In a meeting yesterday the question of using personal data for survey
purposes arose - local authorities are required to use surveys for various
purposes (e.g. best value, customer satisfaction).
I am aware of the guidance from the IC that the Council is allowed to
enclose surveys about its services with its Council Tax canvass forms and
to use Council Tax mailings to promote other council services, as such
activities would be considered to be reasonably incidental to the council’s
general functions and would be permitted by Section 111 of the Local
Government Act 1972, but haven't been able to find any other specific
guidance.
I have advised colleagues that they must not use Council Tax data otherwise
than as noted above, nor must they use the full Electoral Register.
As regards other databases (e.g. housing benefits, fault reports) would I
be right in thinking that we should be asking for consent for names and
addresses to be used for survey purposes at the time of gathering the data -
e.g. by including a clause something like "The Council may wish to contact
users of its services to identify the level of satisfaction with those
services. Please tick here if you do not wish to be contacted for such a
purpose."?
Would I also be right in thinking that if sensitive personal data were
involved we would need to seek explicit consent (i.e. an opt-in box)?
TIA,
Graham
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