Privacy
The following is to explain your rights and to give you information you are entitled to under the Data Protection legislation.
It is important that you read this notice, together with any other privacy notice that is provided when we are collecting or processing personal information about you from services accessed from the Defence Support Hub, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with the data protection principles under the data protection legislation. This says that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- relevant to the purposes we have told you about and limited only to those purposes
- accurate and kept up to date
- kept only as long as necessary for the purposes we have told you about
- kept securely
The identity and contact details of MOD Data Controller and Data Protection Officer
The Ministry of Defence (MOD) is the data controller. The contact detail is:
MOD Data Protection Officer
Ground floor, zone D
Main Building
Whitehall
London
SW1A 2HB
Email: cio-dpa@mod.gov.uk
The kind of information we hold about you
Personal data, or personal information refers to any information about individuals from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The Defence Support Hub collects and uses the following categories of personal information about you:
- contact details such as your name and email address(es)
Our legal basis for processing your personal data
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- where it is in the public interest to do so; or for official purposes; or in the exercise of a function of the Crown, a minister of the Crown or GLD as a government department
- where it is necessary for the purposes of the legitimate interests pursued by MOD or by a third party
- where we need to comply with a legal obligation
- where we have your informed consent
- there can be rare occasions where it becomes necessary to use your personal information to protect your interests (or someone else’s interests)
Why are we collecting or processing your data
The Defence Support Hub collects data only to:
- ensure that you are authorised to access systems
- enable us to contact you if you have reported a problem or submitted feedback
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated or new purpose, we will notify you and explain the legal basis which allows us to do so.
How we store personal data
Your personal data will be stored in a secure government Information technology system. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal information to only MOD personnel, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions. Details of these measures are available upon request from local Data Protection Advisors.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure, in a contractual arrangement.
We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office (ICO) of a suspected breach where we are legally required to do so.
With whom we will be sharing your personal data
We will in some circumstances have to share your data with third parties, including third-party service providers and other Civil Service bodies. We require third parties to respect the security of your data and to treat it in accordance with the law. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you; where it is in the public interest to do so or where it is necessary for the performance of our functions as a government department or a function of the Crown. This will, in some circumstances, involve sharing special categories of personal data and, where relevant, data about criminal convictions/allegations.
How secure is my information with third-party service providers?
All our third party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
If required, we will need to share your personal information with a regulator or to otherwise comply with the law.
Personal data will be kept as long as the individual is a registered user of the Defence Support Hub. Low level personal data will be kept as long as is necessary.
It is very difficult to quantify how long records will be kept for due to the variable lengths of and variable requirements contained in MOD contracts.
However, JSP441 has been referenced and the requirement to maintain records for the length of the contract plus an additional 7 years has been noted.
After the retention period has elapsed all data will be destroyed securely in line with MOD data destruction policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we will anonymise your personal information so that it can no longer be associated with you, in which case we will use such information without further notice to you.
Duty to inform
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights
Under certain circumstances, by law, you have the right to:
Request access to your personal information
This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
If you want to find out if MOD or any of our agencies hold any personal information about you, or want to make any corrections, you can make a ‘subject access request’ (SAR) under the Data Protection legislation. If we do hold information about you, we will:
- give you a description of it
- tell you why we are holding it
- tell you to whom it has, or will be disclosed, in particular if it has been disclosed to international organisations
- let you have a copy of the information in a form that is as clear and understandable as possible
Please be as specific as you can about the information you want. For information about how to make a SAR application see our guide on obtaining information about yourself.
Request correction of the personal information that we hold about you
This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information
This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
Object to processing of your personal information
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information
This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information
Allows you to obtain and reuse your personal data for your own purposes across different services. If you want to verify, correct, or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please make a request in writing to: ISS-DataSubjectRights@mod.gov.uk.
Guidance is also available on Data Protection: rights for data subjects page.
Right to withdraw consent
In the limited circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please contact: ISS-DataSubjectRights@mod.gov.uk
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we are allowed under the law to charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we can refuse to comply with the request in such circumstances.
What we need from you
To comply with your request, we sometimes need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Further information can be found at the ICO website.
How to complain
If you are unhappy with how any aspect of this privacy notice, or how your personal information is being processed, please contact:
MOD Data Protection Officer Ground floor, zone D Main Building Whitehall London SW1A 2HB
Email: cio-dpa@mod.gov.uk
We will acknowledge your complaint within 5 working days and send you a full response within 20 working days. If we can’t respond fully within this time, we will write and let you know why and tell you when you should get a full response.
If you are still not happy, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
Information Commissioner’s Office
Wycliffe House Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
Email: casework@ico.org.uk
Website: https://ico.org.uk/global/contact-us
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We will also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please email the Information Rights Team: cio-dpa@mod.gov.uk.
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