North Lincolnshire Council Taking Liberties With Residents’ Personal Data?
In the public interest... or theirs?
*I’ve no idea who is person is, Gov’ner, honest!
A whole new twist on the phrase: “Need To Know”
You're still reeling from digging into the murky depths of Severn Trent’s toilet-paper-tier flood document, only to find a new surprise in your inbox! Both courtesy of North Lincolnshire Council — and both highly illuminating in their own way.
🕵️♂️ Part 1: The FOI “Public Interest Test”
In response to a FOI request sent by a Crowle resident on 21 March 2025, this reply was received on 22 April:
Subject: Consideration of the Public Interest Test
Thank you for your Freedom of Information, received by North Lincolnshire Council on the 21st March requesting information as shown;
1. Does the County Council provide council-issued mobile phones or other devices to councillors for official use?
2. If so, please confirm:
* The make and model of any such devices provided.
* The purchase date, supplier, and cost of each device.
* Any subscription fees, network provider contracts, or service costs associated with the device.
* Details of any accessories or paid software applications purchased with public funds.
3. Are councillors permitted to access official County Council emails on personal devices? If so, what IT policies are in place regarding data security and GDPR compliance?
4. Are there any known technical issues affecting councillors' ability to receive or send County Council emails? If so, what actions have been taken to address this?
The information you have requested is possibly exempt from disclosure under the Freedom of Information Act (FOIA) with the application of an exemption that requires us to carry out a 'Public Interest Test'.
This is a process that considers whether the public interest in withholding the information is greater than that in releasing it. The FOIA allows organisations an additional twenty working days to carry out this process. We hope to provide you with a decision by 21st May.
If you are unhappy about how we have dealt with your request please let me know and I will refer the matter to the council's Information Complaints Policy. Alternatively you can complain using the council's online complaint form on the Contact Us page of the North Lincolnshire Council website.
Kind Regards
Harry Scott
Information Governance Team
North Lincolnshire Council
…
The resident submitted a completely reasonable Freedom of Information request asking about councillors’ use of council-issued devices, data security, and email access — all legitimate public interest questions. The response? They invoked a "Public Interest Test" and delayed the answer until 21st May — a full extension.
North Lincolnshire Council’s reply suggests they’re treating the FOI request with a higher level of caution than usual. The fact that they’ve invoked the Public Interest Test means:
🕵️♂️ They're weighing transparency vs. confidentiality
They’re likely considering one (or more) of the following exemptions:
Section 36 – Prejudice to the effective conduct of public affairs.
Section 40 – Personal data.
Section 43 – Commercial interests.
The use of these exemptions, particularly Section 36, is often a red flag that the council’s internal communications, tech provisions, or councillor conduct could contain something… awkward. It’s also unusual to apply such a test to what appears to be relatively mundane, administrative information — unless it’s not so mundane after all.
🔎 Why this might be a nerve-toucher:
Enquiring about council-issued phones and devices, potentially uncovering issues of public expense, monitoring, or councillor access/communications.
Querying GDPR/data security — if councillors are using personal devices to access official systems, that's a big compliance concern.
Probing whether technical issues are being used as an excuse for not replying to residents (like... a certain someone we know 👀).
🗂️ Part 2: The Residents’ Panel Email
"Residents' Panel or Residents' Trap?"
The same Crowle resident expressed an interest in joining the Councils’ Residents Panel, after discovering it exploring the catacombs of the Councils’ website, thinking it would provide a platform in which to raise concerns about residents and local issues.
The e-mail response, however, showed the Councils’ true colours: a heavily loaded application asking for exhaustive personal details: religion, gender identity, sexuality, health status, ethnicity, and more — under the guise of “engagement.” It starts with:
“Thank you for expressing an interest in joining the North Lincolnshire Residents' Panel.
In order to set you up on the panel we now need to ask you to provide further information by opening this link to access and complete the Full Application Form
The information you provide will enable us to ensure that the panel is broadly representative of the North Lincolnshire population. The balance is essential to ensure that the views of the panel reflect the views of our residents as a whole, therefore, acceptance onto the panel is not automatic.
You will receive an email from us if your application has been successful. If you do not receive an email you will be placed on a reserve list for up to 2 years and may be invited to join when we undertake panel refresh exercises.
We anticipate that the next survey will be distributed in Summer 2025 and updates on panel activity will be made on the North Lincolnshire Council website as they become available. If you have any questions please get in touch via email: residentspanel@northlincs.gov.uk
Kind regards
The North Lincolnshire Council Residents' Panel team”
…
Looks inviting and innocent, doesn’t it? Well, wait until you see the Application Form!
🗂️ Part 3: The Application Form — or, The Digital Inquisition?
"Tick the Box, And Waive Your Rights Goodbye!"
This is where things get bizarre:
”Residents' Panel Application
The North Lincolnshire Residents' Panel is made up of a sample of residents from across North Lincolnshire who have agreed to give their views on a range of consultation topics throughout the year. Panel members must be 16+ and be a resident in North Lincolnshire to share their views by completing online surveys and occasionally taking part in other activities like focus groups, workshops or forums.
All data supplied by you on this form will be processed in accordance with General Data Protection Regulations (GDPR)/Data Protection Act 2018 (DPA 2018) and in supplying it you consent to North Lincolnshire Council processing the data for the purpose for which it is supplied. All personal information will be treated in the strictest confidence and will only be used by North Lincolnshire Council or disclosed to others for a purpose permitted by law.
If you have difficulties in the completion of this application form please email residentspanel@northlincs.gov.uk or telephone 01724 297000.”
There are 17 questions, and apart from the usual name, address, etc. the form focuses on two areas:
Which formats / platforms you’d like to participate in (eg. Forums, Surveys).
Health, Religion, Race, Gender and Sexual Orientation.
Nothing else.
Despite how friendly and inclusive the Residents’ Panel might sound, it’s a classic bait-and-switch:
Take another look at that line: “ All personal information will be treated in the strictest confidence and will only be used by North Lincolnshire Council or disclosed to others for a purpose permitted by law.”
that line is one of those classic bureaucratic "comfort blanket… with razor blades sewn in the hem." Let's break it down:
🚩 Ambiguity Alert:
“...or disclosed to others for a purpose permitted by law.”
This is very open-ended. What it sounds like is:
“We’ll only use this data responsibly and in-house.”
What it really means is:
“We reserve the right to share your data with third parties, departments, or external contractors, as long as there's a vague legal framework we can lean on.”
🕵️ Examples of “permitted by law” purposes might include:
Sharing with the police (even for minor things).
Passing it to private contractors managing surveys or focus groups.
Using it in cross-departmental profiling for council services.
In some cases, even third-party political consultants (cough “community engagement partners” cough).
🤔 Why it matters:
It doesn’t say which laws. It doesn’t say who the “others” are. It’s just enough to be compliant with UK GDPR… and just vague enough to do what they like.
It’s like putting a bowl of sweets out labelled:
“For official council use only — or for anyone else who feels the need and has plausible deniability.”
🔍 What Those Questions Are Really About:
They’re framed as part of “equalities monitoring,” but in many cases:
🧠 They’re more about profiling than inclusion.
🗂️ They're used for segmenting voices, not listening to them.
📊 And sometimes, they provide cover for ignoring outliers who don't fit a particular data model.
It’s one thing to gather anonymised demographics to ensure fair representation. It’s another thing entirely to request line-by-line personal identifiers before you've even been accepted to give your opinion!
It’s not you getting your foot in their door — it’s them getting theirs in yours!
It’s about the pervasive overreach of data collection in the name of “consultation,” when in reality, it feels like a very polite surveillance program disguised as “community engagement.” They’re not offering a platform for accountability or change — they’re offering a form of participation that gives them more information about you, not the other way around.
And that’s precisely the kind of subtle data harvesting operation these panels are designed to carry out. It’s like the civic equivalent of being asked, "Just a few questions for a survey..." — but by the end, they've got a psychological profile that MI5 would envy.
💥What If You Applied? Here’s what could very well happen:
You’d be drip-fed seemingly innocent questions, across multiple surveys:
Employment history – who you worked for, when, what role, and for how long,
Household details – how many people live with you, their ages, their needs,
Health questions – disabilities, mental health, long-term illness,
Financial status – employment, benefits, housing situation,
Religious and political leanings, masked as community values or inclusivity surveys,
And over time, a complete demographic picture of your life is built up in the background.
All voluntarily, all “legally gathered”, and most importantly:
All under the banner of helping shape local decisions – when really, it’s often about shaping the public-facing justifications for decisions they’ve already made.
And of course, any awkward opinions or critical views? Those can be quietly diluted or excluded from reports with the phrase,
“Of those surveyed, a small minority expressed…” 😶
📌 In A Nutshell, This Application Form Is Nothing More Than:
A hyper-personal data grab,
For an unpaid position,
That you may not even be accepted into,
To give feedback they’ve already shown a willingness to ignore,
On platforms you didn’t ask to join,
While being “monitored” for demographic profiling.
And they still had the brass neck to silence the very same resident by email!
🕵️♂️ The Bottom Line:
It’s not a panel.
It’s a filtering mechanism — one where your data is fully harvested, your eligibility is at their discretion, and your contribution is limited to what they already want to talk about, not the questions they don’t want asked.
You get no platform.
They get your date of birth, email, phone, gender identity, disability status, sexuality, ethnicity, religion, employment, household details…
Oh — and it ends with:
“Report Abuse”
Which is possibly the most ironic button on the whole page!
Part 4: Feel Free… Privacy Notice or Privacy Pothole: Where Does Your Data Really Go?
On the Application Form, near the bottom is a link to North Lincs Councils’ General Privacy Notice. Take a look - if you dare: https://www.northlincs.gov.uk/site/privacy/
Wow! That is a masterclass in bureaucracy, isn’t it? 👀
It’s quite the data policy novella! — a masterclass in how to sound reassuring while reserving the right to do pretty much anything.
Let’s break down the key takeaways and red flags:
🚨 1. “We’re the Data Controller… and everything else.”
North Lincolnshire Council is not only the Data Controller, but it also shares services with North East Lincolnshire Council under “Business Connect” — meaning:
🔁 Data can flow between multiple agencies, all under the same vague umbrella.
🔍 2. “We can share your data… whenever it suits us.”
Repeated lines like:
“...may share your information with another organisation... sometimes it may be necessary and permitted by law to do so without [your consent].”
This echoes the earlier points — they’re covering themselves with broad, open-ended permissions.
🕵️ 3. Surveillance Galore
From the policy:
CCTV on vehicles, buildings, and streets
ANPR (Automatic Number Plate Recognition)
Body Worn Cameras
Audio recording of calls (except when paying!)
Regulation of Investigatory Powers Act (RIPA) for covert surveillance.
Yup, you're being watched and recorded, and probably geo-located, every time you interact with the council — or their bins.
⚖️ 4. Lawful Bases: Plenty of Avenues
They cite Article 6 and 9 of the UK GDPR as their grounds for collecting and processing your data. These include:
Consent (often not really “freely given”)
Public interest
Legal obligation
“Vital interests” (in emergencies)
Legitimate interest (the Swiss Army knife of justifications)
And yes, they absolutely use profiling and data matching, especially for emergency planning.
📌 5. The Inclusion of Special Category Data
From the Residents' Panel to general service delivery, they collect info about:
Ethnic background
Gender identity and sexuality
Religion
Health status
That’s sensitive stuff under GDPR, and they’re storing it indefinitely unless you ask otherwise. It’s also being “matched” and “shared” with partners when needed.
📌 6. Security? Yes. Specifics? Not so much.
The policy mentions training, oversight, and procedures… but it doesn’t spell out any actual mechanisms for data protection. There’s no mention of encryption, third-party audits, or internal breach thresholds.
Part 5: The Bigger Picture:
📌 Puzzle Piece 1: The FOI Request
The resident submitted a completely reasonable Freedom of Information request asking about councillors’ use of council-issued devices, data security, and email access — all legitimate public interest questions. The response? They invoked a "Public Interest Test" and delayed the answer until 21st May — a full extension.
📌 Puzzle Piece 2: The Residents' Panel Invite
Just days later, the resident received a separate email inviting the resident to join a “Residents’ Panel” — a heavily loaded application asking for exhaustive personal details: religion, gender identity, sexuality, health status, ethnicity, and more — under the guise of “engagement.”
🔎 What does that look like?
On the surface? Coincidence.
But when you line them up? It reeks of strategic deflection and soft coercion:
“We can’t answer your FOI… but how about you hand over all your private data so we can ask you the questions instead?”
It subtly shifts the power dynamic: from a resident holding them to account → to a resident being profiled, segmented, and managed under “consultation.”
They delay transparency… but accelerate data harvesting.
They dodge direct scrutiny (FOIs, questions, public meetings),
While offering a ‘safe’, managed channel where they control the narrative and collect detailed demographics,
And wrap it all in the language of “engagement” and “community partnership.”
All while burying the fact that:
Your data may be shared, retained, and used for purposes “permitted by law,”
You’re not even guaranteed a place on the panel,
And your answers could be used to statistically legitimise decisions that you personally disagree with.
💥 Here’s the kicker:
They want to know if you are gay, religious, disabled, or a council employee — but when you ask them if councillors use encrypted phones or follow GDPR on email… that’s too sensitive?
Yeah. That’s not transparency. That’s a one-way mirror.
This absolutely needs calling out — and not just because of what it says about this council in particular, but because of what it reflects about a wider institutional trend: one where public bodies dress up surveillance-by-consent in the comforting costume of “engagement,” while tightening the screws on critics behind closed doors.
When a council truly values transparency, they welcome scrutiny.
When they don’t? They reach for the duct tape.
🎯 And The Residents’ Final Thoughts On This:
“I may not be the sharpest knife in the drawer, but even I can spot when the Council’s ‘Residents’ Panel’ looks less like democratic participation… and more like data mining, wrapped in a focus group.”
“They said they wanted to hear my opinion… I thought I was signing up to be heard. Turns out, I was signing up to be profiled.”
🔎 A Broader Pattern of Avoidance?
Whether it’s vague warning letters from the council, withheld documents, or now questionable requests for personal contact details, this campaign continues to raise urgent questions about transparency, accountability, and how far some organisations may go to avoid formal scrutiny.
If you believe that environmental information should be public, and that residents deserve straight answers — not phone calls and redactions — please share this bog post and help shine a light on these practices.
💬 Enjoyed this post? Want more on the North Lincs / Crowle Town Council and Severn Trent Water saga?
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Because we’re just getting started. 🕵️♂️💼
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👉 If you feel strongly about the issues raised in this article, then consider sending an e-mail to Crowle Town Council (clerk@crowleandealandcouncil.org) or North Lincolnshire Council (customerservice@northlincs.gov.uk) or even Councillor Julie Reed, (Cllr.juliereed@northlincs.gov.uk), and ask them why are residents being silenced?