Freedom of information response

Social media monitoring / social media intelligence

Publication date: 
Friday 1 November 2019
Request: 

1. In 2016 the Rt Hon Lord Judge, then Chief Surveillance Commissioner, wrote to all Local Authorities regarding use of social media in investigations. Please confirm whether you are aware you received this letter and:

a) Provide a copy of your response; (please confirm if you did not respond)

b) Provide a copy of any internal audit relating to social media use arising out of Rt Hon Lord Judge’s recommendations; (please confirm if you did not conduct an internal audit and state whether any internal audit of social media use has taken place since 2016).

c) Provide a copy of your corporate policy on the use of social media in investigations. (please confirm if you do not have one)

d) Please confirm whether a follow up audit was conducted by the Surveillance Commissioner’s Office which was exclusively or partially related to social media use in investigations by your Local Authority.

2. Does your Local Authority conduct overt and/or covert social media intelligence in some or all of its work?

a) If yes, please specify whether this includes profiling individuals, conducting investigations, monitoring individuals, monitoring groups, monitoring locations, gathering intelligence, for recruitment purposes.

b) If your Local Authority does conduct social media intelligence/monitoring, please specify whether this includes both or either overt or covert monitoring of social media.

(c) If the Local Authority has conducted covert social media monitoring, please confirm the number of RIPA warrants obtained in the last two years for this purpose.

3. If the Local Authority conducts social media intelligence, please provide a copy of any current guidance/policies/internal guidance/code of practice or any other such written material used by/available to the local authority or those working on behalf of the local authority to conduct SOCMINT, the monitoring or accessing of information published on social media that is either publicly available or requires additional access e.g. to be friends with an individual, to have password and login details.

4. If you conduct overt or covert social media intelligence relating to social media platforms, please provide a copy of:
(a) Relevant [sections of the] privacy policy;
(b) the data protection impact assessment;
(c) privacy impact assessment;
(d) equality and human rights impact assessment
(e) training materials for those conducting social media intelligence.

Please state if you do not have any of the above.

5. Please provide a copy of any other template/form/document currently used (or to be used with the next three months) by the local authority or fraud investigator (or team) in the conduct of social media monitoring

6. Please confirm whether or not your local authority has purchased or uses software and/or hardware to conduct social network / social media monitoring and/or in relation to sentiment analysis.

a) If yes, please state the name of the company / provider.
b) If no, please state whether the local authority has developed internal methods to conduct social media / social network monitoring.

7. Please confirm, if not stated in the guidance (question 3), the policy on deletion of data obtained from social networking sites.

8. If no documents (question 3) exist, or if the following is not covered in the documents which do exist, please explain:
a. In what areas of the local authority's work is social media monitoring used
b. What criteria must be satisfied in order for social media monitoring to be carried out
c. Who must authorise the request to conduct social media monitoring
d. What is the process for conducting social media monitoring
e. How long is data collected and retained?
f. Is there any process for requesting deletion?

9. Are you able to state how regularly social media monitoring is used? If so, please provide the figures.

Response: 

1.

a) The Council has a letter of 20 March 2017 on file. No response was required in relation to this letter.

b) No Internal Audit reviews have been undertaken of social media has been undertaken since 2016.

c) This is referenced in our RIPA Policy

d) A follow up audit has not taken place

2.

a) If this takes place our RIPA Policy will be followed

b) As above

c) Nil

3. This is contained within our RIPA Policy

4. See response to 2A above

5. Our RIPA Policy will be followed

6. No

a)

b) No

8. Our RIPA Policy will be followed for any monitoring of this nature. Data retention policies will be followed for retention periods

9. This does not take place

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If you remain unhappy following the outcome of your Internal Review you may wish to refer your case to the Information Commissioner’s Office (ICO), details of this organisation can be found at www.ico.org.uk . Please be advised that the ICO will not consider your case until they have confirmation that you have already been through the Internal Review stage with the council.

Request reference:
FOI 9477