How we use your information
This privacy notice tells you what to expect when the Information Commissioner’s Office (ICO) collects personal information. It applies to information we collect about:
- visitors to our websites;
- complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry;
- people who use our services, eg who subscribe to our newsletter or request a publication from us;
- people who notify under the Data Protection Act;
- people who register their household CCTV camera; and
- job applicants and our current and former employees.
When someone visits www.ico.org.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Our website search and decision notice search is powered by System Associates. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either ICO or any third party.
We use a third party provider, Adestra, to deliver our monthly e-newsletter. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Adestra’s privacy notice.
Online reporting tool
We collect information volunteered by members of the public about nuisance calls and texts using an online reporting tool hosted by Snap Surveys. This company is a data processor for the ICO and only processes personal information in line with our instructions.
Security and performance
The ICO uses a third party service to help maintain the security and performance of the ICO website. To deliver this service it processes the IP addresses of visitors to the ICO website.
We use a third party service, WordPress.com, to publish our blog, and some of our conference microsites. These sites are hosted at WordPress.com, which is run by Automattic Inc. We use a standard WordPress service to collect anonymous information about users' activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address. For more information about how WordPress processes data, please see Automattic's privacy notice.
People who contact us via social media
We use a third party provider, Hootsuite to manage our social media interactions.
If you send us a private or direct message via social media the message will be stored by Hootsuite for three months. It will not be shared with any other organisations.
People who call our helpline
When you call the ICO's helpline we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness.
Our helpline also offers a translation service for customers when English is not their first language, this is provided by a third party company. The company that provides this service does not retain any information from the calls or record them.
People who email us
The ICO is part of the GSI network. Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
People who use our LiveChat service
We use a third party provider, Goss Interactive, to supply and support our LiveChat service, which we use to handle customer enquiries in real time.
If you use the LiveChat service we will collect your name, email address (optional) and the contents of your LiveChat session. This information will be retained for two years and will not be shared with any other organisations.
You can request a transcript of your LiveChat session if you provide your email address at the start of your session or when prompted at the end.
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not, identify any complainants unless the details have already been made public.
The ICO offers various services to the public. We use a third party to deal with some publication requests, but they are only allowed to use the information to send out the publications.
We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested a publication to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.
Many businesses are required by law to ‘notify’ certain specified information to the Information Commissioner. This may contain personal information, for example where the business is a sole trader. The ICO compiles this information into a register which it is required by law to make publicly available. The ICO cannot therefore give any guarantees as to how the information contained on the register will be used by those accessing it.
When businesses fill in their registration forms, they are asked to provide the contact details of a relevant member of staff. ICO will use this for its own purposes, for example where we have a query about a registration, but will not put it on the public register.
When we request information as part of the registration process, we make it clear where the provision of information is required by law and where it is voluntary.
This type of registration will contain personal data; the operator of the domestic CCTV system must be a named individual and the registration requires the address of where the camera(s) is/are located. The ICO compiles this information into a register which it is required by law to make publicly available – although for this type of registration there is the option to provide an email or PO Box address instead of a full postal address for publication only. As the register is publicly available, the ICO cannot give any guarantees as to how the information contained on the register will be used by those accessing it.
When we request this information we make it clear what information we will and will not be publishing on the register.
Service providers reporting a breach
Public electronic communications service providers are required by law to report any security breaches involving personal data to the ICO.
We provide an online form for this purpose, hosted by Egress. We use the data collected by the form to record the breach, to make decisions about the action we may take, and as relevant in order to carry out those actions. We retain personal information only for as long as necessary to carry out these functions, and in line with our retention schedule. This means that logs and breach reports will be retained for two years from receipt, and longer where this information leads to regulatory action being taken. We retain de-personalised information about organisations for as long as is necessary to help inform future actions, but no individuals are identifiable from that data.
The ICO and Egress have measures in place to ensure the security of data collected and transferred to the ICO via this form. Egress is a data processor for the ICO and only processes personal information in line with our instructions.
When individuals apply to work at ICO, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
Once a person has taken up employment with the ICO, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with ICO has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.
Complaints or queries
ICO tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of ICO’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
Access to personal information
ICO tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form.
To make a request to the ICO for any personal information we may hold you need to put the request in writing addressing it to our Information Governance department, or writing to the address provided below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the Information Governance department.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Further information is available in our Information Charter about the factors we shall consider when deciding whether information should be disclosed.
You can also get further information on:
- agreements we have with other organisations for sharing information;
- circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics;
- our instructions to staff on how to collect, use and delete personal data; and
- how we check that the information we hold is accurate and up to date.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 31 March 2016.
How to contact us
Information Governance department
Information Commissioner's Office