Introduction and scope
We, as part of our statutory, corporate and public task functions, process special category data and criminal convictions data in accordance with the requirements of:
- Article 9 and 10 of the UK General Data Protection Regulation (‘UK GDPR’) and
- Schedule 1 of the Data Protection Act 2018 (‘DPA 2018’).
Some Schedule 1 conditions for processing special category and criminal offence data require us to have an Appropriate Policy Document (‘APD’) in place. This sets out and explains our procedures for securing compliance with the principles in Article 5 UK GDPR, and policies regarding the retention and erasure of such personal data.
This document explains our processing and satisfies the requirements of Schedule 1, Part 4 of the DPA 2018.
This document should be read alongside our data protection policy.
Special category data is defined at Article 9 UK GDPR as personal data relating to:
- racial or ethnic origin
- political opinions
- religious or philosophical beliefs
- trade union membership
- genetic data
- biometric data for the purpose of uniquely identifying a natural person
- data concerning health; or
- data concerning a natural person’s sex life or sexual orientation
Criminal conviction data is described at Article 10(1) of the UK GDPR as any personal data relating to criminal convictions and offences or related security measures. This is further defined at Section 11(2) of the DPA 2018 as personal data relating to:
- the alleged commission of offences by the data subject; or
- proceedings for an offence committed or alleged to have been committed by the data subject or the disposal of such proceedings, including sentencing
Scope
This policy applies to:
- all special category and criminal conviction data that we process for the purposes described in this document, regardless of its format
- any individual processing personal data that we hold