Privacy notice

Licensing

The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.

This privacy notice applies to services provided by Licensing Authority of the London Borough of Hounslow and tells you what to expect us to do with your personal information.

If you have any questions about this privacy notice or any concerns about how we process your data, please contact the Licensing Team on 0208 583 4711 or email licensing@hounslow.gov.uk. The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.

What type of information we have 

Most of the personal information we process is provided to us directly by you when you apply for a licence.

We currently collect and process the following information:

  • Photo
  • Name (including preferred pronouns)
  • Previous names
  • Maiden names
  • Address
  • Date of Birth
  • Place of birth
  • Contact Numbers
  • Email address
  • National Insurance number
  • DBS checks
  • Proof of your right to work including relevant documents (e.g passport/driving license/utility bill etc.)
  • Bank statements will be required to be able to process refunds
  • Copies of all relevant qualification/certifications
  • Public indemnity insurance
  • Any relevant risk assessments required (including covid-19 risks)

We may collect:

  • Information about your ethnicity
  • Relative information about a recent offense committed by you

We may also request or receive personal information indirectly, from the following organisations:

  • Valuation Office Agency (VOA)
  • Companies House
  • Home Office
  • Neighbouring Authorities
  • Police

The information we collect is only used for the above intended purpose.  If we intend to use it for any other purpose, we will ask you first.  In some cases, the Council may use your information for another purpose if it has a legal duty to do so, to provide a complete service to you, to prevent and detect fraud, or if there is a risk of serious harm or threat to life.

How do we get your information?

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • you may give us your personal data by filling in forms or by corresponding with us by post, phone, email.
  • You may provide personal data when you sign up to enquire about council provided service, request information, complete a survey, give us feedback or make a compliant.
  • Most of the personal information we process is provided to us directly by you through Licensing application forms, for example, when you apply for a premises licence, Or you have contacted the council to report an issue that the Licensing Team will investigate such as a complaint about a licensed premises business.
  • We also collect information available through public sources such as HM Land Registry and Companies House.
  • Emails received directly from yourselves into our Licensing Inbox or through our Customer Service teams.

If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information.

 

Our lawful basis for processing your information

The Licensing Team must process all personal data lawfully, fairly and in a transparent manner.

The lawful basis we rely on for processing this information is

  • Legal Obligation

Please view Appendix 1 to see the laws we rely on.

Lawful basis under Article 9 GDPR (Special Category Data)

If the information you provide us contains special category data, such as health, religious or ethnic information the legal basis we rely on to process is

  • Employment, social security and social protection (if authorised by law)

Lawful basis under schedule 1 of the Data Protection 2018 (Criminal Offence Data)

we will process criminal offence data [if applicable] for the purposes mentioned below:

  • Employment, social security and social protection
  • Preventing or detecting unlawful acts
  • Regulatory requirements relating to unlawful acts and dishonesty.

You can remove your consent at any time by contacting licensing@hounslow.gov.uk

Why we need your information (purposes of processing)

The Licensing Authority of the London Borough of Hounslow is the data controller and is under a legal obligation to administer, ensure compliance and enforce numerous pieces of legislation issued by Central Government. In order to fulfil this obligation, and carrying out its statutory functions, it is necessary to request and process an applicant’s personal, and in certain cases sensitive special category personal and criminal offence data, when they apply for a licence permission.

The personal data we collect will be used for the following purposes:

  • Process licence applications in accordance with the relevant legislation
  • Investigate enquiries and complaints
  • Take necessary enforcement action where necessary.

 

Who your information may be shared with (internally and externally)

We share your information with:

  • The Police
  • London Borough of Hounslow Departments
  • Statutory Consultees
  • Revenue and Benefits
  • Her Majesty’s Revenue and Customs (HMRC)
  • The Home Office
  • Neighbouring Local Government Authorities
  • Those requesting information in accordance with a legislative power
  • Disclosure and Barring Service
  • Environment Agency  
  • Safety Advisory Group (SAG)
  • Gambling Commission
  • Public, via a public register where the Authority is legally required to maintain one
  • National Anti-Fraud Network (NAFN)
  • Any future authorised company/body replacing any of the above service providers
  • Licensing Committee members
  • Any other agency, body, person where it is considered necessary in order to uphold the legal duty the Licensing Authority is placed under.

There will be times when we are under a legal duty to share information. This includes, but is not limited to:

  • disclosure under a court order
  • sharing with the Ministry of Justice for inspection purposes
  • sharing with the police for the prevention or detection of crime
  • where there is an overriding public interest to prevent abuse or serious harm to others
  • disclosure to a Regulator if we identify a situation of potential misconduct or if the information is requested.

We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.

How long we keep your information

See our retention schedule.  This provides details on how long our retention period is for each piece of legislation we collect data under.

We will then dispose of your information in the most secure manner possible.

We keep:

  • Premises Licence
  • Club Premises Certificate
  • Personal Licence
  • Temporary Event Notice
  • Lotteries
  • Betting, gaming and machine permits
  • Collector licence
  • Site licence
  • Storage and sale of explosives
  • Personal Registers of necessary information as required under legislation

For time limit - In perpetuity (without limit) due to public register rules contained in the legislation.

And the following applications 3 years beyond the expiry or surrender of a licence. 7 years beyond the revocation, refusal or withdrawal of a permission, or a case involving legal action:

  • Street Trading Consent
  • Sexual Entertainment Venue
  • Sex Cinema
  • Sex Shop
  • Distribution of Free Literature (DoFL)

 

We will then dispose your information in the most secure manner possible.

Transfers to third countries

We do not transfer your information to any third countries.

Your data is stored in the UK, and in some circumstances Ireland.

All the information you provide us is held within the UK & European Economic Area.

 

Business Intelligence, Profiling and Analysis

We may analyse your personal information to improve the council’s services for the following purposes:

  • undertake statutory functions efficiently and effectively
  • service planning by understanding your needs and your community's needs and to provide the services that you or your community request
  • understanding what we can do for you and your community and inform you of other relevant services and benefits
  • help us to build up a picture of how we are performing at delivering services to you and what services the people of Hounslow need
  • analysis of costs and spend of services we provide so that we can ensure better and efficient use of public funds

The council is committed to using pseudonymised or anonymised information where practical, and in many cases this will be the default position.

Pseudonymisation is a procedure by which the most identifying fields within a data record are replaced by one or more artificial identifiers, or pseudonyms. There can be a single pseudonym for a collection of replaced fields or a pseudonym per replaced field. An example of this is your National Insurance number or Council Tax Reference number.

Anonymisation is the process of removing identifying particulars or details. This means that the data cannot be linked back to identify you.

 

Data matching and auditing

We are required by law to protect the public funds we administer. We may use the information you provide to us for the prevention and detection of crime. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Department for Work and Pensions, other local authorities, HM Revenue and Customers and the Police.

The council uses data matching as a way of processing large volumes of information. While this can be a useful way of detecting fraud, it also enables us to identify information that is inaccurate or out of date, helping us comply with Data Protection law, while improving service provision.

As part of the council’s fraud prevention and detection activities, the council participates in the National Fraud Initiative (NFI). The data matching exercise is run by the Cabinet Office. You can find more information about this at the link below: 

https://www.hounslow.gov.uk/info/20110/open_data_and_information_requests/1365/data_protection/5 

 

Your data protection rights

The rights available to you depend on our reason for processing your information. For further information about your data protection rights and how to make a request, please see ‘Your rights’

 

Your right to make a complaint

The Council 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.

If you want to make a complaint you can contact us on:

Complaints Team
London Borough of Hounslow
Hounslow House
7 Bath Road
TW3 3EB

 

Data Protection Officer

The Council’s Data Protection Officer can be contacted on:

Email: InformationGovernance@hounslow.gov.uk

Information Governance Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB

 

Information Commissioner’s Office

The Information Commissioner is the UK's independent body set up to uphold information rights.

If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website.

If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:

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

Telephone: 0303 123 1113 or 01625 545 745

Email:  casework@ico.org.uk

A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176.  You can view our registration on the Information Commissioner's website.

APPENDIX 1

  • Licensing Act 2003
    • Premises Licence
    • Club Premises Certificate
    • Personal Licence
    • Temporary Event Notice
  • London Local Authorities Act 1990
    • Street Trading Consent
  • London Local Authorities Act 1991
    • Special Treatment Licences
  • Local Government (Misc. Provisions) Act 1982
    • Sexual Entertainment
    • Sex Cinema
    • Sex Shop   
  • Gambling Act 2005
    • Premises Licences
    • Lotteries
    • Betting, Gaming and machine permits
  • Scrap Metal Dealers Act 2003
    • Collectors Licence
    • Site Licence
  • Explosives Regulations 2014
    • Storage and sale of explosives/fireworks
  • Environment Protection Act 1990
    • Distribution of Free Literature (DoFL)
  • Business & Planning Act 2020
    • Pavement licence

Modification of premises licenses to authorise off-sales for limited periods.

 

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