Management of logins at third party partner web sites
Dear Merton Borough Council,
I have a query regarding Merton Council's partnership with Beat the Streets.
I signed up for this and received a "goodbye" email on 9th October 2023. The email is clear that this is a "final farewell".
However the login I set up at the Beat the Streets web site is still functioning today - 16 October 2023.
It is concerning that there is no information in the farewell email about account management.
Having been officially told by a partner provider that their connection with Merton Council is at an end, a user might assume their account is also automatically deleted, or simply forget all about the account they have set up.
In any case, good practice suggests the partner provider should make it clear what happens regarding accounts that were set up, and provide a link for people to delete their account.
Can you please:
a) Provide a copy of Merton Council's policy on working with third party providers that require the creation of an account - please provide the policy in full and in your written reply pull out the section on automatic account deletion at the end of the partner period,
b) Detail Merton Council's specific relationship with Beat the Streets in terms of account deletion at the end of the project period.
Yours faithfully,
Sandra Vogel
Thank you for your email message. We aim to respond to all requests under
the Freedom of Information Act 2000 and Environmental Information
Regulations 2004 within 20 working days. More information about the way we
deal with information requests is on our web site at
[1]www.merton.gov.uk/foi
Information Governance Team
London Borough of Merton.
020 8545 4634
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should handle it accordingly.
Please view the council's privacy notice at
https://www.merton.gov.uk/legal/privacy-...
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Dear Sandra
Freedom of Information Act 2000 / Environmental Information Regulations
2004 Information request
We have now considered your information request as set out below.
You asked:
a. Provide a copy of Merton Council's policy on working with third party
providers that require the creation of an account - please provide the
policy in full and in your written reply pull out the section on
automatic account deletion at the end of the partner period,
Merton Council do not have a policy for working with third party providers
that require the creation of an account.
b. Detail Merton Council's specific relationship with Beat the Streets in
terms of account deletion at the end of the project period.
The Goodbye/Final Farewell email sent by Beat the Street is the title of
the last marketing email sent to participants. Whilst Intelligent Health
(the provider of Beat the Street) will not send registered participants
any more emails, participants email addresses have not been deleted from
Intelligent Health systems yet.
All data collected is anonymised or deleted in accordance with the Beat
the Street Data Retention and Deletion Policy. The timelines of the
deletion of personal data is laid out in the Beat the Street Privacy
Policy which can be found here: [1]https://www.beatthestreet.me/privacy/.
Participants agree to this Privacy Policy when registering to participate.
For your ease, this is set out below.
Summary of how long your data will be kept for different purposes
Unless you have provided explicit authority for data to be kept for
longer:
1. Personal data collected through registration will be de-identified 26
months after you have registered to participate. Personal data for the
purposes of this statement, includes: your email address, name, date
of birth and postcode. It will be de-identified by removing name,
email address, month of birth and substituting post code with Lower
Super Output Area, which are small areas designed to be of a similar
population size, with an average of approximately 1,500 residents or
650 households. There are 32,844 Lower-layer Super Output Areas
(LSOAs) in England.
2. Personal data will be removed from tap data after 14 months - the data
will be de-identified using Globally Unique Identifiers (GUIDs). These
GUIDs will link tap data to the personal data collected in our
surveys, which itself will be de-identified after 26 months.
3. Data used to contact you for marketing or service updates, held by our
third-party provider (Sendinblue), will be deleted 14 months after
registration for the game.
4. Data collected in surveys using our third-party provider
(Surveymonkey) will be removed from Survey Monkey 26 months after
completion of the survey. This data will then be de-identified and
moved to AWS to be stored for an undefined period for the purpose of
conducting statistical research to help improve physical activity and
mental wellbeing for communities. We de-identify this data by removing
personal identifiable information (such as name, email addresses). At
this time, you will be informed of this by email and provided with
details on how to request erasure of your data if you so wish.
5. Photo, audio or video footage data collected at events will be
retained for a period of 36 months, or for for a longer period if the
content remains relevant in its current form when incorporated in
marketing or promotional brochures, presentations, podcasts or videos.
This will be removed at your specific request.
Should a player wish Intelligent Health to delete their email address or
any other personal data that they hold on them, they can request this by
emailing [2][email address], providing their name and email
address. Intelligent Health will then delete all of the data and log this
on their Data Subject Access Request (DSAR) log.
If you have any queries or concerns about this please contact me.
If you are dissatisfied with the handling of your request or wish to
appeal against the decision to exempt any part of your request, you should
request an Internal Review at [3][Merton Borough Council request email] or write in to Freedom
of Information team, Merton Council, Civic Centre, Morden, SM4 5DX.
If you escalate to the Information Commissioners Office (ICO) without
following the council’s internal review process, the ICO will refer you
back to the council to enable the correct process to be followed.
You can also appeal to the Information Commissioner at:
[4]https://ico.org.uk/make-a-complaint/offi...
There is no charge for making an appeal.
Yours sincerely
Barry Causer
Public Health Lead for Adults, Health Improvement and Health Protection.
London Borough of Merton
3^rd Floor, Merton Civic Centre
London Road
Morden
Surrey
SM4 5DX
020 8545 4833
07540 312 948
══════════════════════════════════════════════════════════════════════════
Please help to reduce waste and do not print this message unless you
really need to.
This message, including any attached files, is intended just for the use
of the individual or organisation to whom it is addressed. Unauthorised
use (for example disclosure, storage or copying) is not permitted. If you
are not the intended recipient please destroy all copies and inform the
sender by return email. Any views or opinions expressed in email are
solely those of the author and do not necessarily represent those of
Merton Council. Merton Council reserves the right to monitor, record and
retain any incoming and outgoing emails for security reasons and for
monitoring internal compliance with the Merton Council policy on staff
use. Email monitoring and/or blocking software may be used and email
content may be read. Merton Council may be required to disclose this email
(or any response to it) under the Freedom of Information Act 2000 unless
the information in it is covered by one of the exemptions in the Act. The
message may contain information that is confidential or sensitive; you
should handle it accordingly.
Please view the council's privacy notice at
https://www.merton.gov.uk/legal/privacy-...
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References
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2. mailto:[email address]
3. mailto:[Merton Borough Council request email]
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