PRIVACY NOTICE FOR VULNERABLE PERSONS
Updated April 2025
INTRODUCTION
Welcome to the Fleet Street Quarter Business Improvement District privacy notice for vulnerable persons.
The Fleet Street Quarter Business Improvement District respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after any personal data we collect from you or that you provide us with under “Data Protection Legislation”. It also tells you about your privacy rights and how the law protects you.
This privacy notice explains why we process the personal data of specific individuals (vulnerable persons) and the lawful basis for that processing. It describes the kind of information about them that we process and what we do with that information. ‘Vulnerable persons’ are individuals present within the public spaces of the Fleet Street Quarter Business Improvement District footprint whose personal safety and/or health is at risk. This might typically refer to missing persons or those sleeping and living on the streets.
“Data Protection Legislation” means all applicable legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the UK GDPR (the retained EU law version of the General Data Protection Regulation ((EU) 2016/679), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018); the Data Protection Act 2018 (and regulations made thereunder); and the Privacy and Electronic Communications Regulations 2003 as amended.
Our mandate is to work in partnership with businesses, the police and other stakeholders to keep all of those who live, work and visit the Fleet Street Quarter Business Improvement District area safe and free from harm. With regards to vulnerable persons this means providing them with access to relevant welfare support.
1.Important information and who we are
1.1 This privacy notice sets out the basis on which we will process any personal data we collect from you, or that you provide us with.
1.2 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. For the purpose of applicable data protection legislation, we are the data controller of the data that you provide to us, or we collect about you.
1.3 The Fleet Street Quarter Business Improvement District is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).
1.4 We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
1.5 Contact details
Full name of legal entity: Fleet Street Quarter Business Improvement District
ICO Registration Number: ZB173922
Email contact address: dataprotection@fleetstreetquarter.co.uk
Postal address: Unit 411, 160 Fleet Street, London EC4A 2DQ
2.Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3.Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4.Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
5.The data we collect about you
5.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
5.2 The personal data we collect includes but is not limited to: name, email address, postal address, telephone number, ethnicity (by way of an IC code description) and health conditions.
5.3 Some of the personal data we capture such as health conditions and ethnicity is considered special category data under Data Protection Legislation (UK GDPR and DPA 2108).
6.How is your personal data collected?
6.1 Our Patrol Team monitors the public places within the Fleet Street Quarter Business Improvement District area – engaging with any potentially vulnerable individuals and assisting them in accessing support services.
6.2 A “public place” is defined as any highway, premises or place to which at the material time the public have or are permitted to have access, whether on payment or otherwise.
6.3 You may provide your name, address, contact information, ethnicity and health conditions voluntarily when requested to do so by our Patrol Team.
6.4 Our Patrol Team may record your physical description - including your assumed ethnicity based on the ‘IC Code’ system. This physical description is to help outreach support services locate and identify you.
6.5 Your personal data may be shared with us by The Metropolitan Police and British Transport Police in line with respective Data Sharing Agreements where they deem your welfare is at risk and they require our assistance in locating you to provide support.
7.How we use your personal data
7.1 To inform local outreach support services (such as the police, City of London and specialist charities) of your presence and location in the Fleet Street Quarter Business Improvement District area so they can offer their assistance to you. Support provided by these third parties includes food, shelter, accommodation and healthcare.
7.2 To monitor the prevalence of vulnerable persons in the Fleet Street Quarter Business Improvement District footprint to assess whether measures to address the issue are proving effective.
8.Our lawful basis for processing
8.1 The Fleet Street Quarter Business Improvement District has been given a mandate by its levy-paying businesses to protect members of the public in the BID area and maintain their safety, health and welfare. As such we are relying on Article 6.1(f) of the GDPR, Legitimate Interests - “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.
8.2 Where special category data is collected, we are relying on Article 9.2(g) of the GDPR, Substantial Public Interest – “processing is necessary for reasons of substantial public interest, on the basis of Union or Members State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject.” In terms of meeting the conditions for substantial public interest, we rely on paragraph 18 of Schedule 1 of the DPA 2018, “safeguarding of children and individuals at risk”.
8.3 To support our lawful basis of processing under Art 6.1(f) we have conducted a Legitimate Interests Assessment (LIA).
8.4 To support our lawful basis for processing under Article 9.2(g) we have conducted and Data Protection Impact Assessment.
9.Change of purpose
9.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
9.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
9.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
10.Disclosures of your personal data
10.1 We only disclose your personal data to third parties for the purposes set out in paragraph 7. We require all third parties to respect the security of your personal data, to treat it in accordance with the law and only process it in accordance with our instructions.
11.Data security
11.1 We have put in place appropriate security measures (encrypted storage and access controls) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and will do so in accordance with all relevant legislation.
11.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12.Data retention
12.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
12.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
12.3 Details of retention periods for different aspects of your personal data are available on request by contacting us.
12.4 In some circumstances you can ask us to delete your data: see Request erasure below for further information.
12.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
13.Your legal rights
13.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.
13.1. 1Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
13.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
13.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
13.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
13.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
13.1.6 Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided with your consent for us to use or where we used the information to carry out a contract with you.
13.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
13.1.8 If you wish to exercise any of the rights set out above, please contact us via email or in writing at the office address highlighted in section 1.5 of this document.
13.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
13.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
13.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.