Introduction and Principles

We use information about residents in different ways to improve the services we provide.  This is known as data analytics.  We bring together information from a range of services and sometimes partner organisations to understand more about the needs of those living in the borough.  Sometimes we combine information from the services with which residents use to create a ‘single view’ of a person and/or a family on to one system.  Using our resident’s information in this way is important to us because we want to:

• Make sure we can support residents in the right way.
• Identify households that are becoming more vulnerable so we can offer support at an earlier stage to help them.  This is known as predictive analytics.
• Help residents with more than one issue at the same time.
• Save time by reducing the need for residents to explain their circumstances repeatedly.
• Improve the way our services are designed and are delivered to our residents.
• Fulfill our legal duty to find ways to prevent a resident’s needs from worsening, by identifying them and supporting at the earliest possible stage.

We are, at all times, compliant with General Data Protection Regulations (GDPR). This Charter is to illustrate our commitment and additional actions above and beyond what is legally required.

Ethics

We are committed to the ethical use of our resident’s data.  This applies to the way we receive it, the way we use it and the way we share it.

• The decisions we make about resident’s situation are always made by a human being and are never automated. 
• There are no blanket decisions applied to a resident’s situation, each resident is treated individually, and their response tailored accordingly.
• There is a legal basis in line with data protection legislation for everything we do with information about our residents.  This includes sharing data across our systems, and the use of data analytics including predictive analytics.
• We do not share resident’s information outside of the council unless we have to by law.
• Where data is used to create a single view of a person or household, council staff can only see the adequate level of information required for them to do their job.

• We are fully signed up to the Local Government Ethical Standards which the government put in place to make sure the integrity of decision making is protected, that public confidence is maintained, and that local democracy is safeguarded.

Transparency

Being transparent about all elements of data use in data analytics and predictive analytics is hugely important to us, because how we manage the use of information is critical to the relationship of trust we have with our residents.  We understand that a lack of transparency can often be perceived as a lack of ethics, and this is why we have been proactive in seeking independent review of our use of data for predictive analytics.

Based on our commitment to transparency we have put the following things in place to make sure what we do is open and the reasons why we do it are clear. 

• We have actively sought external review of our use of data analytics by independent organisations including  Imperial College London’s Institute of Global Health Innovation.  
• Where applicable we engage with the Information Commissioner’s Office to seek advice.
• The Information & Ethics Charter is our attempt to separate the specific use of data analytics and emerging technologies to that of the day to day use of information in the council.
• The mathematical process used to facilitate predictive analytics are measured for accuracy on a monthly basis, and the results used for continuous improvement in the system.
• We choose to publish a lot of useful information on our Borough Data Explorer Platform which does not come under data privacy restrictions because it is ‘open data’ which is anonymous.
• We actively promote our work at various conferences and webinars, so others can see what we are up to.
• We have set up management structures within the council to oversee the use of data in predictive analytics, including forums such as the Data Ethics Sub-Group, Information Governance Group and Customer Information Board to fulfil this function.