Multi Agency Public Protection Arrangements: MAPPA
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 Multi-agency Public Protection Arrangements (MAPPA) which manages the risks posed to the public by sexual or violent offenders, and tells you what we will 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 020 8583 3100 or adultsocialcare@hounslow.gov.uk
The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.
Adult Social Care
London Borough of Hounslow
ounslow House,
7 Bath Road,
Hounslow,
TW3 3EB
What type of information we have
We currently collect and process the following personal information for individuals, their family network and for victims:
- Name
- Address
- DOB
- Contact details
- Financial details
- Housing status
- Criminal Offence details
- Custodial establishment details
- Probation details
- Sentencing details
- Risk management details
As well as personal information, where applicable we may collect and share additional information known as ‘Special Categories of Personal Data’ where appropriate including:
Gender
- Nationality
- Ethnicity
- Health data, including any special educational needs and any social, emotional and mental health difficulties
- Genetic data, if required
- Biometric data, if required
- Political opinions, if required
- Religious or philosophical beliefs, if required
- Sex life and sexual orientation, if required.
How do we get your information?
Most of the personal information we process is provided to us directly by you, but we may also receive personal information indirectly from:
- Your family, carer or representative, if applicable
- Health professionals such as your GP and those providing therapeutic or medical care
- Teams within Hounslow Adult Social Care and other departments, such as Children’s Social Care, Youth Offending Services and Housing
- Police
- Courts
- HM Prison Service
- Probation Service
- Other Local Authorities
We only process information from the above if it is required for us to carry out statutory functions for which we are legally responsible for.
Our Lawful basis for processing your information
The lawful basis we rely on for processing this information is:
- Legal obligation Article 6 (1)(c) – so that we comply with a common law or statutory obligation.
- Public task Article 6 (1)(e) – so that we may perform a task in the public interest or for an official function, and the task or function has a clear basis in law • Vital interests - The processing is necessary to protect someone’s life. Article 6 - 1(d)
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
• Substantial public interest – Must still be proportionate to the aim the project is pursuing, respect the spirit of the right to data protection. But also must provide for suitable and specific measures to safeguard the fundamental rights and the interests of the individuals involved. Article 9 - 2(g). The relevant Substantial Public Interest conditions within Schedule 1, Part 2 are:
a) Statutory etc., and government purposes under Para 6(1)(2)
b) Preventing and detecting unlawful acts under Para 10(1)(2)(3)
c) Safeguarding children and individuals at risk under Para 18(1)(2)(3)(4)
• Vital interests – processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent 9(2)(c)
• Social protection law - Carrying out the obligations in the field of employment and social security and social protection law - processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject - Article 9 - 2 (b).
The above lawful bases require legal justification and the Youth Justice Service relies on the following:
- The Criminal Justice Act 2003 – Section 325(3).
Why we need your information (purposes of processing)
The personal data we collect will be used for the following purpose:
Multi-Agency Public Protection Arrangements (MAPPA) are a set of statutory arrangements to assess and manage the risk posed by certain sexual and violent offenders. MAPPA were established by Sections 325 to 327 of the Criminal Justice Act 2003. MAPPA bring together the Police, Probation and Prison Services to form the MAPPA ‘Responsible Authority’ for each MAPPA Area.
Other agencies are under a ‘duty to co-operate’ with the Responsible Authority. These include Adul Social Care, Children’s Services, Health Trusts and Authorities, Youth Offending Teams, Home Office Immigration Enforcement, local housing authorities and certain registered social landlords, the Department of Work and Pensions and electronic monitoring providers.
Duty to Co-operate agencies have a statutory duty to co-operate with the Responsible Authority. Information sharing arrangements outlined in MAPPA Guidelines (March 2023) and the London MAPPA Data Sharing Agreement assist Duty to Co-operate agencies to meet that statutory duty to protect the public in a coordinated way, with access to the support of the other MAPPA agencies. The work benefits individuals who are at risk of harm or exploitation, by reducing the risk posed by sexual and violent offenders. Society benefits by a reduction in crime, and a reduction in resource necessary to mitigate crimes and support victims and witnesses.
MAPPA meetings regularly take place between the Responsible Authority and Duty to Co-operate Agencies. Category 1 Offenders (all Registered Sexual Offenders) are not discussed at MAPPA meetings.
Offenders aged under 18 are subject to the same procedures as other MAPPA offenders, but additional considerations apply. For example, the MAPPA agencies have a statutory duty to have regard to the needs of the offender as a child. Therefore the Youth Offending Team and Children’s Services must be present at a MAPPA meeting when the case of an offender aged under 18 is discussed.
We will work hard to ensure that any personal data in our care will be kept safe and that where your information is shared with other parties working on our behalf, we will seek to ensure that they have satisfactory systems and procedures in place to prevent the loss or damage of personal data.
How long we keep your information
We will keep the information for the following time period:
| Records Description | Retention Period | Trigger | Legal Basis for Retention or Justification |
| Adult Social Care |
|
From date of case closure or death of individual | Limitation Act 1980 (s2) |
| Adult Social Care All records related to the integrated health and social care for clients known to the Mental Health teams |
|
From date of case closure or death of individual | The Records Management Code of Practice for Health and Social Care 2021. |
| Children’s Social Care Varies and includes: Child in Need Plan Child Protection Plan Looked After Children |
|
From DOB From DOB From DOB |
Limitation Act 1980 Arrangements for the Placement of Children (General) Regulations 1991 Children Act 1989 |
| Youth Justice Team Offender records – depending on type of Order, Reprimand or Warning |
|
On completion of Order or issue of reprimand / final warning | Youth Justice Board Advice on Information Management in Youth Justice Teams (England) Jan 2011 |
| Youth Justice Team - Sexual offences (Schedule 1, Sex Offenders Act 1997) | Section 53 (1) or a Section 53 (2) If sentence is 30 months or more, retain indefinitely | From date of sentence | Youth Justice Board Advice on Information Management in Youth Justice Teams (England) Jan 2011 |
| Youth Justice Team - Offences on Sex Offenders Register | Subject to length of time on Register | Date of Register entry | Youth Justice Board Advice on Information Management in Youth Justice Teams (England) Jan 2011 |
We will dispose of the personal information in the most secure manner possible.
Business Intelligence, Profiling and Analysis
We may analyse the personal information you provide to improve the council’s services for the following purposes:
- Undertake statutory functions efficiently and effectively by seeking feedback on the provision of services and measuring outcomes
- Service planning by understanding resident’s needs and to provide the services that you request and for which you are eligible
- Help us to build up a picture of how we are performing at delivering services to you and what services the residents 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.
See Business Intelligence, Profiling and Analysis - Privacy notice.
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. Find more information
The National Data opt out
The national data opt out was introduced on 25 May 2018 to allow you to opt out from the use of your data for anything other than your individual care and treatment. This will prevent it being used for research or planning purposes as listed above. The opt out is in line with the recommendations of the National Data Guardian in the Review of Data Security, Consent and Opt-outs.
The national data opt out applies to the NHS and some of the activities of the council. The following link provides further information for you and details about how you can opt out if you choose to do so - See our The National Data Opt-Out webpage info.
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
E-mail: complaints.crt@hounslow.gov.uk
Data Protection Officer
The Council’s Data Protection Officer can be contacted on:
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: www.ico.org.uk
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
Our Data Protection registration number is Z5761176. You can view our registration on the Information Commissioner's website.
