Your privacy is important to us. This Privacy Notice explains how Greater Manchester Police (GMP) processes personal data. It also outlines the steps we take to ensure that personal data is protected and describes the rights individuals have in relation to the data we process.
Personal data is any data that can be used to identify a living individual, on its own or in combination with other available information. References to names, identification numbers and location data would all be personal data. Processing means anything we do with the data and includes collecting, storing, and sharing.
The Chief Constable of Greater Manchester Police is the controller for any personal data processed by GMP.
2. Data Protection Officer
The contact details for our Data Protection Officer are given at the end of this notice.
Information Compliance and Records Management Unit manages GMP’s data protection compliance and can be contacted by telephone on 0161 856 2529, or via email firstname.lastname@example.org.
3. What information do we collect about you?
GMP collects personal data from a range of sources in the course of the exercise of its statutory Law Enforcement functions. We also process personal data that is collated in the course of our administrative functions, for example staff administration, procurement, property management, advertising and media.
The personal data we collect and use will include personal data and special category personal data.
Types of personal data we process may include information such as;
- personal details such as name, address and emails
- sound and visual images, including Body Worn Video and Facial Recognition
- financial details
- intelligence material
- complaint, incident and accident details
- employment details
Special category personal data may include:
- racial or ethnic origin
- political opinions
- religious beliefs, or those of a similar nature
- trade union membership
- physical or mental health
- sexual health or orientation
- genetic or biometric data
GMP will only use the minimum amount of personnel information necessary to carry out a particular activity.
4. Whose personal data do we handle?
In order to carry out our functions, we process information relating to a wide variety of individuals including:
- people convicted of an offence
- people suspected of committing an offence
- complainants, correspondents and enquirers
- consultants and other professional experts
We also process data relating to existing and former members of staff.
Information is likely to be held in various forms, including electronically in emails and in GMP's electronic filing system and databases as well as in paper-based records. It may also be held in other electronic forms such as CCTV.
5. Why do we use personal data?
GMP processes personal data for law enforcement purposes as outlined in Part 3 of The Data Protection Act 2018 which are the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security. We also process data for the purposes of safeguarding National Security, including National Security Vetting for Met staff.
The legal basis for processing law enforcement data is that it is necessary for the performance of functions. GMP's functions are established in the main under the Police and Criminal Evidence Act 1984 and the Police Act 1996, The Police Reform Act 2002 and include any powers or duties conferred by an enactment, and include:
- protecting life and property
- preserving order
- prevention and the detection of crime
- bringing offenders to justice
- any duty or responsibility arising from common or statute law
We will only use personal information when the law allows us to and where it is necessary and proportionate to do so.
We may also process data for non-law enforcement purposes such as when we recruit and vet potential employees, for staff administration, managing media relations and when we provide educational programmes and support. Where we process data for non-law enforcement purposes, the processing is likely to be based on the following grounds:
- it is necessary for performing the contract
- to comply with a legal obligation
- it is in the public interest to do so; or for official purposes
- we have a legitimate interest to do so, and it is necessary and balanced against your own interests, rights and freedoms
- there may be rare occasions where it becomes necessary to use your personal information to protect your vital interests (or someone else's vital interests).
Where we process special categories of personal data, we will do so in accordance with the specific conditions of processing set out in the Data Protection Act 2018. It is likely that we will use special category data in the following circumstances:
- where we have your explicit consent
- where we are required to do so under Employment Laws
- where it concerns a medical diagnosis, or the medical assessment of your working capacity
- where it is for the purposes of the exercise of GMP's functions and it is in the substantial public interest
6. Asking for your consent to process personal data
Occasionally GMP may ask for your explicit consent in order to lawfully process your data. This will only happen in specific and limited circumstances and won’t usually be relevant to law enforcement data. When we do require consent, we will explain clearly what we are asking for and how we will use it. Consent must be freely given, specific and informed and there must be a genuine choice about offering your data. Where we are processing data based on your consent, you have the right to withdraw that consent at any time.
When we ask for your consent, we will specify why we want your data, and what we are going to do with it, how long we will keep it for and the steps we will take to delete it. We will also explain how you can withdraw consent.
7. How long do we keep personal data?
GMP keeps personal data for as long as is necessary for the particular purpose or purposes for which it is held. Personal data which is placed on the Police National Computer is retained, reviewed and deleted in accordance with the agreed national retention periods which are subject to periodic change.
Other records containing personal data relating to intelligence, digital media, custody, crime, firearms, child abuse investigations, domestic violence and other non-policing activities (such as Human Resources information) will be retained in accordance with the NPCC endorsed guidance on the Management of Police Information (MoPI) 2006, (this can be found on the College of Policing’s website www.app.college.police.uk) and the National Retention and Disposal Schedule, (this can be found on the National Police Chief’s Council website www.npcc.police.uk).
8. Who will we share data with?
The sharing of data is a primary business function. For example, it may be necessary to share data with other law enforcement agencies, both nationally and internationally, and with partner agencies working on crime reduction and prevention initiatives. We may also share data with a range of other bodies such as the press and media, service providers, current, past and prospective employers, voluntary sector organisations, financial institutions and regulatory bodies.
GMP takes steps to ensure that any disclosures of personal data, however obtained, comply with the provisions of the Data Protection Act 2018 and General Data Protection Regulations. This includes ensuring that any disclosures are necessary and proportionate. Disclosures will be made on a case-by-case basis, using the personal data appropriate to a specific purpose, and with necessary safeguards in place.
Some of the bodies or individuals to which we may disclose personal information are situated outside of the European Union (EU). If we do transfer personal data to outside of the EU, we undertake to ensure that there are appropriate safeguards in place to certify that it is adequately protected as required by the legislation.
We will also disclose personal information to other bodies or individuals when required to do so by, or under, any act of legislation, by any rule of law, and by court order.
9. How do we keep your data secure?
Your personal data will be processed securely. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions. The security, confidentiality and integrity of your data is important to us.
10. Is my data subject to automated decision making or profiling?
No, you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
11. Your rights as a data subject
Under the Data Protection Act 2018 you have a number of rights that you can exercise in relation to the data we process about you. Under certain circumstances, by law you have the right to:
- request access to your personal information (commonly known as a right of access request). This enables you to receive a copy of the personal information we hold about you and check that we are lawfully processing it and that it is accurate
- request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
- request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no lawful reason for us to continue to process it
- request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we are allowed under the law to charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we can refuse to comply with the request in such circumstances.
We sometimes need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Further information about these rights can be found within the Data Protection Act 2018 and on the Information Commissioner’s Office website: www.ico.org.uk
To exercise any of these rights please contact the Information Compliance and Records Management Unit at: email@example.com, telephone: 0161 856 2529, or via post:
Information Compliance and Records Management Unit, Greater Manchester Police, Information Services Branch, Openshaw Complex, Lawton Street, Manchester, M11 2NS
12. Complaints and further queries
GMP tries to meet the highest standards when processing personal data. We take complaints very seriously. If you have any concerns about the way that we have handled your personal data please bring it to the attention of our Data Protection Officer via the following means:
Telephone: 0161 856 2529;
Or via post: The Data Protection Officer, Information Compliance and Records Management Unit, Greater Manchester Police, Information Services Branch, Openshaw Complex, Lawton Street, Manchester, M11 2NS
You are also able to submit complaints to the Information Commissioner’s Office;
The Information Commissioner's Office
Telephone: 08456 30 60 60 or 01625 54 57 45