Dear North Lanarkshire Council,

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)

I note that a number of local authorities, including Prevent priority areas, have proactively made public their Information Sharing Agreements and Data Protection Impact Assessments that are attached to Prevent and Channel programmes.

This includes Hampshire County Council, which has released its Information Sharing Agreement; Lincolnshire Police, which has released multiple Information Sharing Agreements signed between itself and public bodies in Lincolnshire; Camden Borough Council, which has released its Data Protection Impact Assessment, and Blackburn and Darwen, which has released its Memorandum of Understanding. London Multi-Agency Data Sharing Agreement for Safeguarding and Promoting the Welfare of Children is also publicly available.

I also note that the Metropolitan Police has made public its National Prevent Referral Form, and has also released the document CTP-Prevent Policy 2020 on using the Prevent Case Management database, which includes information on input, referral, liaison with FIMU. According to this document, Dovetail sites are responsible for updating the Channel Management Information System. This document already places in the public domain the majority of processes for data sharing, including the use of Fixed Intelligence Management Units, the use of the Dynamic Investigation Framework for assessing cases, and the Intelligence Cycle.

Thus there should be little in this request that is not already in the public domain in some form.

I look forward to your reply.

Sam Andrews

Dear Neil McKay,

Thanks for your reply. No problem on being late - indeed this was for an English county, so sorry for taking up your time.

Yours sincerely,

Sam Andrews