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Triage Project Privacy Notice

Information about your Personal Data

As part of the Triage Project, GMP will be working alongside various health care professionals to offer support and guidance to members of the public. This will be done in real time, as and when Officers encounter individuals during day to day policing who may benefit from support by these professionals.

The way we use your personal information in the Triage Project is important to us. This notice contains everything you need to know about how personal data is processed.

What we need:

There are several partners who will be sharing information as part of this project. Each partner will be what’s known as the ‘Controller’ of the personal data that they process. The Controllers are:

  • Greater Manchester Police (GMP)
  • North West Boroughs Healthcare NHS Foundation Trust (NWB)
  • Pennine Care NHS Foundation Trust (PC)
  • Mental Health NHS Foundation Trust (MH)

Relevant controllers will collect personal data from a range of sources in the course of the exercise of their statutory functions. For GMP, information will be collected for a Law Enforcement Purpose, and for the NHS Foundation Trusts, for reasons concerning your health and wellbeing.

We only collect and share relevant personal data about you in order for fulfil our purpose. This will include personal data and special types of 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

Each Controller will only use the minimum amount of personnel information necessary to carry out a particular activity.

Why we need it:

We need to know your personal data in order to provide you with the support you require. GMP Officers and Staff will gather enough information about you to fulfil the purpose as outlined in Part 3 of the Data Protection Act 2018 (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). However, it is recognised that in the course of conducting policing work, GMP will encounter individuals who may require a different type of support, which the Police Service is not in a position to provide. GMP has previously worked closely with the NHS and various other Health Care professionals to provide a greater level of service to the residents of Greater Manchester. This project sees that relationship with partner organisations develop further, with an aim to provide a more effective integrated service to improve the health and social care outcomes of individuals.

The project works by various Healthcare Professionals from each of the three Foundation Trusts working alongside with GMP staff in the Clayton Brook Control Room. This is where various incidents from across the Force are managed. Police Officers have a direct line into the Control Room, and are able to liaise with the Health Care Professionals to provide an elevated level of service to the member of public.

The legal basis for each Controller to process personal data can be found in their respective Overarching Privacy Notices. You can access GMP’s here.

The specific lawful basis for this project is as follows

GMP – NHS Foundation Trusts

The following GDPR conditions are met, for when data is shared for a purpose other than a direct policing purpose (i.e. on transfer of data from GMP to the relevant partner agency):

  • Article 6(e) Performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • Article 9(g) processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject

It is recognised that on occasion, a different lawful basis may be used. For example, if there is a life or death situation such as a suicide attempt, information may be shared using the vital interest basis (Article 6d/ 9c).

NHS Foundation Trust - GMP

  • Article 6(1)(e) ‘Public task in exercising official authority’
  • Special category data condition Article 9(2)9h) ‘Health and social care’ for health management purposes on the assumption that sharing with GMP is to individual(s) with an obligation of a duty of confidence.

NHS Foundation Trust – Other NHS Foundation Trusts and wider partners

  • Article 6(1)(e) ‘Public task in exercising official authority’
  • Special category data condition Article 9(2)9h) ‘Health and social care’.

What you need to supply and what will happen if you don’t?

In order for GMP and the NHS Foundation Trusts to assist you, you will need to provide any information that is relevant depending on the circumstances. Without a full picture of background and circumstances, each Controller would not be able to offer you the best support. If you are not comfortable providing certain types of information, please make the relevant Officer/ Practitioner know, and they can guide you appropriately.

On occasion NHS Foundation Trust may ask for your explicit consent in order to lawfully process your data. This will only happen in specific and limited circumstances. 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.

What we do with it:

Only relevant information will be shared with the appropriate partner.

Appropriate advice will be given by the Healthcare Professionals to GMP staff to allow them to provide a better service to the public. This advice will be in relation to all aspects of health.

Where the Healthcare Professional becomes involved with any data subject, they will create an action plan where required. This will allow for support to be provided to individuals who have mental health concerns. This new way of sharing will ensure that more people with mental health care needs who may have previously been detained under S136 or taken to A&E will instead be referred onto an appropriate agency.

A summary of GM CRT referral and subsequent contact may be shared with the patients GP and any other NHS service involved in their care at the time of the referral to GM CRT. A referral to a number of potential different partners may be made (for example drug related referrals, woman’s centre, primary care IAPT, social care and safeguarding referrals). These referrals will follow existing protocol or sharing agreements that are already in place. Although consent will be sought, an alternative lawful basis will be used in circumstances where referral is deemed necessary to protect or safeguard individuals. This lawful basis is documented in the above section.

All the personal data we process is processed by our staff in the UK however for the

purposes of IT hosting and maintenance this information is located on servers within the European Union. No third parties have access to your personal data unless the law allows them to do so.

Each Controller has a Data Protection regime in place to oversee the effective and secure processing of your personal data. More information on this framework can be found on each Controller’s website.

How long we keep it:

Information held on GMP’s systems 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).

Will this information be used to take automated decisions about you?

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.

What are your rights?

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 GMP:

The Information Compliance and Records Management Unit at: subjectaccess@gmp.police.uk, 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

Making a complaint about your personal data

You can complain directly to the Greater Manchester Police's Data Protection Officer via email or in writing to: -

Email: dataprotection@gmp.police.uk

Data Protection Officer
Information Compliance and Records Management Unit
Greater Manchester Police
Openshaw Complex
Lawton Street
M11 2NS

You also have the right to complain to the Information Commissioner’s Office using the following details:

The Information Commissioner's Office
Wycliffe House
Water Lane
Cheshire SK9 5AF

Telephone: 08456 30 60 60 or 01625 54 57 45

Website: www.ico.org.uk



© Greater Manchester Police 2019