Your data: Managing Unreasonable behaviour by Complainants

 Data Protection and Privacy

Purpose of Data Collection

In managing unreasonable behaviour by complainants, the council may collect and process personal data to:

• Protect staff and service users.
• Maintain the integrity of complaints and service processes.
• Ensure fair and proportionate responses to persistent or disruptive behaviour.

This processing is carried out under the lawful basis of public task (Article 6(1)(e) UK GDPR) and, where applicable, legitimate interests (Article 6(1)(f)).

Types of Data Processed

The council may process:

• Contact details and correspondence history.
• Records of interactions and behavioural incidents.
• Internal assessments or decisions regarding restrictions.
• Special category data (e.g. health information) where relevant and necessary.

Where special category data is processed, this will be done under Article 9(2)(g) - substantial public interest, with appropriate safeguards in place.

 Transparency and Fairness

Complainants will be informed:

• When their behaviour is being assessed under this policy.
• Of any restrictions being applied and the reasons for them.
• Of their rights under data protection law, including how to access or challenge the data held.

This information will be provided via written communication and/or published privacy notices.

Data Minimisation and Retention

Only data that is necessary and proportionate to the management of the behaviour will be collected. Records will be:

• Reviewed regularly.
• Retained only for as long as necessary in line with the council's retention schedule.
• Deleted or anonymised when no longer required.

Security and Access

All personal data will be stored securely and access will be restricted to authorised staff involved in complaint handling, legal services, or safeguarding.

Rights of the Data Subject

Complainants have the right to:

• Access their personal data.
• Request rectification of inaccurate data.
• Object to processing, subject to legal and operational considerations.
• Lodge a complaint with the Information Commissioner's Office (ICO).