1. Introduction
1.1 This privacy statement explains how the Comptroller and Auditor General (C&AG) and the National Audit Office (NAO) use and protect any data they hold about you. This statement also summarises your rights in relation to that data.
2. Who is the data controller?
2.1 When the C&AG or the NAO uses data about you the C&AG or NAO does so as a data controller.
2.2 In this privacy statement ‘we’, ‘us’ and ‘our’ refers to the C&AG, the NAO, or both, depending on which holds your data.
2.3 We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below:
The Data Protection Officer
National Audit Office
157-197 Buckingham Palace Road
Victoria
London SW1W 9SP
3. What kinds of data may we access or hold about you?
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified directly or indirectly. It does not include data where the identity has been removed (anonymous data).
3.2 We process data where we have a clear legal basis for doing so and where it is proportionate and necessary in pursuance of our role and responsibilities. In practice, this means that we may potentially collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3.2.1 Identity Data could include names, marital status, title, date of birth, nationality and gender.
3.2.2 Contact Data includes address, email address and telephone numbers.
3.2.3 Work Data includes details about your work for an organisation that we audit or examine or a related organisation or for an international organisation, including details of your role at the organisation, projects you have worked on, your personnel file, information about your performance, and correspondence between you and colleagues at that organisation or between you and people who interact with that organisation.
3.2.4 Financial Data includes bank account details, pay and payslips, pension contributions and entitlements, records of payments to and from you, and tax records.
3.2.5 Service Data includes details about your use of services provided by organisations we audit or examine or related organisations or by an international organisation and details about actions those organisations have taken relating to you, including case files and other records the organisation keeps about you and correspondence between you and those organisations.
3.2.6 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
3.2.7 Usage Data includes information about how you use our website.
3.2.8 Communications Preferences includes your preferences in receiving information from us such as updates about our work and events and our other public engagement activities, and your communication preferences.
3.2.9 CCTV and Access Data includes data captured by our CCTV system and building access control systems.
3.2.10 Event photographs or videos means group or individual photographs, or videos taken at conferences or other events hosted at our offices.
3.3 Work Data, Financial Data and Service Data may sometimes include Special Category Data, which means data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, and may also sometimes include data about criminal convictions and offences (Criminal Data). This is rare, but does sometimes happen, for example:
3.3.1 where our financial audit includes payroll information it might include details of trade union subscriptions you have asked your employer to deduct from your pay;
3.3.2 where we examine the effectiveness of organisations that provide services relating to the criminal justice system we might access Criminal Data in the course of the examination.
4. How do we collect your personal data?
4.1 We collect your data in different ways. Most of the data we hold about you is data you have provided directly or is data provided to us by organisations that we audit or examine or related organisations.
4.2 In this statement we use the phrases ‘audit’ and ‘examine’ to refer to the work we carry out for our main statutory functions:
4.2.1 ‘Audit’ refers to the financial audits and examinations of accounts that we are required to carry out by law, or that we carry out under agreements. You can find out more about our audit work here [Financial Audit].
4.2.2 ‘Examine’ refers to the value for money studies and investigations that we carry out using our legal powers. You can find out more about this type of work here [Value for Money and Investigations].
4.3 Data collected for audits or examinations. When we audit or examine an organisation we collect information from that organisation, and sometimes from its contractors, grant recipients, or other related organisations. The information we collect from them may contain your Identity Data, Contact Data, Work Data, Financial Data, Technical Data or Service Data. Sometimes that information is provided to us voluntarily, but generally we obtain it through using our legal powers to access information.
4.4 Data collected in our international work. We work with international organisations to share knowledge and develop their audit expertise and capacity, including by supervising pilot audits. Those organisations may provide personal data to us.
4.5 Direct interactions. You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This also includes personal data you provide when you:
4.5.1 subscribe for email updates;
4.5.2 take part in one of our surveys;
4.5.3 give us feedback;
4.5.4 apply for a job with us;
4.5.5 connect with us on social media; or
4.5.6 attend an event we host.
4.6 Correspondence or publicly available sources. We may receive personal data about you from people who write or telephone us or from publicly available sources such as Companies House.
4.7 Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
4.8 Photography or video recordings at our events. If you attend events hosted at our offices, you may be invited to appear in an individual or group photograph or video used to record or publicise the event.
5. How do we use your information?
5.1 We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
5.1.1 Where it is necessary in order for us to carry out our statutory functions in the public interest or, in the case of special categories of personal data, for reasons of substantial public interest. Our audits and examinations help Parliament to scrutinise public spending, hold government to account, and drive improvement in public services. This work serves a substantial public interest.
5.1.2 Where it is necessary for us to comply with a legal or regulatory obligation.
5.1.3 With your consent, but only in the case of sending you email updates. You have the right to withdraw consent at any time by contacting us.
5.2 We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so.
5.3 Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose | Type of data | Lawful basis for processing |
| a) To conduct a financial audit that statute requires us to conduct, or where we have agreed to act as a statutory auditor, including reporting the results of the audit; orb) to conduct statutory examinations of the economy, efficiency, and effectiveness of certain types of organisation, which we do by carrying out value for money studies, investigations, and briefing Parliament. | Identity Contact Work Financial Service Technical (These types of data may include Special Category Data or Criminal Data.) | The processing is necessary for us to carry out statutory functions in the public interest.Where we process Special Category Data or Criminal Data we do so because it is necessary for carrying out statutory functions, which serves a substantial public interest. |
| To carry out the statutory function of providing services outside the United Kingdom by providing technical co-operation to international organisations. | Identity Contact Work Financial Service Technical (These types of data may include Special Category Data or Criminal Data.) | The processing is necessary for us to carry out statutory functions in the public interest.Where we process Special Category Data or Criminal Data we do so because it is necessary for carrying out statutory functions, which serves a substantial public interest. |
| To act as a statutory prescribed person for whistleblowing disclosures.Note that references to the types of data we process for this purpose are to data relating to the whistleblowing disclosure. | Identity Contact Work Financial Service Technical (These types of data may include Special Category Data or Criminal Data.) | The processing is necessary for us to carry out statutory functions in the public interest.Where we process Special Category Data or Criminal Data we do so because it is necessary for carrying out statutory functions, which serves a substantial public interest. |
| To carry out the daily process of approving issues from the Consolidated Fund and National Loans Fund. | Identity Contact Work Financial Technical(These types of data may include Special Category Data) | The processing is necessary for us to carry out our statutory functions relating to the Consolidated Fund and National Loans Fund in the public interest.Where we process Special Category Data we do so because it is necessary for carrying out our statutory functions relating to the Consolidated Fund and National Loans Fund, which serves a substantial public interest. |
| To carry out quality assurance for our audit and examination work, and to enable the Financial Reporting Council to review our audit work. | Identity Contact Work Financial Service Technical(These types of data may include Special Category Data or Criminal Data.) | The processing is necessary for us to carry out our statutory functions in the public interest.Where we process Special Category Data or Criminal Data we do so because it is necessary for carrying out our statutory functions, which serves a substantial public interest. |
| To contact you to ask you to participate in surveys relevant to our value for money studies, investigations, and briefings to Parliament. | Identity Contact | The processing is necessary for us to carry out the statutory functions in the public interest. |
| For recruitment purposes | Identity Contact Work Technical (These types of data may include Special Category Data or Criminal Data.) Your Consent. | Necessary for entering into a contract between the data subject and data controller.Our trainee recruitment processes make use of automated decision making in relation to UCAS points and our use of online testing. You can request to have this automated decision reviewed by a human being. |
| To send you NAO publications, email updates and manage event invitations you have accepted | Identity Contact Communications Preferences | Your consent.Processing is necessary in the public interest. |
| To respond to correspondence from you. | Any data you include in correspondence.Technical. | The processing is necessary for us to carry out the statutory functions in the public interest. |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical Usage | The processing is necessary for us to carry out the statutory functions in the public interest.Processing is necessary to comply with a legal obligation. |
| To maintain the physical security of the NAO, our staff, tenants, clients, and visitors in and around our premises and for the detection and prevention of crime. | CCTV and Access Data | Processing is necessary in the public interest. |
| For fulfilling our legal obligations to provide information to third parties. | Any of the categories of data we hold. (These types of data may include Special Category Data or Criminal Data.) | Processing is necessary for compliance with our legal obligations.In the case of Special Category Data or Criminal Data processing is necessary for reasons of substantial public interest, or is necessary for the establishment, exercise, or defence of legal claims. |
| To take legal advice and to make and defend legal claims. | Any of the categories of data we hold. (These types of data may include Special Category Data or Criminal Data.) | Processing is necessary in the public interest.In the case of Special Category Data or Criminal Data processing is necessary for the establishment, exercise, or defence of legal claims. |
| To record or publicise the events that we host. | Event photographs or video | Processing is necessary in the public interest. |
5.6 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
5.7 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5.8 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Who do we share your personal data with?
6.1 We may have to share your personal data with the following parties for the purposes set out in the table above.
6.1.1 Parliament, if the personal data is included in a report that we are required to lay before Parliament;
6.1.2 the Financial Reporting Council (FRC), where the FRC reviews our audit work for quality assurance;
6.1.3 third parties that are legally entitled to receive the data;
6.1.4 our service providers that process the data on our behalf in order to provide IT and system administration services; and
6.1.5 our service providers who process the data on our behalf to conduct surveys or to distribute our newsletters or other communications;
6.1.6 our professional advisers including lawyers and auditors who provide professional services to us.
6.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. Do we transfer your data outside the EEA?
7.1 If we transfer data outside of the European Economic Area, we will take measures to ensure all adequate safeguards are in place that matches the EU Data Protection standards, in accordance with legal requirements.
8. How do we keep your data secure?
8.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. How long do we keep your data?
9.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9.3 Details of retention periods for different aspects of your personal data are available in our Retention Policy.
10. What are your rights?
10.1 You have the right to:
10.1.1 Request access to your personal data (commonly known as a “data Subject Access Request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
10.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
10.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
10.1.4 Object to processing of your personal data where the processing is based on our exercise of our statutory functions in the public interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
10.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
10.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
10.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
10.1.8 Request a review by a human being of the automated decision making element of our trainee recruitment processes.
10.2 The rights listed above are subject to some exceptions and limitations. If those are relevant when you ask to exercise your rights we will tell you.
11. How can you exercise your rights?
11.1 If you wish to exercise any of the rights set out above please contact us using the details at the start of this privacy statement.
11.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
11.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
11.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11.5 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12. Changes to this privacy statement
12.1 This version was published on 01 June 2020. We will update this statement as necessary and any superseded versions can be obtained by contacting us.