Customer Service team privacy notice

First published

24 Jul 2024

Last updated

24 Jul 2024

Customer Service team privacy notice

Find out how Stirling Council uses personal data by checking the Council’s website at the following address:

https://www.stirling.gov.uk/privacy-statement/

Our website contains a Register of Data Processing which lists all the different ways
in which the Council uses personal data.

This Privacy Notice provides more information about just one of those processes.

Who do I contact about my personal data?

The Council has a Data Protection Officer to make sure it is complying with data protection laws.

They can be contacted at:

Data Protection Officer
Stirling Council
Old Viewforth
14-20 Pitt Terrace
Stirling
FK8 2ET

Email: dataprotection@stirling.gov.uk
Telephone: 01786 404040

Why does the Council process personal data?

The Customer Service Team are the first point of contact for all council services, and the point at which basic personal data is collected.

All data is processed in line with all regulated services.

This information is recorded and processed in order to: 

  • signpost customers. This is where personal data is stored where no service has been provided but will allow call-backs where appropriate
  • provide immediate services to customers (e.g. telecare services)
  • call recordings will be used by Stirling Council to identify staff training issues and verifying information conveyed in calls to and from the customer service team
  • allow for booking requests (bookable spaces such as rooms, halls and football pitches etc.) to be confirmed and confirmation emails sent. Also to allow the processing of invoices for bookable spaces

The type of personal information we collect

The data collected includes information about current or potential service users, their carer’s and any appropriate third party organisations.

Calls made to the customer service team are recorded for monitoring and quality assurance purposes. 

Personal data processed 

  • name 
  • address
  • email address
  • contact number
  • date of birth
  • name and address of GP
  • information about the reason for the call

Special category data processed 

  • health (physical or mental)
  • racial or ethnic origin

What makes it lawful for the Council to process this personal data?

The Council is permitted to process your personal data in this way because it is in the public interest that training requirements in frontline staff are identified and that information conveyed in calls to and from the Council, about a wide range of matters, can be verified. 

Formally, the processing of personal data provided to us for this purpose satisfies GDPR Article 6(1)(e) - processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Sometimes sensitive information (known as special category data) is recorded during calls to or from the Customer Service Centre. If special category data is being processed, the Council has to provide a reason for doing so; in the case of information recorded during telephone calls we consider that the power to advance well-being (provided in the Local Government in Scotland Act 2003) permits us to process this information under the terms of GDPR Article 9(2)(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.

Where does the Council obtain personal data from?

Data is collected by Council employees in the course of an interview or telephone conversation or in written correspondence with the data subject or agent. 

The personal data is stored in a variety of electronic systems and this information may be accessed by other areas such as Intake or Locality Teams, Housing, waste etc. in order to deliver services and capture additional information as required.

Where does the Council keep personal data?

All data is stored electronically in a variety of electronic systems.

Details of calls to the customer service team are stored on a secure call recording system.  Calls which include card details are suppressed to ensure no card details are recorded in line payment card industry standards.

How long does the Council keep personal data?

Adult social care’s retention rules are either 5 years from last action or 3 years from the death of the adult. 

Recordings of phone calls to Stirling Council’s customer service team are retained for 3 months.  After this they are deleted unless they are required to be retained as part of an ongoing complaint or investigation.

Who does the Council share personal data with?

Data can be shared with external providers who provide service users with a service or for the detection and prevention of crime.

Our booking system is administered through the Artifax system.

Your personal details may be shared with the Scottish Government and the National Health Service for statistical and research purposes. 

  • This information will help the Scottish Government, your local authority and your Health Board plan future care services. This will help improve services for you and others.
  • Every effort will be made to ensure that your information is kept safe at all times.
  • All pieces of information which could identify you, such as names and dates of birth will be removed.

Your rights

You have the following rights under data protection laws. If you have a request under any of these rights, you can make a subject access request.

  • The right of access You have the right to request information we hold about you. This is known as a subject access request and is free of charge. We must respond within one month, although this can be extended to three months if the information is complex.

  • The right to rectification - You are entitled to have your information rectified if it is factually inaccurate or incomplete. We must respond to your request within one month. If we decide to take no action, we will tell you why and let you know about your right of complaint to the UK Information Commissioner

  • The right to erasure - You have the right to ask us to delete your information or stop using it. It will not always be possible for us to comply with your request, for example, if we have a legal obligation to keep the information. If we decide to take no action, we will tell you why and let you know about your right of complaint to the UK Information Commissioner.

  • The right to restrict processing - You have the right to restrict how your data is processed in certain circumstances, for example, if the information is not accurate. If a restriction is applied, we can retain just enough information to ensure that the restriction is respected in future. We must tell you if we decide to lift a restriction on processing.

  • The right to data portability – You have the right to object to processing, if we are processing your personal data with your consent, and it is held in a structured, commonly used, machine-readable form, you have a right to ask us to transmit it to another data controller so they can use it. This right does not apply if we process your personal data as part of our public task.

  • The right to object - You can object to your information being used for profiling, direct marketing or research purposes.

  • You have rights in relation to automated decision making and profiling - to reduce the risk that a potentially damaging decision is taken without human intervention.

Complaints and comments

If you want to complain about or comment on how we have processed your personal information, you should email dataprotection@stirling.gov.uk

If you are still unhappy with how the council handled your complaint, you can contact the UK Information Commissioner's Office at:

The Information Commissioner,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire SK9 5AF

Phone: 0303 123 1113

You can find further information on the Information Commissioners Office website.

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