1.          Introduction
      1.1.   This Code of Practice refers to all data matching carried out internally by Fife
             Council or by a third party on behalf of the Council.
      1.2.   In producing this Code of Practice, Fife Council recognises its obligations to
             protect the rights of individuals as set out in the Data Protection Act 1998. In
             addition, the Code supports the Council’s aims and values and assists the
             Council, as a public body, to meet its responsibilities to protect public funds. This
             is achieved by defining the circumstances in which personal data can be used for
             the purposes of improving service delivery, protecting vulnerable individuals,
             identifying possible cases of fraud and reducing financial losses.
      1.3.   The Data Protection Act has eight key principles which must be met to ensure
             compliance. These are listed in the Appendix to the Code.
      1.4.   The Code explains why the Council uses data matching and the processes which
             are involved. It also explains the controls and safeguards which are in place to
             ensure that the Council conforms to what is allowed by the law.
      1.5.   The Code is not intended to be a full and authoritative statement or interpretation
             of the law.

 2.        What data matching is
      2.1. Data matching is a technique used to help deliver joined up services, business
           improvement, detect fraud, and for debt recovery within the public and private
           sectors. It compares the data contained in two or more computer systems from
           which inconsistencies are identified. The results are then used for further
           investigation. This means that data provided for one purpose may be matched
           against data provided for another purpose.
      2.2. Data matching is used to check accuracy of data by comparing multiple datasets.

 3.        Why we use data matching
      3.1. The Council is expected to carry out all of its functions accurately, efficiently and
           in accordance with the law.
      3.2. The use of data matching helps the Council to:

              ensure data accuracy;
              deliver joined up services both internally and with partner
              improve the Council’s business processes; leading to improved
               efficiency and effectiveness;
              detect duplicate payments;
              prevent and detect fraud both against the Council and other public
               government bodies or agencies where the Council has relevant
               statutory / authorised powers;
              improve the Councils ability to recover debt.

      3.3. Where the data matching process reveals inaccuracies in the information held,
           this will be amended without delay.

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      3.4. The use of data matching does not affect the responsibility of each person to
           provide the Council with all relevant information and, in particular, to notify all
           relevant changes of circumstances.

 4.        Definitions
      4.1. Statutory definitions contained within the Data Protection Act are as follows:

            Data is information recorded in a form in which it can be processed
             automatically in response to instructions; information recorded as part
             of a relevant filing system or an accessible record.
            Personal data is anything which is capable of identifying a living
             individual, e.g. name and address, CCTV image, telephone call
             recording, e-mail address, postcode, photograph etc.
            A data subject is a living individual who is the subject of personal data;
            Processing data means re-arranging, correcting and extracting it by
             reference to the data subject;
            Disclosing data includes disclosing information from the data and from
             any data matching exercise by the Council to any other party.

      4.2. Other technical definitions are as follows:

            Data matching is the computerised technique whereby matches,
             near matches or anomalies of data fields within and between
             computerised or manual systems are identified for further
            Output means the printed list and / or data file reported from the
             data matching process;
            Media means computer data in whatever form, e.g. paper, disk,
             floppy disk, CD, USB memory stick, CSV file, tape, cartridge etc.

 5.        The security & confidentiality of data matching
      5.1. General Principles
           The general principles and practices governing the data matching exercise are set
           out below:-
           a) Data will only be obtained and used in accordance with the provisions of the
                Data Protection Act 1998.
           b) To ensure the data is processed fairly, the software, techniques and
                algorithms used in the data matching exercise are focused on data quality
                improvement, business improvement and the detection and prevention of
                fraud. They will be reviewed and refined in the light of practical experience.
           c) Where data matching is undertaken to detect or prevent fraud no
                assumptions will be made that the matches are fraudulent. Auditors will
                review output to eliminate coincidental matches, in order to concentrate
                exclusively on potentially fraudulent cases.
           d) The data obtained and processed will be current, adequate and relevant and
                will be the minimum required to undertake the matching exercise and report
                the results.

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            e)     At the conclusion of the exercise, the output data will be held for no longer
                   than is necessary for the purpose of the exercise.
            f)     Disclosure of the results of the exercises will be restricted to Fife Council
                   Services, Fife Council External Auditor, the Department for Work and
                   Pensions, Employment Services, Inland Revenue, NHS and the Police or
                   such other bodies as may be required in law.
            g)     Data will be held securely at all times.

    5.2. Media Control
         a) All physical media will be stored securely in a locked cabinet or cupboard.
         b) Media will not be passed to any third party unless specified in the Data
             Protection Act Registration and unless the third party has a code of practice
             or equivalent standard to this Code.
         c) All media, except matches, will be erased, shredded or otherwise securely
             disposed of after all queries have been resolved. This will normally be less
             than six months after its production.
         d) All data created during the data matching process, except matches, will be
             erased as soon as the next processing stage has been successfully
         e) Any paper output resulting from the data matching process will be disposed
             of as confidential waste or will be shredded.

    5.3. Output Control
         a) All output, in whatever form, will be stored securely in a locked cabinet or
         b) The data matching process will be refined in the light of experience to reduce
             coincidental matches and to focus on key areas.
         c) Where data matching is undertaken to detect or prevent fraud decisions on
             matches will not be made without human intervention. Lists of anomalies will
             be passed to appropriate investigating officers.
         d) Where data matching is undertaken to detect or prevent fraud; to avoid
             duplication of matches in subsequent matching exercises, a master copy of
             matches will be held by Audit and Risk Management Services.

    5.4. Access Control
         a)  Through training, all staff involved will be made aware of the requirements for
             confidentiality and the requirements of the Data Protection Act
         b)  Access to the data matching process will be available only to Audit and Risk
             Management Services staff or other authorised employees of Fife Council
             and Community Planning Partners (e.g. NHS Fife and Fife Constabulary).
         c)  All computers involved in processing or matching will have appropriate
             physical and logical access controls, all of which will be reviewed at intervals.
         d)  Access controls will restrict individuals to their own required levels of access.

    5.5. Back-up
         a)  All data will be backed up at appropriate intervals. Backup files will be
             subject to the same controls as the original files.

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 6.        Where the Data comes from
      6.1. The data used for matching will be provided by systems operated by Fife Council
           and a range of external bodies including partner organisations, Council related
           companies and grant aided agencies. The information is gathered from a variety
           of sources including service requests, benefit forms, licence forms, supplier
           invoices, payroll forms, rent forms and voters roll records.
      6.2. All information gathered is covered by a Privacy (Fair Processing) Statement.
      6.3. Data gathered in the data matching process by Fife Council will not be transferred
           to third parties without the consent of the data subject, unless there is a legal
           obligation to do so, such as in relation to Benefits Fraud where the Council has a
           legal obligation to inform the Benefits Agency under the Social Security
           Administration (Fraud) Act 1997 and Audit Scotland for the National Fraud

 7.        How the Data is obtained
      7.1. When asking a Fife Council Service (data provider) for data, the data requester
           identifies the information which is required to facilitate matching against
           information in other Council systems, and provides the reasons for carrying out
           the matching exercise. The data requester and the data provider will formally
           agree, in writing, what data will be required. This is the data specification.

 8.        How the Data is matched
      8.1. Where data matching is undertaken to detect or prevent fraud files or parts of files
           will be downloaded from the source systems to the data requester; they will only
           receive data that they require and that the law allows.
      8.2. The contents of files downloaded will be compared to identify, as appropriate:

            Matches
            Near Matches
            Anomalies

      8.3. These computer-identified cases will not be taken as evidence of error or fraud.
           They will be treated as anomalies and will be sent to appropriate expert staff for

 9.        Quality of Data
      9.1. The data specification agreed between the data requester and the data provider
           ensures that the data requester only receives the data that is required.
      9.2. When the data requester receives the data, it is checked to ensure that it
           conforms to the data specification and is of a sufficient quality to prevent
           unnecessary mismatches. If it does not conform to the specification, the data
           requester and the data provider will reconsider how the relevant data can be
           supplied. So far as possible, Fife Council only holds data which is accurate and
           up to date.

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 10.    The reporting of Data matching
   10.1. Where data matching is undertaken to detect or prevent fraud the results of data
        matching will be reported on a regular basis to the Standards and Audit
   10.2.Where data matching is undertaken to improve data quality the results of the data
        matching will be reported on a regular basis to the Information Governance

 11.    How we comply with Data Protection Principles
   11.1.Fair and lawful obtaining and processing of data:-
        a)   All forms issued by Council Services for completion by members of the public
             or employees shall include the warning that the information supplied will be
             used for data matching purposes, including the prevention and detection of
         b) All software, formulae, algorithms and techniques used in the matching
             process will be focused on data quality improvement, business improvement
             and the detection and prevention of fraud. They will be reviewed and refined
             in the light of practical experience.
         c) Anomalies highlighted by data matching undertaken for the purpose of
             identifying fraud will not be assumed to be fraudulent but will be the subject
             of detailed investigation by expert staff.

    11.2.Personal data will be held only for purposes for which the Council has a Data
         Protection Registration.
    11.3.Personal data will not be used or disclosed in any manner incompatible with the
         registered purposes.
    11.4.Data held or used will be the minimum required to carry out the matching
         exercise. Only relevant information will be downloaded from systems.
    11.5.All possible steps will be taken to ensure that data held or used is accurate and
         up to date. Practices will be refined in the light of experience.
    11.6.Data will be disposed of (see section 5.1) as soon as the purpose of the matching
         has been achieved.
    11.7.Data Subject Access
          a) On request, individuals will be supplied with information on their personal
               data, if any, which is held for data matching purposes, provided this does not
               impede any legal or statutory business process. Where any data thus
               supplied proves to be inaccurate, the data will be corrected or erased, as
    11.8.All data shall be securely stored and guarded against loss, damage or
         unauthorised access (see section 5).

 12.    The review of this code
   12.1.This Code of Practice will be subjected to review periodically.

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 13.    The complaints procedure
   13.1.Other than from employees, any complaints concerning data matching will be
        dealt with through the Council's Corporate Complaints Procedure. This will give
        individuals the chance to raise their concerns and give the Council the opportunity
        to make any necessary amendments.
   13.2.Any complaints from employees concerning data matching will be handled
        through the Grievance Procedure if they have not been resolved informally.
        Employees have the right to raise a grievance and will suffer no detriment or
        victimisation as a result.
   13.3.Anyone who considers there has been a breach of one of the principles, or any
        other provision, of the Data Protection Act is entitled to complain to the
        Information Commissioner. When the Commissioner has considered the
        complaint, the complainant must be notified of any action which the
        Commissioner proposes to take.
   13.4.More detailed information on all aspects of the Data Protection Act 1998 is
        available from the Commissioner's Office. The address is:

           Information Commissioner’s Office
           Wycliffe House
           Water Lane
           SK9 5AF
           Tel: 0303 123 1113
           Fax: 01625 524510
           Internet website:

           Information Commissioner's Office – Scotland
           93 - 95 Hanover Street
           EH2 1DJ
           Tel: 0131 301 5071
           Fax: 0131 301 5069

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                                      Data Protection Act 1998

The eight data protection principles are set out in Schedule 1, part I, of the Act, as follows:

 1.      Personal data shall be processed fairly and lawfully in accordance with the Act.
 2.      Personal data shall be obtained only for one or more specified and lawful
         purposes, and shall not be further processed in any manner incompatible with
         that purpose or those purposes.
 3.      Personal data shall be adequate, relevant and not excessive in relation to the
         purpose or purposes for which they are processed.
 4.      Personal data shall be accurate and, where necessary, kept up to date.
 5.      Personal data processed for any purpose or purposes shall not be kept for
         longer than is necessary for that purpose or those purposes.
 6.      Personal data shall be processed in accordance with the rights of data subjects
         under this Act.
 7.      Appropriate technical and organisational measures shall be taken against
         unauthorised or unlawful processing of personal data and against accidental
         loss or destruction of, or damage to, personal data.
 8.      Personal data shall not be transferred to a country or territory outside the
         European Economic Area unless that country or territory ensures an adequate
         level of protection for the rights and freedoms of data subjects in relation to the
         processing of personal data.

For further information contact:

Information Policy Team, Fife Council, Fife House, North Street, Glenrothes, KY7 5LT

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