Data collecting, storing, sharing or selling. And data breaches

The request was successful.

Dear Warwickshire Police,

I am making a Freedom of Information request to find out the answers to the below
questions. Please provide your responses in electronic format. Thank you in advance for
your time spent answering them.

Can I have your records pertaining to sales of personal data from 2019 (01.01.2019) to 2020 (31.12.2020), including trading partners and money earned from transactions?

Do you use tracking cookies on your website, and can I have a list of third parties
that you share personal data with?

Have you received any complaints about how you handle personal data? This
includes collecting, storing, sharing or selling, as well as wider processing
practices. Please can I view records pertaining to these complaints for the years 2019 and 2020?

How many Subject access requests did you receive in the period 2019-2020,
broken down by year? What types of personal data did they typically receive? For
example email addresses, home address and telephone number?

How many data breaches have you experienced for the past 5 years (broken down by each year).

Yours faithfully,

Hana Bednarova

@ Freedom of Information, Warwickshire Police

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Please see below other teams that may be of assistance.

 

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·          [3][email address] for Criminal
Injuries Compensation Authority (CICA) requests.

 

·          [4][email address] for all
data protection related requests

 

References

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2. mailto:[email address]
3. mailto:[email address]
4. mailto:[email address]

@ Freedom of Information, Warwickshire Police

1 Attachment

Dear Hana Bednarova,

 

FREEDOM OF INFORMATION REQUEST REFERENCE NO: 230-2021

 

We are writing in connection with your request for information which was
received on 12^th March 2021.  Your request will now be considered in
accordance with the Freedom of Information Act 2000 (“the Act”).

 

We will make every effort to provide a response to your request within 20
working days as stipulated by the Act.

 

There may be a fee payable for the retrieval, collation and provision of
the information you request.  If this is the case you will be informed and
the 20 working day timescale will be suspended until we receive payment
from you.  If you chose not to make payment then your request will be
withdrawn.

 

Some requests may also require either full or partial transference to
another public authority in order to answer your query in the fullest
possible way.  Again, you will be informed if this is the case.

 

Should you have any further enquiries concerning this matter, please
contact the Freedom of Information Unit via email quoting the reference
number above.

 

Yours sincerely,

 

Amy Kimber

FOI Administration Officer

Information and Compliance

Warwickshire Police

 

[1]Colour - Warwickshire Logo (FINAL Oct 2019)

 

References

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@ Freedom of Information, Warwickshire Police

 
Dear Hana Bednarova,
 
FREEDOM OF INFORMATION REQUEST REFERENCE NO: 230-2021
I write in connection with your request for information which was received
on 12^th March 2021. Please find below the response to your request:
 
Request:
 
I am making a Freedom of Information request to find out the answers to
the below questions. Please provide your responses in electronic format.
Thank you in advance for your time spent answering them.
 
1.Can I have your records pertaining to sales of personal data from 2019
(01.01.2019) to 2020 (31.12.2020), including trading partners and money
earned from transactions?
 
2.Do you use tracking cookies on your website, and can I have a list of
third parties that you share personal data with?
 
3.a)Have you received any complaints about how you handle personal data?
This includes collecting, storing, sharing or selling, as well as wider
processing practices.
b)Please can I view records pertaining to these complaints for the years
2019 and 2020?
 
4. a)How many Subject access requests did you receive in the period
2019-2020, broken down by year?
b) What types of personal data did they typically receive? For example
email addresses, home address and telephone number?
 
5.How many data breaches have you experienced for the past 5 years (broken
down by each year).           
 
Response:
1. Warwickshire Police do not sell personal data. As such there is no
information held.
 
2. Information relevant to this question is published on the Warwickshire
Police website at the link below.
 
As the information is Reasonably Accessible by other means, exemption
under S21 FOIA is applicable.  This is an absolute class based exemption
which does not require evidence of harm and does not require consideration
of a public interest test.
 
 
Cookies - [1]Cookies | Warwickshire Police
([2]https://www.warwickshire.police.uk/hyg/c...)
 
Privacy notice - [3]Privacy notice | Warwickshire Police
([4]https://www.warwickshire.police.uk/hyg/f...)
 
3. a) complaints relating to processing of personal data for 2019 and 2020
2019- Nine complaints received from ICO, of these:

* Seven related to complaints from individuals unhappy with SAR
responses
* One related to complaint re the intrusiveness of vetting
* One  related to a concern of unauthorised disclosure

2020- One concern / request for deletion of vetting record
 
 
3. b) The following exemption is applicable to the records pertaining to
the complaints for the years 2019 and 2020 referred to as these would
contain personal data.
 
Section 40(2) Personal Information
 
Section 40(2) applies to third party personal data. This would not be
released under the Freedom of Information Act unless there is a strong
public interest. This is because any release would breach the Data
Protection Principles contained within the Data Protection Act (1998).
 
Section 40 is an absolute class-based exemption which does not require
evidence of the harm that disclosure would cause and does not require
demonstration of a public interest test. That said, where Section 40(2) is
engaged, in order to make the exemption absolute, there needs to be
evidence that a data protection principle would be breached by disclosure.
Any information that relates to an individual, or from which an individual
could be identified, constitutes personal data and, in this case, it would
not be fair to process information which could lead to the identification
of an individual and would breach the first principle of the Data
Protection Act, ‘Fair and Lawful Processing’.
 
Please treat this letter as the Refusal Notice I am required to provide to
you in relation to Q3.b)
 
4. a)   2019 – 233
2020 - 245
 
b) No specific Information Held. Please note that there is not any typical
type of information provided under a SAR, other than it being the personal
information to which the requesting individual is entitled to receive from
Warwickshire Police.  Examples of information requested under a SAR could
include crime reports, statements, body worn video footage, interview
records etc.
 
Every effort has been made to ensure that the information provided is as
accurate as possible
 
Your attention is drawn to the below which details your right of
complaint.
 
Should you have any further enquiries concerning this matter, please write
or email the Freedom of Information Unit quoting the reference number
above.
 
Yours sincerely
 
Sabina Harris
Freedom of Information Officer
Freedom of Information Unit
Warwickshire Police
PO Box 4
Leek Wootton
Warwickshire
CV35 7QB
[5][email address]
 
Warwickshire Police in complying with their statutory duty under sections
1 and 11 of the Freedom of Information Act 2000 to release the enclosed
information will not breach the Copyright, Designs and Patents Act 1988. 
However, the rights of the copyright owner of the enclosed information
will continue to be protected by law.  Applications for the copyright
owner’s written permission to reproduce any part of the attached
information should be addressed to The Force Solicitor, Warwickshire
Police, Leek Wootton, Warwick, Warwickshire, CV35 7QA.
 
COMPLAINT RIGHTS
 
Are you unhappy with how your request has been handled or do you think the
decision is incorrect?  You have the right to require Warwickshire Police
(WP) to review their decision.
 
Prior to lodging a formal complaint you are welcome and encouraged to
discuss the decision with the person that dealt with your request.
 
Ask to have the decision looked at again.  The quickest and easiest way to
have the decision looked at again is to telephone the person named at the
end of your decision letter.  That person will be able to discuss the
decision, explain any issues and assist with any problems.
 
Complaint
 
If you are dissatisfied with the handling procedures or the decision of WP
made under the Freedom of Information Act 2000 (the Act) regarding access
to information, you can lodge a complaint with WP to have the decision
reviewed.  WP must be notified of your intention to complain within 20
working days of the date of its response to your Freedom of Information
request.  Complaints should be made in writing and addressed to:
 
Freedom Of Information Unit
Warwickshire Police
PO Box 4
Leek Wootton
Warwickshire
CV35 7QB
 
 
Alternatively, you can email
[6][email address]
 
In all possible circumstances, WP will aim to respond to your complaint
within 20 working days.
 
The Information Commissioner
 
If after lodging a complaint with WP you are still dissatisfied with the
decision, you may make application to the Information Commissioner (ICO)
for a decision on whether the request for information has been dealt with
in accordance with the requirements of the Act.
 
For information on how to make application to the Information Commissioner
please visit their [7]website.  Alternatively, you can contact the ICO in
writing or via phone:
 
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
 
Tel:  0303 123 1113 (local rate) or 01625 545745 (national rate)
Fax:  01625 524 510
 
 
 
 
 
 

References

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1. https://www.warwickshire.police.uk/hyg/c...
2. https://www.warwickshire.police.uk/hyg/c...
3. https://www.warwickshire.police.uk/hyg/f...
4. https://www.warwickshire.police.uk/hyg/f...
5. mailto:[email address]
6. mailto:[email address]
7. https://ico.org.uk/

Dear Sabina,

Thank you for your reply and all the information.

I wanted to check if question 5 (5.How many data breaches have you experienced for the past 5 years (broken
down by each year) can also be answered? I can't find relevant information regarding this question in the above response.

Yours sincerely,

Hana Bednarova

@ Freedom of Information, Warwickshire Police

1 Attachment

Dear Hana,

Thank you for your email below. Please accept my apologies for the omission of the response to Q5. I have now attached an amended copy of the Warwickshire Police response to your request, which includes the response to Q5.

Yours sincerely,

Sabina Harris
Freedom of Information Officer
Freedom of Information Unit
Warwickshire Police
email: [email address]

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