We deal with complaints alleging breaches of the Member Code of Conduct by elected councillors and co-opted members.

Processing activity -in order to deal with your complaint, it is necessary for us to collect and hold personal information about you.  

Information requirements - our processing activities may include:

  • your name, address, telephone number(s), email address
  • nature of your complaint
  • who you are complaining about
  • remedy sought
  • equalities monitoring
  • general correspondence between you and us on matters related to your complaint

Anonymous complaints will not be considered.

Lawful bases1- our lawful bases for processing your personal information are:

  • UK GDPR Article 6(1)(c) - our legal obligation(s) under the Localism Act 2011

  • UK GDPR Article 6(1)(e) and DPA 2018, section 8(c) - necessary for the performance of a task in the public interest or in the exercise of official authority vested in the Data Controller (under the above legislation)

  • Equalities Monitoring – please refer to our Privacy Notice for the Equalities Questionnaire – Service Provision

 We have a Data Protection Policy which sets out how this information will be handled.

Data sharing - your information will be shared with the councillor you complain about, our Independent Person and where applicable, with Kent Police, our investigator, our Audit Board and courts/tribunals.

We 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 period - we keep your personal information for the minimum period necessary. The information outlined in this Privacy Notice will be kept in accordance with the retention periods referred to in our Information Asset Register (Member Code of Conduct Complaints (Monitoring Officer)). All information will be held securely and disposed of confidentially.

Anonymisation - your personal information may be converted ('anonymised') into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Aggregated data cannot, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in our reports such as showing the number of complaints we receive and/or equalities monitoring, but not in a form which identifies anyone.

Right to object - where processing your personal information is required for the performance of a public interest task (see our lawful bases above), you have the right to object on ‘grounds relating to your particular situation’. We will have to demonstrate why it is appropriate for us to continue to use your personal data.

Changes to this Privacy Notice - we review this Privacy Notice regularly and will place updates on our website.

Please refer to our Corporate Privacy Notice for further details of how we process your personal information and for details on your additional rights.


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 Member Code of Conduct Complaints Privacy Notice