Procedures

Privacy policy

 

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1. We recommend that you read this Privacy Notice in full to ensure that you are fully informed. However, if you only want to access a particular section of the Privacy Notice, then you can click on the relevant link above to jump to that section.

Introduction
2. The Daniel Morgan Independent Panel (“Panel”) is registered with the Information Commissioner’s Office as a controller in respect of all personal data held by the Panel. The Panel’s powers to act derive solely from its terms of reference as set out by the Secretary of State.

3. This Privacy Notice explains how the Panel collects, shares and uses personal information about you; and how you can exercise your privacy rights. This Privacy Notice applies to personal information that the Panel collects through its website at www.danielmorganpanel.independent.gov.uk (“website”), or that the Panel otherwise collects and uses for the purposes of completing its report into the circumstances surrounding the murder of Daniel Morgan, as further set out in our terms of reference (the “Report”).

4. If you have any questions or concerns about the Panel’s use of your personal information, then please contact the Panel using the contact details provided below.

Contact details

5. The Panel’s contact address is:

Daniel Morgan Independent Panel
2 Marsham Street
London SW1P 4DF

6. The Panel’s Data Protection Officer can be contacted via the e-mail address: [The email address is no longer live]

7. The Controller of your personal information is available using the following ICO registration number: ZA022890.

What personal information does the Panel collect and why?

A. Website Users

Information you provide voluntarily

8. If you contact us, we may keep a record of that correspondence. This will be kept confidential within the Panel and its team, except for the purposes set out in this Privacy Notice. We use this information to provide you with the content that you request from us or for the purposes of the Panel’s work in relation to the Report.
Information we collect automatically

9. When you visit our website, we may capture certain information automatically from your device. In some countries, this information may be considered personal information under applicable data protection laws.

10. Specifically, the information that we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

11. We also make use of Google Analytics to collect information including patterns of browsing behaviour to improve the content provided to you on this site. If you would like to prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on. Otherwise, we will assume you are content to continue using Google Analytics.

12. Collecting this information enables us to better understand the visitors who come to our Website, where they come from and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors (for example, to ensure that the content on our website is presented in the most effective manner for our visitors).

B. In relation to the Report

Information you provide voluntarily

13. If you agree to provide the Panel with information in an interview about the investigation into the murder of Daniel Morgan, we may keep a record/note of that interview. The note may include any information you give us, such as names, date of birth, address, statement of events, criminal records data, or sensitive information (such as information about health). This statement may be used for the purposes of compiling the Report.

Information that we obtain from third party sources

14. In order to conduct our review and compile the Report, we may receive a variety of personal information from third party sources (primarily government, or regulatory or enforcement bodies), such as: the Metropolitan Police Service, the Home Office, the Crown Prosecution Service, Hampshire Constabulary, the Independent Office for Police Conduct, the Coroners Court, the Attorney General’s Office, and the National Crime Agency. We will only accept this personal information where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose this information to us.

15. This information could include full name, date of birth, ethnic origin, addresses, contact details, national insurance number, or security clearance information. This information could also contain sensitive information (such as race, religious or philosophical beliefs, trade union membership, genetic or biometric data for the purpose of uniquely identifying individuals, health information, sexual orientation information or details of the sex life of an individual), or criminal records data (such as information about previous convictions).

16. We use this information to conduct our review into the handling of the murder of Daniel Morgan, as further permitted by our terms of reference. The sole purpose of the Panel is to review material relating to this incident in order to produce the Report, which will assess the background and handling of the Daniel Morgan murder investigation.

17. In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice, or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest) if and where this is permitted by applicable data protection laws.

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Who does the Panel share my personal information with?

18. We may disclose your personal information to the following categories of recipients:

• to our third party services providers, government partners and the National Archives, who provide data processing services for us (for example, who support the delivery of, provide functionality on, or help to enhance the security of our Website, or who help us compile the Report), or who otherwise process personal information for purposes that are described in this Privacy Notice (such as Epiq Systems Ltd) or notified to you when we collect your personal information;
• to any competent law enforcement body, regulatory, government agency, court or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to the general public, if we include your personal information within our final, published Report. If we intend to refer to you critically in the Report, we will notify you of this in advance in order to seek your feedback on how you will be portrayed before the Report is finalised;
• the family of Daniel Morgan in accordance with principle 5(d) of the Panel’s terms of reference; however only where such disclosure is permitted by applicable data protection law; and
• to any other person with your consent to the disclosure.

Legal basis for processing personal information

19. The Panel’s legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

20. However, we will normally collect personal information from you only (i) where the processing is in our legitimate interests and not overridden by your rights, (ii) where the processing is necessary for the performance of a task carried out in the public interest (i.e. compiling the Report), or (iii) where we have your consent to do so. In particular, the Panel relies on substantial public interest in connection with statutory and government purposes, the administration of justice and parliamentary purposes, preventing or detecting unlawful acts, protecting the public against dishonesty and regulatory requirements relating to unlawful acts and dishonesty (as applicable). In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

21. If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

22. If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to: (i) operate our Website; or (ii) communicate with you as necessary to respond to your queries. We may have other legitimate interests and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

23. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the Contact details heading above.

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How does the Panel keep my personal information secure?

24. We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

International data transfers

25. Our website servers are located in the United Kingdom. When we collect and use personal information for the purposes of the Report, our suppliers are located in the United Kingdom.

26. We do not currently transfer your personal information outside the United Kingdom, however if we ever need to do this, we will ensure that we do so in accordance with applicable data protection laws.

Storing your information

27. The Panel retains personal information it collects from you where we have an ongoing legitimate business need or public interest to do so (for example, to respond to your query or to prepare our Report).

28. When we have no ongoing legitimate business or public interest need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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Your data subject rights

29. In certain circumstances, you have the right to:

(a) request access to the personal information that we hold about you;
(b) object to and restrict the use of your personal information, or to ask to have your data deleted, or corrected;
(c) you may request portability of your personal information;
(d) where you have explicitly consented to the use of your personal data and that is the lawful basis for processing, you have the right to withdraw your consent to the processing of your data; and
(e) complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

30. If you would like to exercise any of your rights, please contact us using the contact details provided under the Contact details section above. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Children’s privacy protection

31. We understand the importance of protecting children’s privacy online. Our website is not designed for, or intentionally targeted at, children 13 years of age or younger. It is not our policy to intentionally collect or maintain data about anyone under the age of 13.

Updates to this Privacy Notice

32. We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update the Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

33. This Privacy Notice was last updated on 3 March 2020.

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