This guide has been written for Devon County Council staff but is published in a public domain so that the public and other organisations can have access to it to help understand how and why we collect and use data. The guide also has the endorsement of our Equality Reference Group – a group of voluntary sector agencies who represent diverse communities and act as a ‘critical friend’ to the County Council.
Please note, this guide does not seek to explain Data Protection requirements.
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Collecting Personal Information
It is usually necessary to collect information about people in order to correspond with them, for example their title, name and address. It may also be necessary to collect other information such as date of birth and disability to understand a bit more about the customer and their needs or eligibility, or to check we are dealing with the right person.
However, in decision-making processes such as employment recruitment and selection, it is best practice to put all personal information in a section that can be separated – and is visibly separate – so that decision-makers do not have access to it. Note that all personal data collected for equality and diversity monitoring such as race, gender, disability must be separate.
This is because personal information may influence the decision-making processes through ‘unconscious bias’. Unconscious bias is where we make judgements and assumptions about people based on previous experience and stereotypes. An example of a stereotype is that women make better carers than men.
We all have biases. Sometimes we are unaware they are influencing us, and they can get in the way of us making the best decision. Our biases are most dominant when we make quick decisions or decisions under pressure.
Personal information can imply more about a person than may be needed for a decision, for example:
- Names could imply gender, marital status (women), ethnic and religious backgrounds.
- Dates attended school could reveal how old someone is.
- Address tells us where someone lives – if they are living in a deprived or wealthy area, or are homeless or a Gypsy/Traveller.
Appropriate categories for collecting personal information (names)
- Title: We would recommend leaving this open (blank space) for people to add their own. If you do need to use honorifics, these are the most appropriate: Dr / Miss / Mr / Mrs / Ms / Mx / Other (please specify), however people should be allowed to leave this blank if they wish.
‘Mx’ is for anyone who doesn’t want to, or cannot, identify as male or female. If you don’t know whether to use ‘he’ or ‘she’ (and usually it is best avoided if the person’s gender is not known), use ‘s/he’ (in documents) or ‘they’ (verbally or in documents), or Dear Sir/Madam in formal letters.
- First name: ‘Christian name’ is not appropriate in many circumstances because not everyone is Christian, therefore use ‘first name’. ‘Forename’ is also acceptable.
- Known as: use this if you want to know how someone prefers to be called on first name terms, for example, ‘Jo’ rather than ‘Joanna’.
- Middle name(s) and Surname are appropriate to use. Some people refer to their Surname as their ‘Family Name’.
- Previous surnames: use this rather than ‘maiden name’ because a man may have changed his surname.
- Parent, guardian or carer: use instead of ‘mother’ or ‘father” or ‘parent’ in data collection so that it is inclusive. A child may have two female or two male parents, a single parent, or may be adopted or in foster care.
Please see the equality and diversity monitoring section for guidance on collecting information about other categories such as ethnicity, disability and sex or gender.
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Finding out about needs
You may also need to find out if someone has any needs related to a diversity characteristic. It’s up to the individual if they want to share this information with you and therefore you need to treat the information sensitively and without prejudice.
If someone has a disability and requests an adjustment you have a legal obligation to meet this need, if it is reasonable. Adjustments are not limited to modifications to the physical environment or format of information. If you are unsure if it is reasonable, please contact the equality officer (DCC staff only).
You could ask all or any of the following questions, for example, depending upon the need for information and how you will support an individual:
- Do you have access requirements, or need assistance or adjustments made because of a disability? If yes, please give details:
- Can you speak or read English? Yes / A little / No – If ‘no’ or ‘a little’, what language(s) can you speak or read?
- Is there anything about your religious beliefs, ethnic/cultural heritage, sexual orientation or gender identity that we need to take into account when considering your needs? (this could be used as part of a social care assessment, for example).
For people with little or no English language skills, you could use a Language Identification Card which is available from the Telephone Interpreting Service. If the person is Deaf, it is likely they will need a British Sign Language interpreter. People with a learning disability usually require Easy Read or Total Communications support.
For further information about providing alternative formats and communication support please see our guidance for DCC staff on Inside Devon.
For further information about meeting needs please see our Diversity Guide.
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Monitoring Equality and Diversity
Equality and diversity data collection and monitoring is useful for assessing the impact our policies and practices have on different people, including levels of satisfaction and other outcomes. By collecting and analysing equality and diversity data, we are able to see if practices are providing fair access and opportunities for all and reducing inequalities. This would include collecting and analysing data about employees, potential employees, service users and Devon residents. Examples of DCC equality and diversity monitoring are available.
Some people may be fearful of why you are asking the information and do not want to be identified. For example, some people do not like to say they are from an ethnic or religious minority community for fear that they will be treated badly. Others are concerned about surveillance tactics used by governments or simply prefer to be ‘off the radar’ for socio-political reasons. People who lived through the holocaust will have a deeply negative experience of the collection of personal data which was used by the Nazis to identify Jews and others. Some things are very private to people such as their sexual orientation or religion/belief, for others they may be very open and expressive about these identities.
Always have a clear purpose for asking information, communicate this clearly and show the results so that people can see how you are using the information fairly and lawfully.