Dartford Town Against Crime (D -TAC) Business Crime Retail Partnership - Privacy Notice
The Dartford Town Against Crime Business Retail Partnership is a membership organisation established to assist member businesses to respond in an organised manner to retail crime that affects their businesses, profitability, staff, customers and the local economy. By working together and sharing information about crime and those committing it, the Partnership provides greater protection for its members and the local business community.
Business crime is identified by the National Police Chiefs’ Council as ‘any criminal offence that is committed against a person or property which is associated by the connection of that person or property to a business’.
The partnership is registered with the Information Commissioner for the purpose of ‘the prevention and detection of crime and the prosecution of offenders’ under Registration Number Z7629935.
Processing activity - in order to undertake our functions, it is necessary for us to collect and hold personal information. In general terms, we process personal information relating to:
- the investigation and detection of crime
- the detection and prevention of anti-social behaviour
- the instigation of legal proceedings
- safeguarding of vulnerable people
Information requirements - our processing activities may include:
- name and address
- date of birth
- suspected/attempted criminal and/or anti-social behaviour activity/incidents
- warning markers
- CCTV images of individuals
- photographs of detained persons
- vehicle registration numbers
- details of crime incidents
- specific locations relating to activities of individuals
- Police intelligence or data relating to specific individuals, or groups of people
- Community Protection Restrictions (Section 43(5) (a) of the Anti-Social Behaviour, Crime and Policing Act 2014)
- personal data captured in minutes from meetings
- managing membership and payment details
- submission of information of interest to our members
- monitoring or recording any communication between you and us for quality control and training purposes
Lawful bases1- our lawful bases for processing your personal information are:
- UKGDPR Article 6(1)(a) - your consent (to subscribe to electronic communications from us)
- UK GDPR Article 6(1)(f) - in our legitimate interests
- UK GDPR Article 9(2)(g) - special category personal data (health and ethnicity related information) - where processing is necessary for the reasons of substantial public interest (and DPA 2018, Schedule 1, para.6(1) & (2)(a))
- UK GDPR Article 10 - criminal convictions and offences - where processing is necessary for reasons of substantial public interest (as supplemented by DPA 2018 section 10(5) & Schedule 1, Part 2, paras. 6(1) and (2)(a)) This is processed for reasons of substantial public interest where this helps to prevent and detect unlawful acts and for the purposes of establishing or defending legal rights.
We have a Data Protection Policy that sets out how this information will be handled.
We have defined a legitimate interest as working on behalf of our retail business members and the business community. We prevent and detect crime and prosecute offenders who are, or are suspected of being, involved in business crime, where that crime, anti-social behaviour or other criminal activity impacts upon our members or the business community.
When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.We have a Legitimate Interests Policy that sets out how this information will be handled.
Data sharing - to aid with the detection and prevention of criminal acts, we may collect from and share your information with:
- Dartford Borough Council
- neighbouring Business Retail Crime Partnerships
- Kent Police
- Kent Fire and Rescue Service
- Kent County Council social services
- Metropolitan Police
- British Transport Police
- National Probation Service
- Crown Prosecution Service
- Border Force
- HM Revenue and Customs
- Trading Standards
- Department of Work and Pensions
- Other non-Council Housing providers
We may also rely on a number of exemptions, which allow us to share information without needing to comply with all the rights and obligations under the Data Protection Act 2018. Please refer to the Kent and Medway Information Agreement for further details on our sharing arrangements.
Retention periods - we keep your personal information for the minimum period necessary. The information outlined in this Privacy Notice will be kept in accordance with the following retention periods:
- incidents’ data over two years old will be deleted under yearly audits;
- once only processing of offenders’ data will be deleted after a period of 18 months subject to no further incident reports;
- images of unidentified offenders will be deleted after 2 years;
- information regarding vulnerable person offenders will be dealt with in accordance with 1 to 3 above;
- information regarding offenders under 14 will not be retained unless there is a significant public interest and agreement is obtained from the Police and Dartford Town Against Crime Board;
- information regarding offenders under 18 will be retained if they are active, but deleted if no further incidents are reported for more than 12 months
Members - you have the absolute right at any time to opt-out/unsubscribe from our electronic communications by clicking the link at the bottom of our communications or by writing to us at the address given in our communications.
All information will be held securely and disposed of confidentially. We will not make your personal information available to companies for marketing purposes.
Intent to transfer personal data to a third country or international organisation - should it be necessary to transfer personal information outside the European Economic Area it will only be transferred to a third country or international organisation which the European Commission has decided has appropriate safeguards, including binding corporate rules.
Rights of individuals whose information we hold:
The right to be informed - we are required to supply you with information about the processing of your personal information through notices such as this one.
The right to access the personal information that we hold about you - you have the right to obtain from us confirmation that your personal information is being processed and access to your personal information. This is so that you are aware of and can verify the lawfulness of processing. There is generally no charge for this. We will provide your personal information without delay and generally within one month of the receipt of your request. If you wish to make a subject access request, please contact the DTAC Operations Manager, The Civic Centre, Home Gardens Dartford DA1 1DR. Email address: firstname.lastname@example.org
The right to ask for your personal information to be rectified - you have the right to have any personal information which we hold about you rectified if it is inaccurate or incomplete. We will generally deal with your request within one month.
The right to request your personal information is deleted (sometimes called the ‘right to be forgotten’)
- there are some specific circumstances where the right to erasure does not apply and we can refuse to deal with a request for example, where we are required to comply with a legal obligation or where we are prosecuting or defending legal claims
You have the right to have personal information erased and to prevent processing in specific circumstances:
- where the personal information is no longer necessary in relation to the purpose for which it was originally collected/processed
- when you withdraw consent
- when you object to the processing and there is no overriding legitimate interest for continuing the processing
- the personal information was unlawfully processed (ie: otherwise in breach of the UK GDPR)
The right to restrict processing of your personal information - you have the right to restrict processing of your personal information in certain circumstances. Where processing is restricted, we are permitted to store your personal information but we may not process it further. We can retain just enough information about you to ensure that the restriction is respected in future. The right to restrict arises in the following cases:
- where you contest the accuracy of your personal information, we may restrict the processing until we have verified the accuracy of the personal information
- when processing is unlawful and you have opposed erasure and requested restriction instead
- if we no longer need your personal information but you require the personal information to establish, exercise or defend a legal claim
The right to object - you have the absolute right to object to the processing of your personal data if it is for direct marketing purposes. You also have the right to object (not an absolute right) if the processing is in our legitimate interests (or those of a third party).
You can also object to our processing where we are relying on the ‘legitimate interests’ lawful basis. The burden is on us to prove that we have compelling grounds to continue processing the data.
The right to lodge a complaint - if you wish to complain about how we are processing your personal information, please contact the DTAC Operations Manager, Civic Centre, Home Gardens Dartford DA1 1DR. Email address: email@example.com
You also have the right to complain to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF: Telephone: 0303 123 1113 or 01625 545745: Website: www.ico.org.uk. Further information about your personal data rights can be found at https://ico.org.uk/your-data-matters/
Changes to this Privacy Notice - we review this Privacy Notice regularly and will place updates on our website.
1 Note that we may process your personal information on more than one lawful basis depending on the specific purpose for which we are using your information
GDPR Privacy Notice D-TAC 2020