Digital Advisory Panel: Managing conflicts of interest policy
Annex B: Privacy notice – register of personal interests
This Privacy Notice sets out how the Gambling Commission (the Commission) processes your personal information in relation to the Register of Personal Interests.
The purpose of the register is to record information about any private interests that individuals have that others may reasonably consider to conflict with their public duties.
We collect this information to protect both the organisation and the individuals involved with it to maintain the highest standards of probity and integrity.
Who do we keep information about?
We keep information about:
- independent members of Commission committees
- Commission employees
- independent contractors working with the Commission
- members of Commission advisory groups
- connected persons (for example spouse and/or civil partner and/or cohabitee).
What information do we collect about you?
We will record the information that is provided to us on the Register of Interests form as follows:
- outside personal interests
- financial interests
- political interests.
How will your information be used?
Your information will be held on a central register of interests which will be maintained by the Governance team.
For the most senior decision-makers and advisers in the organisation, information will be published on the Commission website as part of our commitment to transparency and to meet the requirements of the Cabinet Office Code of Conduct for Board Members of Public Bodies which specifies interests should be declared publicly.
Annex A of the Managing Conflicts of Interest Policy contains information relating to which category of information will be published.
What is our lawful basis for processing your personal information?
The General Data Protection Regulation and the Data Protection Act 2018 (opens in new tab) sets out the lawful bases for which personal information can be processed. The personal information that we process is done so as follows:
For Commission employees
Article 6(1)(a) – processing is necessary for the performance of a contract.
Please see relevant Codes of Conduct.
For individuals appointed by the Commission and/or Connected Individuals
Article 6(1)(f) – processing is necessary for the purposes of the legitimate interests pursued by the Commission for the Register of Interests to be established and maintained.
Who is your personal information is shared with?
The central register of interests and completed forms, that are maintained by the Governance team will only be accessed by that team.
Where required this information will be published on the Commission’s website as set out in Annex A of the Managing Conflicts of Interest Policy.
Is my information transferred to a third country or international organisation?
No – but the Register of Interests is published on the Commission’s website which can be viewed from any location.
How long do you keep information about me?
The information that we collect about you will be updated at least annually.
The details recorded on the Personal Interests Register will be removed from the Commission’s website within one month after the individual leaves their position.
Electronic records will be kept for the duration of employment and/or appointment and then for 3 years after the individual has left their position. After this time, the information will be destroyed.
Your data protection rights
Under data protection law, you have rights including:
Your right of access
You have the right to ask us for copies of your personal information.
Your right to rectification
You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure
You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing
You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing
You have the the right to object to the processing of your personal information in certain circumstances. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at firstname.lastname@example.org if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at email@example.com.
You can also complain to the ICO if you are unhappy with how we have used your data.
The Information Commissioner's Office's (ICO) address:Information Commissioner’s Office
Helpline number: 0303 123 1113.
ICO website: https://ico.org.uk (opens in new tab).Previous section
DAP: Managing conflicts of interest policy - Annex A: Rules and handling
Last updated: 14 February 2023
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