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Vetting privacy

Bedfordshire Police, Cambridgeshire Constabulary and Hertfordshire Constabulary (BCH) are required to collect, use and disclose information about people – ‘their personal information’ – to carry out their legal and legitimate functions as defined by legislation, common law, regulation, policy and best practice.

Information we collect from you

Everyone in the police service must maintain high ethical and professional standards and act with the utmost integrity and a robust vetting process is necessary to verify whether or not someone is suitable to serve in, or work alongside BCH.  To enable the vetting process to take place you will be asked to provide personal details, such as your name, address, date and place of birth, employment history, financial history, your contact details, your interactions with law enforcement, your social media presence, etc. 

Third party personal data

You will also be asked to provide personal details of people you have an association with.  This would include as appropriate; partner, family members, people you live with and any known offenders. You must inform all those listed on the form, where practical to do so, that background checks will be conducted about them.

Do I have to provide the information?

Whilst 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.

Special category data

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

  • Race;
  • Ethnic origin
  • Religion or belief
  • Biometric data;
  • Sexual orientation

Also see protected characteristic data below.

Criminal offence data

As part of the vetting process, criminal offence data may be collected.  This concept of criminal offence data includes the type of data about criminal allegations, proceedings or convictions that would have been sensitive personal data under the 1998 Act. However, it is potentially broader than this.  We process this type of data as we have official authority to do so because we are processing the data in an official capacity.  This includes Spent and Unspent criminal records, as well as those offences that are Protected and Not Protected under the Rehabilitation of Offenders Act. 

Protected characteristics

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

  1. Age
  2. Disability
  3. Gender reassignment
  4. Marriage and Civil Partnership
  5. Pregnancy and Maternity
  6. Race or Ethnicity
  7. Religion or Belief
  8. Sex or Gender
  9. Sexual Orientation

The information on the vetting form that specifically asks about 1-9 above is for monitoring purposes only, except where it is required for identification purposes.  Eg; your age.  The information supplied will be treated in the strictest confidence and will not affect the vetting outcome in any way.  The information will help us to monitor any disproportionality in vetting.

The Police Service recognise their 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. The Police Service acknowledge the government guidelines and 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. The Police Service acknowledge their legitimate aim for requesting disclosure and its legal obligations under these requirements.  Where you are providing details of another individual (Partner, family members etc.) and this discloses their (Trans) gender history the same protections are afforded.  You are obliged to provide this information, however it is recognised that 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 police personnel involved in the vetting process who will be required to honour that confidentiality under Section 22 of the Gender Recognition Act (2004).  In the event that any relevant information is divulged which requires confirmation or clarification, it may be necessary to disclose information contained within the vetting unit to other organisations or agencies not part of the Police Service. These organisations are also bound by their equality duty and subject to the same laws of confidentiality.  As part of the aforementioned confirmation or clarification, the organisation or agency concerned may be requested to disclose personal information. 

There is no statutory protection for individuals who fail to disclose this information, where it is legitimately required, say for identification purposes, e.g.; your age

Should you wish to have a conversation about how this information, or any personal information is handled and the protection it is afforded, please contact ask for the “HR Equality and Inclusion Advisor” by phone on 101 or by email for all three forces at HRenquiries@herts.pnn.police.uk or if you prefer to talk to the BCH Vetting Team direct, then contact BCHVetting@herts.pnn.police.uk.

Legal basis

Under the General Data Protection Regulation (GDPR) the legal basis we rely on for processing personal information for vetting purposes is Article 6(1)(c) compliance with a Legal Obligation.

The Statutory basis for this is the College of Policing Vetting Code of Practice (issued October 2017).  This was presented to Parliament pursuant to Section 39A (5) of the Police Act 1996, as amended by Section 124 of the Anti-Social Behaviour, Crime and Policing Act 2014. 

Storing information

The information provided will be stored securely in manual and/or computerised forms.

Sharing information

The information may be shared with other police forces / agencies in the United Kingdom in respect of any applications you may make where police or national security vetting is necessary.  Within BCH the information provided will not be shared with anyone outside the Professional Standards Department and Human Resources Department, on occasions Information Management Department and Legal Services Department, unless for a legitimate law enforcement or other lawful purpose.  Notwithstanding the above, by and large, the information is not shared with anyone outside the Vetting Unit. 

What we will use the information for

The information provided will be used as the basis for conducting background checks and enquires against Police databases 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 vetting subject only and not for any other individuals named on the form.  Although if you are financially linked to someone, then that will become apparent.

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. The personal data collected will continue to be held within the records created for that purpose.     

Human and unattended automation data processing

The background checks [data processing] will be conducted by specially trained vetting personnel.  In addition, unattended automation will take place, this is called Robotics [Bot], which will assist the vetting personnel.  This is not automated decision-making or profiling.  The Bot will extract some of the vetting subject’s personal data [Name(s), Date of Birth and Address(es)] from the vetting database and automatically input that data into the search databases that a human would do. 

The results are presented to the vetting personnel to assess as normal.  The data subjects’ usual rights of data processing throughout this Privacy Notice are not affected by this automation.  The Bot meets all the necessary accreditation for such purpose. To ensure the Bot has returned the correct information, the data results from the Bot will be subject to the same checks and balances as if the data had been collated by a human.

How long will we keep your information for?

We will only keep your information for as long as it is required to be retained.  Information provided to facilitate vetting will be retained for the duration of the application and beyond in accordance with the National Police Chief Council document; National Guidance on the minimum standards for the Retention and Disposal of Police Records.

Third party personal data

Third party personal data provided by individuals subject to the vetting process will be retained on the file of the person who was vetted. As above the information will be held and reviewed in line with the National Guidance on the minimum standards for the Retention and Disposal of Police Records. The relevant section of the National Guidance is shown below:

Third party personal data

Information Activity / Task

Description / Example of Record

Retention (Minimum Period)

Rationale

Vetting

Contractor vetting

End of contract + one year

Force   Policy

Vetting

Successful vetting:

Personnel vetting, local intelligence checks, references, referees checks, counter terrorist checks etc.

 

Police personnel

-

Six years after leaving, one year after death

Force   Policy

Vetting  - refusals

Failed vetting

Six years

Civil   Liability Act

Vetting   – Temporary Staff and Contractors

Non-Police Personal Vetting

End of contract + one year

Force   Policy

Your rights

Amongst other rights, you have a right to request a copy of personal information that BCH holds about you.

Contact details

Bedfordshire Police, Cambridgeshire and Hertfordshire Constabularies [BCH] are part of a strategic alliance which deliver joint capabilities through some collaborated units including the BCH Vetting Unit.

The Chief Constables of Bedfordshire Police, Cambridgeshire Constabulary and Hertfordshire Constabulary are data controllers for their respective forces, and as such have overall responsibility for the lawful processing of all personal data by their force.

The Controller, as defined by Data Protection Act 2018 and the GDPR, is: 

Data Controller for Cambridgeshire Constabulary:

The Chief Constable
Cambridgeshire Constabulary Headquarters
Hinchingbrooke Park
Huntingdon
PE29 6NP

ICO Registration Number: Z4882190

Any individuals with concerns regarding the way in which BCH handle their personal information, may contact the Data Protection Officer, via the following:

Director of Information
c/o Bedfordshire Police Headquarters
Woburn Road
Kempston
Bedford
MK43 9AX

Information Commissioner

The Information Commissioner is the independent regulator responsible for enforcing the legislation and provides advice and guidance about the requirements. The Information Commissioner’s Office (ICO) can be contacted via the following:

Information Commissioner’s Office
Wycliffe House
Water Lane
SK9 5AF

Tel: 0303 123 1113 (local rate) / 01625 545 745 (national rate)

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