Guidance

Privacy information relating to honours nominations

Updated 7 December 2021

Our Contact Details

Honours and Appointments Secretariat
1 Horse Guards Road
Room G39
London
SW1A 2HQ

Telephone: 0207 276 2777

Email: honours@cabinetoffice.gov.uk

Why we store your personal information

Our lawful basis for processing of your personal details is that it is necessary to carry out the exercise of the honours function for the Crown. We process special category data because it is necessary to do so for reasons of substantial public interest (para 6, schedule 1, Data Protection Act 2018).

The Cabinet Office collects the personal information necessary to process honours and gallantry nominations with the purpose of making a determination of eligibility and suitability for an award. We also collect personal information necessary to process cases of potential honours forfeiture, should the system be brought into disrepute.

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

• 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 nominator and/or supporters and the nominee
• using data to liaise with relevant third-parties, for example, government departments and Lord-Lieutenants, for the purposes of validating nominations
• making offers of awards, and sending congratulations letters, to honours and gallantry recipients
• using recipient profiles for publicity of honours/gallantry lists or outreach on the honours system, where the recipient has consented to do so
• investigating complaints or forfeiture requests which may include liaising with relevant third parties
• contacting you about matters related to honours, such as invitations offered to honours recipients

We will always ensure that your information is held confidentially and accessed only by those people involved in processing the nomination, correspondence or complaint. This will be undertaken in compliance with all the relevant laws and regulations on data protection; including HM Government’s policy on retention and release.

The type of personal information we collect

We currently collect and process the following information:

• 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’s sex life or sexual orientation; disability data; data concerning a nominee’s 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 Cabinet Office’s commitment to ensuring honours lists recognise all groups in UK society.
• Other information such as health and political beliefs are collected only if included in information provided to the Cabinet Office and where directly 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).
• We may also collect data on past criminal convictions and may ask His Majesty’s Revenue and Customs (HMRC) to advise about any potential risk posed to the government and the Crown by honours candidates in respect of their tax affairs by reference to a low, medium or high rating.
• We may also collect data from relevant Government departments and agencies and other public sector bodies like regulators to obtain professional and other types of relevant information to ensure all professional and related information is accurate.
• When you visit our website, or interact with us via social media channels, we will collect your IP address and browsing preferences and choices.
• Personal data provided for promotional videos that share the experiences of those who have been awarded honours. We will ask you to sign a consent form in such cases.

How do we collect it?

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

• From you when you contact or interact with us by telephone, email, post or through the online honours nomination form;
• From forms we may ask you to complete, particularly if you make or support an honours or gallantry nomination for someone else or if you are the recipient of an honour, medal or other award;
• From government departments or agencies who might provide advice concerning information held in scope about an honours nominator, nominee and/or an honours or gallantry recipient, such as HMRC or the Criminal Records Office;
• From a third party who may contact us, or who we may contact, on an individual’s behalf. This could include friends, family, employers, government departments and agencies, and international organisations or governments. In such cases, information shared will be the minimum necessary to undertake the purpose;
• Where you feature in a promotional video, we will process the following personal data: video, name, honour received, and any other information you volunteer in the video;
• From a Lieutenancy local to the nominee for purposes including, but not limited to, confirming the accuracy of an honours nomination, seeking information about an individual or allowing the Lord-Lieutenant to carry out their role as a representative of HM The King (for example, in congratulating recipients or presenting awards); or
• From any publicly available sources.

With whom do we share your information?

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

Your data or data you provide about a potential nominee may be shared with the members and chairs of the ten independent honours committees; the Royal Household or the George Cross Committee for the purpose of considering nominations and making recommendations for awards. Similarly, any complaint about the recipient of an honour may be shared with the Honours Forfeiture Committee.

In respect to promotional videos, your personal data will be shared by us publicly on YouTube and at https://honours.cabinetoffice.gov.uk/.

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

As your personal data will be stored on our IT infrastructure it will also be shared with our data processors who provide web hosting, email, and document management and storage services.

How do we protect your data?

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.

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 the security of data in line with the relevant legislation.

How long do we keep it for?

Information relating to honours nominations may be retained for 30 years and a record will be maintained in perpetuity of those nominees who receive an honour for the purposes of maintaining the records of the honours system. Any tax affairs ratings supplied to us by HMRC are deleted within 12 months as per our Memorandum of Understanding with the organisation. All promotional video personal data will be reviewed by us every 5 years to ensure it is still timely and relevant.

How is it stored?

Your personal data is stored in a number of ways:

• In paper files stored securely in office or in a recognised external facility, for example, the National Archives
• In software systems and data banks that are managed by the Honours and Appointments Secretariat – overseen by Cabinet Office Data Handlers
• All the data received about you from third-parties are stored on both ours and theirs [third-parties] systems electronically and in paper files

Your rights

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

• request information about how your personal data is processed, and to 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) to request that the processing of your personal data is restricted

• object to the processing of your personal data

UK General Data Protection Regulation

Under the data protection legislation in effect from 25 May 2018, information relating to honours nominations is exempt from the requirement to issue a privacy notice, or to respond to data subject requests. However, this notice is being issued in respect of exempt activities in order to help you understand what the Cabinet Office is doing with your information.

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

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

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:

• the requirement under Articles 13 and 14 UK GDPR to issue privacy notice;
• the requirement under Article 15 UK GDPR to respond to subject access requests;
• 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:

• 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 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;
• 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

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 and gallantry personal data held in manual unstructured personal data. These are principally paper records organised by theme rather than by reference to specific individuals. Further information is available on request.

How to complain

If you have any concerns about how your personal data are being handled, you may contact us:

The data controller of your data is the Cabinet Office:

Honours and Appointments Secretariat
1 Horse Guards Road
Room G39
London
SW1A 2HQ

Telephone: 0207 276 2777

Email: honours@cabinetoffice.gov.uk

The contact details for the data controller’s Data Protection Officer are: dpo@cabinetoffice.gov.uk.

The Data Protection Officer provides independent advice and monitoring of Cabinet Office’s use of personal information.

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:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Email: icocasework@ico.org.uk