Child licensing and employment privacy notice

Purpose for processing your information

The Child employment and licensing officers sits within the Admissions and Access to Education Service. The purpose is to fulfil the statutory requirement of the issue of child licenses in Entertainment for children and young people from  birth up until the June of the year they turn the age of 16; and the issue of part-time work permit for children and  young people from the age of 13 up until the June of the year they turn the age of 16.

We collect the following information

Information we request from you is for the purpose of processing child licenses, employment permits and chaperone licenses. These are:

• full name of your child or chaperone
• date of birth
• home address
• parent or carers full name
• address
• your contact details including phone numbers and email address
• current education provision
• professional supporting documents and references of chaperones

This information is only used for the intended purpose but if we intend to use it for any other purpose; we will normally ask you first. In some cases, the council may use your information for another purpose if it has a legal duty to do so, to provide a complete service to you, to prevent and detect fraud, or if there is a risk of serious harm or threat to life.

How we collect your information

The initial application for a child licenses, work permits and chaperone licenses can either be submitted via email or a hard copy paper. Additional information will be requested by face-to-face.

Who the information is shared with

The child employment and licensing officer may also use your information for other legitimate purposes and may share (where necessary) with other Council departments and external bodies responsible for administering services to children and young people. Reasons for sharing information with the internal and external bodies will be; to enable the processing of child licences for entertainment and employment, to fulfil the council’s safeguarding duty and comply with the Prevent Strategy, the Home Office to notify of potential illegal immigration and the Police may request information at any time as part of a criminal investigation.

Internal bodies are:

• Admissions and Access to Education that covers Children Missing Education (CME)
• Elective Home Education (EHE) and Exclusions
• the Data Team
• the Early Help Service
• the MASH Team and Safeguarding service
• the Early Years’ Service
• Governance and Legal Services

External bodies are:

• schools/academies
• venue/theatres
• child’s own agency
• chaperone referees
• place of business for work permits
• other councils and the police
• The Home Office and the Department of Work and Pensions

For the purpose of validating proof of address, the child employment and licensing team will refer to data held by any of the services mentioned above, internal Council Tax records, the Housing Team, Parking Services and the Fraud Team.

How long do we keep your information?

The child employment and licensing officers will keep your licensing documents for 1 year. Chaperone applications/documents will be kept for 4 years. After this time, it will be deleted.

How is your information retained?

Article 6 (1) of the UK GDPR states that processing shall be lawful only if and to the extent that at least one of the following applies. The Act lists 6 lawful basis. In this instance, the council asserts that it is processing data under 6 (1)( e) “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller”. In line with the ICO, the term Public Task to signify, reference is made to Article 6 (1)(e ).

The public task for is  to fulfil the statutory requirement of the issue of child licenses in Entertainment for children and young people.

The above establishes that the council has both a public interest task and duty to respond to EHE Assessments. Processing (including documenting) assessments takes place under the Public Task basis. The data protection regulator, Information Commissioner’s Office [ICO] notes that a specific power is not needed to establish the Public Task lawful basis. Please note, under the Public Task basis, the right to erasure is set aside. The right to object remains, but the right to rectification will only apply to factual content, rather than a difference of opinion. The council may consider accepting addendums to be placed on records where there is a dispute based on opinion, but this will be on a case by case basis.

In addition, the council has other duties associated with maintaining adequate records of its transactions (activities, correspondence) as set out under the Local Government Act 1972 section 224. Specifically, evidencing its transactions, requires considering the integrity of those records. The council is also subject to the Code of Practice on the Management of Records issued under section 46 of the Freedom of Information Act 2000. Included in the Code is the requirement to adhere to “three principles of value, integrity and accountability… to manage information and maintain a record of their (Public Authorities) activities”. When viewed together the council must be able to maintain records of its transactions as they happened.

Your rights and access to your information

You have the right to request a copy of the information that we hold about you. 

The new General Data Protection Regulation also gives you additional rights about the information we hold about you and how we use it, including the right to:

• Withdraw consent and the right to object and restrict further processing of your data; however, this may affect service delivery to you.
• Request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.
• Request your data to be rectified if it is inaccurate or incomplete
• Have your data transferred or copied should you move to another authority
• Not be subject to automated decision-making including profiling

To submit a Subject Access Request email the child employment and licensing officer at [email protected]  or [email protected]

If you have any concerns

Please contact us if you would like to know more about the information we hold about you and how we use it.  The child employment and licensing officer contacted on telephone 0202 7745 6641 (RBKC) or 0207 745 6612 (Westminster) between 9am and 5pm, Monday to Friday.

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information; please visit email the child employment and licensing Team at: [email protected] or [email protected]

Your concerns will be investigated via the respective council’s complaints procedures. 

If you are not satisfied with the council’s response you have a right to complain to the Information Commissioner’s Office (ICO). Visit the ICO website.

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.