Appointee and Deputyship Service privacy notice
Who we are
Slough Borough Council (“the Council”) is the data controller for information we process to deliver the Appointee and Deputyship Service.
Address:
25 Observatory House
Windsor Road
Slough
SL1 2EL.
Email: Data Protection Officer (DPO): DataProtectionOfficer@slough.gov.uk
What this notice covers
This notice explains what personal information we collect, why we use it, who we share it with, how long we keep it, and your rights.
What information we collect depending on your case
- Identification and contact details: name, title, date of birth, address/postcode, email, telephone, National Insurance number, nationality and length of time in the UK.
- Financial details: income, benefits, pensions, bank/building society accounts, assets and liabilities, property ownership and valuations, utility/bill information.
- Household and relationships: details of relatives, friends and other contacts involved in your affairs.
- Legal and administrative records: Court of Protection orders/applications, appointeeship records, wills (where provided), correspondence and case notes.
- Special category data: health/medical information relevant to mental capacity and support needs.
- Criminal offence/fraud data (where relevant): information used to prevent/detect fraud or other unlawful acts.
How we collect your information
- Directly from you: referral forms, evidence you provide, email, telephone or face-to-face contact.
- From someone acting for you: a relative, friend, advocate or professional with authority to act.
- From other organisations when necessary and proportionate to deliver the service: Social Services/Adult Social Care, NHS teams, housing services, other local authorities, the Department for Work and Pensions (DWP), Office of the Public Guardian (OPG), banks/building societies and utility providers.
Why we use your information (purpose)
- Apply to the Court of Protection to be appointed as Deputy (property and affairs) and, once appointed, to manage your financial affairs (including operating accounts and, where necessary, selling property).
- Apply to the DWP to act as your Appointee and manage state benefits on your behalf.
- Safeguard your interests, prevent and detect fraud, protect public funds and meet our statutory obligations.
- Keep accurate records, report and audit our activities, and improve the service.
Lawful bases for using your information
Under the UK GDPR we rely on:
- Article 6(1)(e) public task – performing our functions under the Mental Capacity Act 2005, Court of Protection Rules/Practice Directions 2017, and related legislation.
- Article 6(1)(c) legal obligation – complying with laws that require processing (e.g., financial administration, fraud prevention, record-keeping).
- Article 6(1)(d) vital interests – where necessary to protect life.
For special category data (e.g., health/mental capacity):
- Article 9(2)(g) substantial public interest, with DPA 2018 Schedule 1 conditions including (as applicable):
- para 6 statutory and government purposes;
- para 10/11 preventing/detecting unlawful acts / protecting the public against dishonesty;
- para 16 support for individuals with a particular disability or medical condition;
- para 18 safeguarding of children and individuals at risk.
- in some cases, Article 9(2)(b) social security and social protection may also apply (e.g., DWP benefits management).
For criminal offence data (where processed):
- processed under DPA 2018 s.10 and the relevant Schedule 1 conditions (e.g., para 10/11).
We only rely on consent for optional activities (not for core deputyship/appointeeship functions). If we rely on consent, you can withdraw it at any time.
Who has access to your information
Access is limited to staff who need it to carry out their duties, including the Appointee and Deputyship Service and relevant Adult Social Care teams.
Who we share your information with (where necessary)
- Government/oversight bodies: Department for Work and Pensions (DWP), Office of the Public Guardian (OPG).
- Local partners: Adult Social Care, housing services, other councils (for continuity of support).
- Financial and legal: banks/building societies and other financial institutions, solicitors, auditors.
- Health and support: NHS teams, Community Mental Health Teams (CMHT).
- Fraud prevention/law enforcement: the Council’s fraud team, and law enforcement where legally justified.
- IT and service providers: our contracted providers may access data incidentally for technical support.
We will also disclose information if the law requires it or to protect someone’s vital interests.
International transfers
We do not routinely transfer your data outside the UK. If a transfer is necessary (for example, a supplier uses overseas support), we will ensure appropriate safeguards are in place (such as adequacy regulations or approved contractual clauses).
How long we keep your information
We keep your information for 1 year after the estate is settled or we stop acting for you, in line with the Council’s records retention schedule. After this, we securely delete or anonymise it.
Automated decision-making
We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
Your rights
You have rights to:
- access your data
- have inaccurate data corrected
- request erasure or restriction in certain circumstances
- object to processing (especially where we rely on public task)
- data portability (where applicable).
Some rights may be limited where we process data for legal obligations or our public tasks. You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.
How to contact us about your data
DPO: DataProtectionOfficer@slough.gov.uk
Service team: _appointeeship@slough.gov.uk
Post:
Appointee and Deputyship Service
Observatory House
25 Windsor Road
Slough
SL1 2EL
Keeping your data secure
We use technical and organisational measures to protect your information and limit access to those who need it.
Updates to this notice
We may update this notice from time to time and will publish the latest version on our website.