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Our Contact Details听

Email: honorarykc@justice.gov.uk听

The Ministry of Justice is committed to protecting the privacy of your personal information and that of anyone you nominate for the Honorary King鈥檚 Counsel awards. Under the Data Protection Act 2018, information relating to honours nominations is exempt from the requirements to issue a privacy notice or respond to data subject requests. However, we want you to understand what the Ministry of Justice is doing with the personal information that it collects as part of the awards process. The following information explains the basis for what we do.听

Who manages this process听

The Ministry of Justice administers the Honorary King鈥檚 Counsel award process and is the data controller for the personal data collected for it.听听

The information you submit will be processed by the Honorary King鈥檚 Counsel Secretariat at the Ministry of Justice.听

Why we store your personal information听

The Ministry of Justice collects and processes the personal information necessary to determine eligibility and suitability for the HonKC award. The lawful basis for processing your personal information is that it is necessary for the exercise of a function of the Crown - specifically, the conferral of an honour. We process special category data because it is necessary for reasons of substantial public interest (paragraph 6, Schedule 1, Data Protection Act 2018).听

We may also collect personal information in relation to any concerns about the integrity of the honours system, including where the honour may be reviewed or forfeited if the system is brought into disrepute.听

This privacy policy covers personal information collected for the purpose of:听

• Processing the nomination of the named nominee.
• Carrying out the relevant checks on nominees to meet our duty of probity and due diligence
• Confirming the relationship between nominators and/or supporters and the nominee.听
• Liaising with relevant third parties鈥攆or example, government departments, professional bodies, or regulators鈥攆or the purposes of validating nominations and/or determining eligibility
• Using recipient profiles to publicise the Honorary KC awards, where the recipient has consented to do so
• Contacting you or the nominee about matters related to the Honorary KC award, such as follow-up correspondence or invitations to related events
• Investigating complaints or forfeiture requests, which may include liaising with appropriate third parties

We will always ensure that your information is held confidentially and securely and accessed only by those involved in processing the nomination, correspondence or complaint. This will be done in accordance with all relevant data protection legislation, and in line with HM Government鈥檚 policy on retention and release.听

Please note that transmitting information over the internet is generally not completely secure, and the Ministry of Justice can鈥檛 guarantee the security of your data. Any data you transmit is at your own risk. The Ministry of Justice have procedures and security features in place to keep your data secure once we receive it.听

The type of personal information we collect听

We currently collect and process the following information:听

• Personal identifiers, contacts and characteristics (for example, name, date of birth and contact details)
• Personal data, including some special category data, which may include but not be limited to the following: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, data concerning a natural person鈥檚 sex life or sexual orientation; disability data; data concerning a nominee鈥檚 socio-economic background; and job details
• Some special category data is collected for one of two reasons. Diversity information such as ethnic origin or sexual orientation is collected and aggregated as part of the Ministry of Justice鈥檚 commitment to increasing representation from underrepresented groups amongst the award recipients
• Other information such as health and political beliefs are collected only if included in information provided to the Ministry of Justice and where relevant to an honours nomination (for example, health information might contextualise what kinds of service a nominee can give; political information might be relevant if the nominee were nominated for political service).听
• We may also collect data on past criminal convictions
• We may also collect data from relevant Government departments, agencies and other public sector bodies (for example, regulators) to obtain professional and other types of relevant information to ensure all professional and related information is accurate
• We use to collect data that tells us about how the service is used, including: your computer, phone or tablet鈥檚 IP address, the region or town where you are using your device, and the operating system and web browser you use. This information is not used to identify you personally

How do we collect it?

Most of the personal information we process is provided to us directly from one of the following sources:听

• From you when you contact or interact with us by telephone, email, post or through the online awards nomination form
• From forms we may ask you to complete, particularly if you make or support an awards nomination for someone else or if you are the recipient of an award
• From government departments, agencies, professional bodies or regulators who might provide advice concerning information held in scope about an award nominator, nominee and/or an award recipient, such as the Criminal Records Office
• From members of the selection panel who may have relevant knowledge of the nominees or nominators that should be considered in the decision-making
• From any publicly available sources

With whom do we share your information?听

We may share your data with and or obtain information from third parties; these are determined by relationships with government departments and agencies that carry out the objectives listed above.听

Your data or data you provide about a potential nominee may be shared with the Honorary King鈥檚 Counsel selection panel members, which includes senior representatives from across the legal sector, for the purpose of considering nominations and making recommendations for awards.听听

Your contact details may be shared with other public bodies to facilitate your attendance at an awards ceremony aimed at recipients, where you have expressed an interest.听

The MOJ uses third party organisations for its information technology needs. As such, your personal data will be stored and processed on IT infrastructure, some of which are supplied by third parties, meaning your data is shared with them.听

We鈥檒l never share your information with other organisations for marketing, market research or commercial purposes.听

How do we protect your data?听

We take the security of your data very seriously. We have internal policies and controls in place to ensure that your data is retained appropriately, and is not accessed except by our employees or authorised third parties in the proper performance of their duties.听

When we engage third parties to process personal data on our behalf, they do so, on the basis of written instructions, are under a duty of confidentiality, and are obliged to implement appropriate technical and organisational measures to ensure data security in line with the relevant legislation.听

How long do we keep it for?听

To protect your personal information, any data you enter as you progress through the online form is held temporarily and securely until you submit your nomination, after which your nomination cannot be viewed online or modified further.听听

Once the nomination is submitted, information will be retained for 20 years to support the administration of the awards process and fulfil our legal and recordkeeping responsibilities. After this period, most records will be securely deleted. However, where appropriate, selected records may occasionally be preserved permanently and transferred to The National Archives to maintain an historical record.听

How is it stored?听

The Ministry of Justice take data security very seriously and take every step to ensure that your data remains private and secure. Your personal data is stored in several ways:听

• In software systems and secure databases that are managed by the Ministry of Justice
• In paper files stored securely in office
• All the data received about you from third parties are stored on both ours and their systems electronically and in paper files

Your rights听

Unless an exemption applies (see below), you have the right to:听

• Request information about how your personal data is processed, and request a copy of that personal data
• Request that any inaccuracies in your personal data are rectified without delay
• Request that any incomplete personal data is completed, including by means of a supplementary statement
• Request that your personal data is erased if there is no longer a justification for them to be processed
• Request in certain circumstances (for example, where accuracy is contested) that the processing of your personal data is restricted
• Object to the processing of your personal data
• Object to automated decision making, including profiling, that has a legal or significant effect on you as an individual听

UK General Data Protection Regulation听

Under the data protection legislation in effect from 25 May 2018, information relating to honours nominations is exempt from certain GDPR requirements, including issuing a privacy notice or responding to data subject requests. However, this notice is being issued in respect of exempt activities in order to help you understand what the Ministry of Justice is doing with your information.听

Under the UK General Data Protection Regulation (UK GDPR), the lawful exemptions we rely on for processing this information are:听

(a) Personal data processed for the purposes of the conferring by the Crown of any honour or dignity听

Under paragraph 15 of Part 2 of Schedule 2 to the Data Protection Act 2018, the following requirements are disapplied where personal data is processed for the purposes of the conferring by the Crown of any honour or dignity:听

• The requirement under Articles 13 and 14 UK GDPR to issue privacy notices
• The requirement under Article 15 UK GDPR to respond to subject access requests听
• The requirement to comply with requests for rectification of data under Article 16 UK GDPR
• The requirement to comply with requests for erasure of data under Article 17 UK GDPR
• The requirement to comply with requests for restriction of processing of data under Article 18 UK GDPR
• The requirement to comply with requests for electronic data to be provided in an open electronic and machine-readable format under Article 20 UK GDPR
• The requirement to comply with objections to processing of data under Article 21 UK GDPR

Where the above exemptions apply, we are still subject to the following duties under data protection law:听

• To comply with the data protection principles, including the obligations that data is processed lawfully (under an identified legal base), that it is only collected for a specified purpose(s), that it is adequate and relevant to that purpose, that it is accurate and kept up to date where necessary, that it is only kept for as long as it is needed for that purpose (unless forming part of the historic record), that it is kept secure.听
• The requirement that data subjects should have the right not to be subject to automated decision making that produces legal or other significant effects on them
• To ensure that any contracts with data processors include Article 28 UK GDPR compliant clauses
• To produce and maintain records of personal data processing activity under Article 30 UK GDPR
• To notify the Information Commissioner in the event of a data breach (and possibly the data subject)
• To carry out a Data Protection Impact Assessment for high-risk processing activities

(b) Unstructured manual data relating to honours and dignities听

UK GDPR also extends to manual unstructured personal data processed by a public authority (as defined by the Freedom of Information Act 2000). But section 24 of the Data Protection Act 2018 provides a number of exemptions for manual unstructured personal data. These further exemptions apply to any honours personal data held in manual unstructured personal data.听听

How to seek further information or complain听

The data controller of your data is the Ministry of Justice. If you have any concerns about how your personal data are being handled, you may contact us:听

Email: honorarykc@justice.gov.uk听

Alternatively, the contact details for the Ministry of Justice鈥檚 Data Protection team are: DataProtection@justice.gov.uk听

You can also contact the Data Protection Officer, who provides independent advice and monitoring of Ministry of Justice鈥檚 use of personal information: dpo@justice.gov.uk听

You can also complain to the Information Commissioner if you are unhappy with how we have used your data. The Information Commissioner can be contacted at:听

Helpline number: 0303 123 1113听

Email: icocasework@ico.org.uk