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Use of Social Media Data to conduct age assessments

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Privacy International

Dear Sir/Madame,

This request relates to the use of social media data by local authorities and/or entities carrying out public functions on behalf of local authorities to conduct age assessments.

We aware of the increasing prevalence of the use of social media intelligence within central and local government for a wide variety of purposes.

For example, in 2020 Privacy International published research highlighting the use of social media intelligence (SOCMINT) by local authorities. Our report (https://privacyinternational.org/report/...) disclosed that local authorities are looking at people's social media accounts, as part of their intelligence gathering and investigation tactics in areas such as council tax payments, children’s services, benefits and monitoring of protests and demonstrations.

This year, we have become aware that local government authorities are collecting personal data from individuals' social media accounts, and using this as evidence in the course of age verification hearings for asylum seekers (https://tribunalsdecisions.service.gov.u...). Local Authorities are requesting access to log in details (usernames and passwords) to social media accounts, as well as downloads of full histories of Facebook activities (which is only accessible to users when logged in)(https://www.independent.co.uk/news/uk/ho...). This has also included data from personal messaging apps such as WhatsApp and Facebook Messenger.

In light of the above information, we request the following information by way of a Freedom of Information Act request:

1. Please inform us if, further to a court order and/or Home Office instruction, you have conducted a review of an individual's social media or other communications or downloaded data for the purposes of an age assessment in the immigration context.

2. (a) Please confirm whether the individual is always present when the review is conducted and

(b) whether they are accompanied by their legal representative or an appropriate adult.

3. Please clarify if you record these requests in such a way that you can give figures for the amount of age assessments conducted by your local authority that involve reviews of social media or other communications or downloading of data. If you do record them in a way that means you can provide figures, please confirm the number of age assessments conducted that involve a review of an individual's social media in the last 12 months.

4. Please could you provide us with the relevant guidance and/or policy in relation to these requests for age assessments that involve reviews of social media or other communications or downloading data.

5. Please can you provide us with a copy of the Data Protection Impact Assessment if you have conducted one (DPIA).

6. Please confirm the legal basis you rely upon when seeking to obtain disclosure of social media and messenger (such as WhatsApp, Facebook Messanger, Viber etc) log in details or other communications for age assessment for immigration purposes.

7. Please provide us with any training materials relevant to the above issues.

If you are unclear on what we are asking or require us to reduce the number of questions to enable you to respond please let us know.

I look forward to hearing from you.

Yours faithfully,

Nour Haidar
Privacy International

East Dunbartonshire Council

Thank you for you Freedom of Information request.

This is an automated response. Your message has been received by East
Dunbartonshire Council.

Your request will be dealt with promptly and a full response will be issued
within 20 working days.

Should you not receive a response within this period, or you have any other
queries about your request please contact: [East Dunbartonshire Council request email] or 0141
578 8057.

DISCLAIMER:
This email and any files transmitted with it are intended for the use of the individual or entity to whom they are addressed. It may contain information of a confidential or privileged nature.

If you have received this email in error please notify the originator of the message and destroy the e-mail.

East Dunbartonshire Council can not be held responsible for viruses, therefore please scan all attachments.

Any personal data contained in email communications with East Dunbartonshire Council will be processed in accordance with the UK General Data Protection Regulations ("GDPR") and all other relevant data protection laws.

Further information detailing how East Dunbartonshire holds and uses personal information and copies of privacy notices used throughout the Council are available on our website at:
https://www.eastdunbarton.gov.uk/council...

The Council?s Data Protection Officer can be contacted at [email address] or on Tel: 0300 123 4510.

The views expressed in this message are those of the sender and do not necessarily reflect those of East Dunbartonshire Council who will not necessarily be bound by its contents.

East Dunbartonshire Council

FAO Nour Haidar
Privacy International

Dear Nour,

Thank you for your request for information. In answer to your enquiry I can
provide the following response on behalf of East Dunbartonshire Council

1. Please inform us if, further to a court order and/or Home Office
instruction, you have conducted a review of an individual's social media or
other communications or downloaded data for the purposes of an age
assessment in the immigration context. We have conducted no such reviews.

2. (a) Please confirm whether the individual is always present when the
review is conducted and
(b) whether they are accompanied by their legal representative or an
appropriate adult. N/A

3. Please clarify if you record these requests in such a way that you can
give figures for the amount of age assessments conducted by your local
authority that involve reviews of social media or other communications or
downloading of data. If you do record them in a way that means you can
provide figures, please confirm the number of age assessments conducted
that involve a review of an individual's social media in the last 12
months. N/A

4. Please could you provide us with the relevant guidance and/or policy in
relation to these requests for age assessments that involve reviews of
social media or other communications or downloading data. N/A

5. Please can you provide us with a copy of the Data Protection Impact
Assessment if you have conducted one (DPIA). N/A

6. Please confirm the legal basis you rely upon when seeking to obtain
disclosure of social media and messenger (such as WhatsApp, Facebook
Messanger, Viber etc) log in details or other communications for age
assessment for immigration purposes. N/A

7. Please provide us with any training materials relevant to the above
issues. N/A

Should you have any questions on the content of the response and would like
the Local Authority to clarify or explain, please do feel free to get in
contact, citing the enquiry reference number above.

If you are dissatisfied with the way in which East Dunbartonshire Council
responded to your request, you are entitled to require the Council to
review its decision. The review will be handled by staff who were not
involved in the original decision. Please note that in order for a review
to take place you must:
· Lodge a written requirement for a review within 40 working days of
the date of this letter
· Include a correspondence address and a description of the original
request and the reason why you are dissatisfied.
· Address your request to the Freedom of Information team :

[East Dunbartonshire Council request email]

The review will be handled by staff who were not involved in the original
decision. You will receive notice of the results of the review within 20
working days of receipt of your request. The notice will state the
findings of the review as well as details of how to appeal to the Scottish
Information Commissioner if you are still dissatisfied with the Council?s
response. You must request an internal review by the Council before a
complaint can be directed to the Scottish Information Commissioner.

Information Management Team
East Dunbartonshire Council
[email address]
www.eastdunbarton.gov.uk
www.facebook.com/edunbartonshirecouncil

Kind regards
Angela

Angela Fegan
Customer, Performance & PR Manager
East Dunbartonshire Council

Tel: 0141 578 8078
[mobile number]
Email: [email address]

www.eastdunbarton.gov.uk
Follow us on Twitter @EDCouncil or like us on
www.facebook.com/edunbartonshirecouncil

DISCLAIMER:
This email and any files transmitted with it are intended for the use of the individual or entity to whom they are addressed. It may contain information of a confidential or privileged nature.

If you have received this email in error please notify the originator of the message and destroy the e-mail.

East Dunbartonshire Council can not be held responsible for viruses, therefore please scan all attachments.

Any personal data contained in email communications with East Dunbartonshire Council will be processed in accordance with the UK General Data Protection Regulations ("GDPR") and all other relevant data protection laws.

Further information detailing how East Dunbartonshire holds and uses personal information and copies of privacy notices used throughout the Council are available on our website at:
https://www.eastdunbarton.gov.uk/council...

The Council?s Data Protection Officer can be contacted at [email address] or on Tel: 0300 123 4510.

The views expressed in this message are those of the sender and do not necessarily reflect those of East Dunbartonshire Council who will not necessarily be bound by its contents.

We don't know whether the most recent response to this request contains information or not – if you are Privacy International please sign in and let everyone know.