Privacy Notice for the Prevent Duty

Components

This Privacy Notice explains who we are, what personal data we hold, how and why we use your personal data, our lawful bases for processing, who we share your personal data with, relevant retention periods and how you can exercise your privacy rights in respect of the Prevent duty.

Please do read this notice to understand our practices and if you have any questions contact us using the details provided. Further details can be found on MMU’s Prevent Duty internet page.

Background

Manchester Metropolitan must adhere to Section 26 of the Counter Terrorism and Security Act 2015 (CTSA 2015), which places a statutory Prevent duty on specified authorities in the exercise of their functions, to have ‘due regard to the need to prevent people from being drawn into terrorism’. More information on the Prevent duty can be found on the Government’s Prevent duty guidance pages.

The Prevent programme is part of the Government’s counter-terrorism strategy, CONTEST. Its aim is to prevent people from becoming terrorists or supporting terrorism. It is designed to ensure that individuals who are identified as being at risk of being drawn into terrorism are given appropriate advice and support so that they may turn away from radicalisation. Under the Prevent duty Manchester Metropolitan will raise concerns with appropriate agencies where they believe that an individual is at risk of, or is being, radicalised.

Channel is a multi-agency programme which identifies and supports at-risk individuals, and which delivers this strategic aim of Prevent. A referral that Manchester Metropolitan make through Prevent may result in the Channel process being actioned by the Police or another agency. Having identified an individual at risk, the Channel process will see that the nature and extent of that risk is appropriately assessed, and subsequently, the most appropriate support plan will be developed for the individual concerned. This may involve mentoring, counselling and assistance with education, employment & training. 

The information we share

The categories of information that Manchester Metropolitan collect, process, hold and share under Prevent include:

  • Name
  • Date of Birth
  • Contact details (including address, email address and telephone number)
  • Gender
  • Nationality and citizenship
  • Immigration/ Asylum Status
  • Emergency Contact details,
  • Further family details (such as family makeup and who you live with)

We will also share other type of descriptive personal information if we deem it relevant, such as:

  • Details of our concerns about you
  • Background information about financial or housing issues
  • Educational or work issues
  • Disability and medical background
  • Copies of your University assignments and assessments
  • Details and outcomes of University disciplinary procedures
  • Whether you have accessed Counselling, Wellbeing or Mental Health services
  • Information about your on campus web history
  • Details of any previous support, which is provided by Further Education providers

Some of the categories outlined above are considered to be ‘special category personal data’ under the data protection legislation; Information about race, ethnicity, political views, religion, health, sex life or sexual orientation is special category information.

Why we collect and hold this information

We use this personal data in order to:

  • Ensure you are safeguarded from harm and being drawn into terrorism.
  • Fulfil our legal obligation for the delivery of Prevent duties which are set out in Section 26 of the Counter-Terrorism and Security Act 2015 (CTSA).
  • Evaluate and improve Manchester Metropolitan’s processes under Prevent.
  • Identify local trends and patterns to inform future practice and support.

Who we share with

We share information with the following agencies:

  • Further Education Colleges, the Department for Education and Manchester Metropolitan University Students’ Union- This may include details of previous support offered to you previously, or specific safeguarding requirements they think we need to know about
  • Manchester local authority- Including metal health support agencies and social services.
  • The Channel programme.
  • Greater Manchester Police and Counter Terrorism Policing North West

The above information sharing may result in the offer of support from the local authority, or through the Channel programme. The Police will be involved where there is suspected criminal activity, or a perceived risk of criminal activity occurring.

The lawful basis on which we use this information

The processing of personal data for the Prevent duty is necessary to meet our legal obligation as set out in Section 26 of the Counter Terrorism and Security Act 2015. This legislation places a statutory duty on specified authorities in the exercise of their functions, to have ‘due regard to the need to prevent people from being drawn into terrorism’. The appropriate lawful basis under the GDPR is Article 6(1)c – Legal obligation.

Where Manchester Metropolitan share special category data, we rely on Article 9(2)g – substantial public interest, on the basis of Union or Member State Law (i.e. the Prevent duty).

Will we inform you of any data sharing we conduct?

Under Prevent, we do not need consent from the individual to share information with the above mentioned agencies and organisations. However, we will always consider informing individuals where we make a referral. Please be aware that this may not be possible depending on the nature of our concern and in particular if we reasonably believe that informing the individual may jeopardise the purpose of referral. 

Storing the information

Manchester Metropolitan will hold this information about you for 20 years (6 years after the closure of the case the full prevent record will be reduced to a summary prevent record and all other information relating to the case will be destroyed).

Data subject rights and where to find out more

If you have any queries about this privacy notice or about the Prevent obligation, please contact [email protected].

For further information about how Manchester Metropolitan process your personal data and how to contact our data protection officer or raise a complaint, please visit our Data Protection pages. Further information about your data subject rights can be found here.