personal information
We will hold your personal information for 25 years – in line with safeguarding retention periods. After this period the information will be reviewed and only retained where there is an ongoing requirement to retain for a statutory or legal purpose. Following this your personal information will be securely destroyed.
How your information is stored
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. Access to information systems is controlled by a minimum of two-factor authentication, e.g. username and password.
We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
What happens if you don’t provide us with your information
Data is collected by Hertfordshire Channel Panel for the purpose of preventing Children and Adults from being drawn into terrorism or radicalisation.
The Channel Programme is a voluntary service for individuals who may be vulnerable to terrorism, and offers a bespoke multi agency response, tailored to individual circumstances. To receive such support, you, or your parent, carer or guardian, will need to give informed consent. If consent is not given, services will not be provided to you.
Will your information be used to make automated decisions?
No
Your rights
You have a number of rights regarding your personal data, including withdrawing your consent where we have asked for it. You can also ask for a copy of the information we hold about you and ask us to correct anything that is wrong.
You also have the right to secure access to your personal data, erase what we hold or restrict or object to what we do with it.
We will always seek to comply with your request, however, we may be required to hold or use your information to comply with legal duties. We will liaise with the Home Office regarding your request, as information is jointly controlled with the Home Office. Please note, your request may delay or prevent us from supporting you.
Whether we are able to grant your rights request depends on the circumstances but in the first instance you should contact data.protection@hertfordshire.gov.uk.
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office on individuals’ rights under GDPR.
The Council’s Data Protection Officer can be contacted at DataProtection.Officer@hertfordshire.gov.uk.
If you are concerned about the way the council processes your personal data, please contact us at data.protection@hertfordshire.gov.uk. We will look into your concerns.
If, after that, you are still concerned you may contact the Information Commissioner’s Office.
For further information about Home Office handling of Channel information, see the Channel data privacy information notice.
For further information about Prevent and Channel, see FACTSHEET: Prevent and Channel - 2021.