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Privacy Notice

This document describes the Portsmouth Business Crime Reduction Partnership (PBCRP/the Scheme), explains why the Scheme processes the personal data of specific individuals (Offenders) and the lawful basis for that processing. It describes the kind of information about Offenders that the Scheme processes and what it does with that information.

Contact details
Portsmouth Business Crime Reduction Partnership
PO Box 983
Portsmouth
PO1 9PH

Mobile: 07908 157 597
Telephone: 023 9229 6012

Email: crime.manager@pbcrp.com 

The Scheme’s Data Controller is responsible for ensuring its compliance with current Data Protection law and can be contacted at the above address, email address or telephone number. The Scheme is registered with the Information Commissioners Office as a Business Crime Reduction Partnership.

Purpose of processing personal data

Members of the Scheme have the right to protect their property, staff and customers from crime and anti-social behaviour and to exclude from their premises any individuals who are proven threats to their property, staff or customers. The Scheme processes Offenders’ personal data for the specific purpose of managing its Exclusion Scheme on behalf of its Members.

The Scheme’s area of operation, and its Exclusion Scheme, extends across Portsmouth and surrounding areas

Types of processing

The Scheme undertakes the following types of processing of personal data of Offenders:



Lawful basis of processing

The Scheme’s Members’ ‘legitimate interests’ provides the lawful basis on which it may process specific items of Offenders’ personal data for specific purposes without Offenders’ consent.

The Scheme has assessed the impact of its processing on Offenders’ rights and freedoms, has balanced these with its Members’ own rights, and has concluded that its Members’ rights prevail over Offenders’ rights in this specific matter. Therefore, for the specific purpose of managing an exclusion scheme, Members’ legitimate interests constitute the Scheme’s lawful basis for processing Offenders’ personal data without requiring consent.

Categories and types of personal data processed



Sources of personal data

Offenders’ personal data may be provided to the Scheme by:

Recipients, or categories of recipients, of personal data

The following types of individuals may have access to the Scheme’s data, including Offenders’ personal data:



The Scheme will not transfer Offenders’ data outside the UK.

Data retention period

When an Offender is reported by a Member for participating in any threat or damage to any Member’s property, staff or customers, his/her name and facial image may be shared among Members for 12 months. If no further report is submitted during that period, the Offender’s data will be withdrawn from Members at the expiry of that period. It will be retained for a further 12 months in the Scheme’s database (which can only be accessed by the Data Controller) after which time it will be irrevocably deleted.

If during the 12 months when an Offender’s data is circulated among Members he/she is reported for another incident involving a threat or damage to any Member’s property, staff or customers, his/her name and facial image will be circulated among Members for a further 12 months from the date of the second report. Additionally, the Offender will be excluded from all the properties of all Members for 12 months, and this fact will be shared with Members. If no further report is submitted by a Member during that period, the Offender’s data will be withdrawn from Members at the expiry of that period. It will be retained for a further 12 months in the Scheme’s database (which can only be accessed by the Data Controller) after which it will be irrevocably deleted.

Offenders’ rights

Every Offenders has the right to obtain a copy of all the personal data which the Scheme holds about him or her; to do so the Offender must contact the Data Controller (see contact details above); the Offender may be required to provide proof of his/her identity. In any case the Scheme will respond to the request within 30 days and provide full documentation to demonstrate compliance with Data Protection law.

If, when an Offender accesses his/her personal data, any of it is found to be incorrect, unnecessary or disproportionate, the Offender can require the Scheme to correct it. Offenders do not have the right to require the Scheme to delete correct, necessary or proportionate information.

Offenders have the right to complain about the Scheme to the Information Commissioners Office; Offenders can submit a complaint on the ICO’s website at https://ico.org.uk/concerns/handling/