Thank you for contacting the FOI Team.

This is confirmation that we have received your email. You should receive
a further acknowledgment shortly with a reference number.

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The use of Brent Council's e-mail system may be monitored and
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and other lawful purposes.

[1]brentlogo1 (227×84)   Tel: 020 89371234
Email: [email address]
Web: [2]https://www.brent.gov.uk/your-council/

Dear Sam Andrews 

RE: Prevent/Channel data management 
Thank you for contacting the council on 22/03/2023.
Your case will be assigned to an officer and you should receive their
details soon.

Please use this reference number IRC-29309-V9R8T9 when contacting us about
this case.
Please note that we may require further information in order for us to
proceed, in which case we will contact you. 

If you would like further information on how your case will be dealt with,
please visit our website: [3]https://www.brent.gov.uk/your-council/ 
Yours sincerely 
London Borough of Brent

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The use of Brent Council's e-mail system may be monitored and
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and other lawful purposes.

References

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[1]brentlogo1 (227×84)   Tel: 020 8937 4225
Email: [email address]
Web: [2]https://www.brent.gov.uk/your-council/

Our Ref: IRC-29309-V9R8T9

Dear Sam Andrews

Freedom of Information Act 2000

Thank you for your information request received on 22/03/2023.

This request is being handled under the Freedom of Information Act 2000.

You requested the following information:

This is a request under the Freedom of Information Act.
 

According to the document CTP-Prevent Policy 2020, released publicly by
Counter Terrorism Policing, each local authority and police force should
enter into Data Sharing Agreements (DSA) with regards to Prevent and/or
Channel. According to legislation, DSA’s should be entered into after a
Data Protection Impact Assessment has been carried out. Any data
processing should be covered by a Data Processing Contract.Please release:

1: Any Data Sharing Agreement(s) made with regards to Prevent and/or
Channel.
2: Any Data Protection Impact Assessment done in relation to these Data
Sharing Agreement(s).
3: Any Data Processing Contract(s) relevant to the Data Sharing
Agreement(s).
4: A list of partners without Data Sharing Agreement(s) that you have
entered into a Memorandum of Understanding with for the purposes of
Prevent and/or Channel implementation.
5: Any information given to persons, or the guardians of said persons,
referred to Prevent and/or Channel, including any Privacy Notice.
Additionally, please answer the following questions:
6: Is the Data Sharing Agreement derived from the template Data Sharing
Agreement found on the Police CTNet?
7: Are any data relevant to Prevent and/or Channel shared outside of Data
Sharing Agreements, such as via Multi Agency Safeguarding Hub emails being
copied in to Police?
8: Do invitees to Channel or Police-Led Partnership Panels have to sign
Data Sharing or Confidentiality Agreements?
9: If YES to (8) please release a copy of this agreement.
10: Is any data relevant to Prevent stored outside of the Prevent Case
Management Database or Channel Management Information System?
11: If YES to (11) please list these databases.
12: Please indicate whether your area is a Prevent priority area (YES/NO)
13: Please indicate whether your area is a Dovetail area (YES/NO)
14: Please list all the persons consulted on the decision to release the
above information (only position and organization)
 

Brent Council holds the information you have requested, however I have
withheld some of this information on the basis that I consider that the
following exemption applies:

Under section 17(4) and in accordance with section 24 (National Security)
which provides that Information is exempt information if it is required
for the purpose of safeguarding national security; and section 31(a) (Law
enforcement) which provides that it is exempt information if its
disclosure under this Act would, or would be likely to, prejudice the
prevention or detection of crime, we neither confirm nor deny whether
Brent holds the information requested.
S24(2) and s31(a) of the Freedom of Information Act 2000 are qualifying
exemptions and subject to the public interest test. This requires
consideration of whether the public interest favours maintaining the
exemption or disclosing the information

1: Any Data Sharing Agreement(s) made with regards to Prevent and/or
Channel.

2: Any Data Protection Impact Assessment done in relation to these Data
Sharing Agreement(s).

3: Any Data Processing Contract(s) relevant to the Data Sharing
Agreement(s).
 

Answer 1,2,3: In response to questions 1,2 and 3 please refer to
paragraphs A, B and C below.

Factors in favour of disclosure

1. There is always a general public interest in openness and transparency
in local government affairs and spending of public money.
2. By enhancing openness, it helps the public understand the threat to
security posed by terrorism and extremism.

Factors against disclosure

I am of the view the public interest test remains in favour of maintaining
the exemption for the factors set out below.
 

 A. As part of wider CT efforts, the Government employs a range of
programmes to safeguard susceptible individuals and the public.  The
nature of these programmes means that there is sometimes limited
information about them in the public domain.  Data protection
documents contain detailed descriptions of the purposes for which
information is being stored and used.  Disclosing detailed operational
information about certain intervention programmes, including
information contained in data protection documents, would provide
detailed information on how they operate and could undermine their
effectiveness.
 B. This information could be used by individuals or groups to devise
counter strategies to these programmes, weakening their effectiveness
and expose susceptible individuals to a greater risk of being drawn
into terrorism.  If more people are drawn into terrorism this would
increase the national security threat to the UK.  There is a serious
terrorism threat to the United Kingdom and the Information
Commissioner recognises that terrorists are highly motivated and will
go to great lengths to achieve their goals.
 C. Some local authorities may see fit to disclose this information, but
the fact that other public authorities choose to disclose this
information does not set a precedent for every public authority to do
the same.  Each request and response must be considered individually,
and the risks identified by the Council in this case do not change
simply because another Council has taken a different approach.

It is considered that the greater public interest therefore lies in not
providing the information at this time. In coming to that conclusion, the
public interest in providing the information has been carefully weighed
against any prejudice to the public interest that might arise from
withholding the information; in all the circumstances of the case, the
public interest in maintaining the exemption outweighs the public interest
in disclosing the information.
 
This part of your request constitutes a refusal notice under Section 17 of
the Freedom of Information Act.
 
4: A list of partners without Data Sharing Agreement(s) that you have
entered into a Memorandum of Understanding with for the purposes of
Prevent and/or Channel implementation.

Answer 4: Please refer above to paragraphs A and B in the interest of
national security.

5: Any information given to persons, or the guardians of said persons,
referred to Prevent and/or Channel, including any Privacy Notice.
 
Answer 5: Please refer to London Borough of Brent Council’s Channel Panel
Privacy notice, (link below).
[3]Channel Panel Privacy Notice | Brent Council

6: Is the Data Sharing Agreement derived from the template Data Sharing
Agreement found on the Police CTNet?
 
Answer 6: Your question relates to an internal Police based system, please
direct this query to the Metropolitan Police.

7: Are any data relevant to Prevent and/or Channel shared outside of Data
Sharing Agreements, such as via Multi Agency Safeguarding Hub emails being
copied in to Police?
 
Answer 7: We do not foresee any information being shared outside the data
sharing agreement or that is not in line with wider statutory
responsibilities

8: Do invitees to Channel or Police-Led Partnership Panels have to sign
Data Sharing or Confidentiality Agreements?
 
Answer 8: Yes

9: If YES to (8) please release a copy of this agreement.
 
Answer 9: Please refer to above paragraphs A, B and C

10: Is any data relevant to Prevent stored outside of the Prevent Case
Management Database or Channel Management Information System?
 
Answer 10: Yes
 
11: If YES to (11) please list these databases.
 
Answer 11: Secure Brent Mosaic System

12: Please indicate whether your area is a Prevent priority area
 
Answer 12: YES

13: Please indicate whether your area is a Dovetail area
 
Answer 13: NO

14: Please list all the persons consulted on the decision to release the
above information (only position and organization)
 
Answer 14: We withhold this information due to the following exemptions
stated below, please refer to sections 40 Personal Information and Section
38 Health and Safety.
Section 40 – Personal Information
This exempts personal data if disclosure would contravene any of the data
protection principles in Article 5(1) of the General Data Protection
Regulation and section 34(1) of the Data Protection Act 2018.  By
disclosing two identifiers (organisation and position within it) any
individuals who have been consulted could be identified.  This exempts
personal data being shared if disclosure would contravene any of the data
protection principles in Schedule 1 to the DPA. Section 40(2) is an
absolute exemption, which does not require a public interest test.

The information is exempt from disclosure under Section 38(1) of the
Freedom of Information Act (FoIA). Disclosure of this information would be
likely to endanger an individual (this could be the applicant, the
supplier of the information or anyone else).

To use this exemption we are required to undertake a public interest test.
The matters which were considered in applying the public interest test are
as follows:

Factors in favour of disclosure
1. There is always a general public interest in openness and transparency
in local government affairs and spending of public money.
2. By enhancing openness, it helps the public understand the threat to
security posed by terrorism and extremism.

Factors in favour of withholding
 
Prevent is part of the Government’s Counter Terrorism Strategy and those
involved with it are engaged in reducing the terrorist threat to the UK.
 There is a risk that individuals or groups seeking to undermine the UK’s
counter terror strategy could target people who were consulted in
answering this FOI as anyone who is consulted would have some
responsibility for delivering Prevent.  An additional concern is that if
individuals know that they could potentially be identified by information
released via FOI this would negatively impact their mental wellbeing.

It is considered that the greater public interest therefore lies in not
providing the information at this time. In coming to that conclusion, the
public interest in providing the information has been carefully weighed
against any prejudice to the public interest that might arise from
withholding the information; in all the circumstances of the case, the
public interest in maintaining the exemption outweighs the public interest
in disclosing the information.

This part of your request constitutes a refusal notice under Section 17 of
the Freedom of Information Act.

If you are dissatisfied with the way in which your request has been
handled or the outcome, you may request an internal review within two
calendar months of the date of this response by writing to the following
address:

Freedom of Information

Brent Civic Centre Engineers Way Wembley

HA9 0FJ

[4][email address]

If you remain dissatisfied with the handling of your request or internal
review, you have a right to appeal directly to the Information
Commissioner for a decision. The Information Commissioner can be
contacted at:

The Information Commissioner's Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF. Phone: 0303 123 1113

Website: [5]www.ico.org.uk

I will now close your request as of this date.

Yours sincerely
 

Kibibi Octave
Head of Community Safety and Prevention

══════════════════════════════════════════════════════════════════════════

The use of Brent Council's e-mail system may be monitored and
communications read in order to secure effective operation of the system
and other lawful purposes.

References

Visible links
2. https://www.brent.gov.uk/your-council/
3. https://www.brent.gov.uk/the-council-and...
4. mailto:[email address]
5. http://www.ico.org.uk/