Data Protection FAQS

Q1. What type of individuals do you collect data about?

We collect data for two separate groups of people: Members of the BCRP and alleged offenders.

Q2. What is the lawful basis for collecting the information?

For our Members the lawful basis is consent by virtue of the 'contract' that we have with them for their membership of the BCRP. For alleged offenders the lawful basis is 'legitimate interest' to protect our Members and their property from harm and to prevent crime and disorder. Look at the Privacy Notice [Offenders] at the bottom of the Exclusion Notice page.

Our Members give us consent by virtue of asking to be members of the scheme and completing an application form.

Offenders do not give consent but we collect their information on the basis of 'legitimate interest'.

Q4. What does 'legitimate interest' mean?

The BCRP has assessed the impact of its processing on offenders’ rights and freedoms, and has balanced this with its Members’ own rights, and has concluded that its Members’ rights prevail over offenders’ rights in this specific matter.

This means that the BCRP has a compelling reason to collect data without asking for permission to do so. For the BCRP it is to protect the property of our Members and their staff and customers from crime and anti-social behaviour. It is also to exclude from Members' premises any individuals who are proven threats to their property, staff or customers or disrupt the peaceful enjoyment that their customers expect from the goods and/or services that our Members offer.

The BCRP processes Offenders’ personal data for the management of its Exclusion Scheme [see Exclusion Scheme FAQs page] on behalf of its Members, to inform Members of an offender’s modus operandi, to collate intelligence on criminal activity within the area of the scheme’s operation and to contribute to legal proceedings against offenders where appropriate.

Wherever possible we also try to prevent people from being excluded by writing to them beforehand. For young people we also have a 'Putting it Right' scheme which may be suitable for some young people to try to stop them from offending at an early stage. We also have a separate policy on processing the personal data of children with additional safeguards in place.

Q5. What specific data do you collect about members of the BCRP?

A contact name, the name of the company, the company's address, email address and telephone number.

Q6. What specific information do you collect about alleged offenders?

Name, date of birth, address [if possible] and other contact details, distinguishing marks e.g. tattoos etc, a photographic image and CCTV film and details of any offences against our members. We collect offender's addresses so we can write to them to explain what information we have and what we intend to do with it. But we do not share the address with anyone else. We may also collect data about conditions attached to bail or court mandated santions e.g. Community Protection Notices and Criminal Behaviour Orders.

The information on our Members is not shared with anyone.

Limited information about offenders - name, date of birth, distinguishing features, a photograph and a brief two or three word description of offences for whcih they are known - may be shared with our Members. Under a precedent set in the Judicial Review M v Chief Constable of Sussex we may also share offender's bail conditions with Members if breach of the same is likley to affect our Members. Everything we share with Members is on the strict understanding that they cannot be shared under any circumstances with third parties.

More detailed information about offences may be shared with statutory agencies e.g. police, Youth Offending Service. We do not share an offender's address with our Members. Although we have access to this information it does not belong to us [it belongs to Sussex Police] and hence we do not have the right to share it.

Q8. Where can I get a full version of your Data Processing Documentation?

For a copy of our full Data Processing Documentation, please click here