Police vetting privacy notice

Vetting is a risk management process used to assess any potential risk posed to a police force or wider service and, where appropriate, assist in the identification of proportionate and realistic risk mitigation measures.

We will process your personal data and that of third parties (family members, relatives, associates) in accordance with the College of Policing Vetting Code of Practice, associated Authorised Professional Practice (APP) and the Police Act 1996.

We will collect:

• Personal information, for example, name, home address and previous address where necessary, date of birth and national insurance number

For higher clearance levels, we will collect:

• Information in relation to your family members, including your partner and children and potentially, your associates. It is the responsibility of the applicant to request the consent of any third parties listed on their vetting form
• Alleged or actual criminal offences
• Financial data and banking details
• Social media information

Your personal data and that of third parties will be processed in accordance with the Vetting Code of Practice and APP dependent on the level of access required to Police infrastructure and information assets. The vetting form that you are required to complete and provide personal data on, is proportionate and necessary for your level of vetting.

United Kingdom Security Vetting Services (UKSV) provide vetting clearance for national security roles. Avon and Somerset Police will submit your details to their system and they will process your application. UKSV have their own privacy notice.

The information you provide will be checked against Police databases (Local and National systems) and information systems.

Where applicable, it will also be checked against ‘open source’ internet, the records of Credit Reference Agencies and other third party records.

Where Credit Reference Agency records are checked, this will be for the applicant only and not for any other individuals named on the form.

Any information which is revealed as a result of the vetting process is reviewed by a vetting practitioner. There is no automated decision making process.

While you can decline to provide some or all of the information required in the vetting forms, it will not be possible to conduct a meaningful risk assessment and clearance cannot be granted.

As part of the vetting process, special category data may be collected. Special
category data includes information about your:

• race
• ethnic origin
• religion
• biometric data
• sexual orientation

Protected characteristics

The vetting form requires the disclosure of sensitive data, including data relating to protected characteristics.

There is no statutory protection for individuals who fail to disclose this information, where it is legitimately required.

Vetting of transgender individuals

Within its vetting process in Avon and Somerset and its legal obligations under the Equalities Act 2010  and the Gender Recognition Act 2004 with particular attention paid to Section 22 (GRA 2004) regarding disclosure of Protected Information.

Additionally we acknowledge  the government guidelines and the requirements to secure ‘Protected Information’ whether it is communicated verbally, materially or held electronically as required under UK law.

Any disclosed information is managed by these protocols and is not disclosable to any other parties without explicit written permission from the owner of the Protected Information. We acknowledge its legitimate aim for requesting disclosure and its legal obligations under these requirements.

Should you have any concerns specifically regarding the disclosure of information in relation to gender history, email the Equality and Diversity team at Representative.Workforce@avonandsomerset.police.uk.

Be reassured that all information is treated in the strictest confidence and only used for the purposes of vetting. Confidence will be maintained as much as possible. There will be occasions where it is proportionate and necessary to disclose the information to other units, such as Professional Standards Department or Counter Corruption.

Where you are providing details of another individual, for example, partner, or family members, and this discloses their (Trans) gender history, the same protections are afforded.

The applicant is obliged to provide this information, however it is recognised these security checks will seek information that may lead to the identification of transgender status.

This information will remain confidential and the disclosure of this information will be restricted to those members of staff involved in the vetting process who will be required to honour that confidentiality under Section 22 of the Gender Recognition Act (2004).

The information you provide is stored electronically in a secure database. This database is restricted to only those personnel who are required to access for a business purpose associated to vetting.

Applications are kept only for as long as necessary are available. The retention periods are documented on the Force’s Retention Schedule on our website.

Your personal information may be shared with the Human Resources (HR) department for the purposes of adding you to the HR system. The personal information of any other individuals named on the form will not be provided to HR.

The above also applies to any external personnel or contractor who require unsupervised access to force premises, information, systems or other assets.

Risk mitigation

On rare occasions where a risk has been identified, we may consider that it is possible to mitigate that risk to an acceptable level by sharing relevant information with someone within your line management chain.

Should this apply to you, we will not share your personal data without discussing this with you first and obtaining your explicit consent. If we seek to do this we will give you further explanation of the reasons why and purpose and also explain your rights with regard to providing and withdrawing consent.

Personal information provided on the vetting form may, where necessary and proportionate, be shared with other departments of the force, other police forces or external agencies. This will be considered on a case by case basis and be limited to only the information which is necessary, in accordance with the relevant legislation. Further information relating to organisations we share data with can be found on our Privacy notice.

Information provided within the vetting form is not normally transferred overseas unless there is a requirement due to residency or checkable history. Details from your application will be forwarded to ACRO for checks to be completed. Further details in relation to this process can be found on the ACRO website.

Information provided on the vetting form may be used for the purposes of statistical information. Such data will be fully anonymised.

If your clearance is refused or withdrawn and you decide to appeal to the vetting appeal panel and or designated authority, we will provide the panel and or designated authority with relevant personal data to enable them to consider your appeal.