Information governance

Here you will find information about the council's policies covering data protection, freedom of information, environmental information regulations and records managements.

Information governance is the framework of law and best practice that regulates the manner in which information (including, but not restricted to information relating to and identifying individuals) is managed, obtained, handled, used and disclosed.

Northumberland County Council recognises the importance of maintaining an appropriate and robust system of information governance management, so as to underpin and support the council in the exercise of its functions, protect privacy and confidentiality and maintain public trust.

This page provides guidance about how the council deals with data protection, freedom of information, environmental information regulations and records management.

Information governance is regulated by the Information Commissioner’s Office.
Personal information retained by, or submitted to, Northumberland County Council is governed and protected by the General Data Protection Regulation 2018 (GDPR).

This means only necessary information will be kept accurately, safely and securely. Northumberland County Council is registered on the public register of data controllers, with the registration number Z1727733.  Please direct all data protection queries to informationgovernance@northumberland.gov.uk.
Please click this link to access the form to report a security incident or data breach in line with the Council's Security Incident and Data Breach Policy.

Northumberland County Council is the data owner of the information collected by us.  The information provided by you will only be used for the purposes of carrying out an investigation into the incident/breach and for any follow up action such as for the investigation of a crime and/or disciplinary actions.

The information will be held securely with access restricted to the Information Governance Team who can be contacted via informationgovernance@northumberland.gov.uk.

We will not provide your personal information to any other external organisation or individual unless it is lawful to do so, e.g. the prevention and/or detection of crime, or where you have provided explicit consent to do so. 

Personal data will be destroyed in line with the council’s retention schedule. The Council’s retention schedules and full Privacy Notice can be found on this website.
All organisations must adhere to six principles in relation to personal information.

We ensure your personal information is:
  • processed lawfully, fairly and in a transparent manner in relation to individuals;
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
 
The seventh principle is in relation to accountability. We must comply with the GDPR and be able to demonstrate our compliance
The GDPR provides the following rights for individuals:

The right of access - GDPR Article 15
Which gives you the right to know whether personal data about you is being processed, and if so, access to that information.

The right to rectification - GDPR Article 16
When personal data is inaccurate, you have the right to have inaccurate data corrected or completed if it is incomplete.

The right to erasure - GDPR Article 17
This gives you the right to have personal data erased.  It is otherwise known as the right to be forgotten.  This is not an abolute right and only applies in certain circumstances.  It does not apply if personal data is required for the council to carry out a statutory task.

The right to restrict processing - GDPR Article 18
This gives you the right to restrict the processing of your personal data in certain circumstances however is not an absolute right. This means that you can limit the way that we use your data as an alternative to requesting the erasure of your data.

The right to be informed - GDPR Article 19
You have the right to be informed about the collection and use of your personal data. We must provide you with information including: your purposes for processing your personal data, how long we will retain that personal data, and who it will be shared with.  We would usually call this ‘privacy information’ which is provided at the time we collect your personal data.

The right to data portability - GDPR Article 20
This allows you to obtain and reuse your personal data for your own purposes across different services.
It allows you to move, copy or transfer it, without affecting its usability, easily from one IT environment to another in a safe and secure way.

The right to object - GDPR Article 21
This gives you the right to object to the processing of your personal data in certain circumstances.  You have an absolute right to stop your data being used for direct marketing.

Rights in relation to automated decision making and profiling - GDPR Article 22
This right means that where a decision is made solely by automated means without any human involvement or where there is the automated processing of personal data to evaluate certain things about you with legal or similar effects, you have a right to request this is reviewed again with human involvement.

If you exercise any of your rights under data protection law, we must respond as quickly as possible, but no later than one calendar month, starting from the day after we receive the request.

However, if your request is complex or you make more than one, the response time may be a maximum of three calendar months, starting from the day after receipt.

Further information on these rights can be found on the Information Commissioner’s website which is accessible here.
This includes data that can be used to identify a living person, either on its own or when referenced with data held by an organisation. This includes data such as your name, address, date of birth and council tax reference number. Data relating to more than one individual, such as council tax records, can also be personal.

Information identified as special category data under the GDPR includes; ethnic origin, religious belief, political belief, health data and sexuality. This information is subject to additional rules and safeguards. Photographs taken at public events and venues for the promotion of council services may also be included. If you can be identified in these, we ask permission before publication.

Information is also used for statistical and research purposes but does not include personal data.
This includes collecting, storing, accessing, changing and destroying held information. The volume of data held depends on services used. There may be times we are required to share information between departments in order to provide the required service to you.

You have a right to request we stop processing your personal information by writing and explaining your reasons. We must respond no later than one calendar month, starting from the day after we receive your request, advising you of the outcome of your request.
Your information can be processed or accessed by employees and elected members to perform their duties. They only access what is appropriate for the required purpose. Personal information is not passed to third parties without your knowledge, unless there is a legal reason to do so. 
Some data may be withheld if it also refers to others or may compromise crime prevention. In this instance, we will inform you about the nature of the data we keep and why.

Generally, members of the public are prohibited from accessing data about others. In certain circumstances, this may be permitted if you have written permission from the subject of the data or if you are a parent seeking information from your child’s social care or education records. In such cases, we may ask for additional information before data can be released.

By law, the council is also required to protect the public funds it administers, and therefore may share information provided with other relevant bodies in order to prevent and detect fraud.
You do not have the right to access personal information about other people, unless:
  • you have written consent to request the records
  • you are a parent requesting to see your child's social services or education records
  • you have written authority to act on behalf of someone
We have a right to request further information before we adhere to the request or may refuse to provide information if there is a duty of confidentiality to the data subject. 
Those wishing to access adoption record information should contact our adoption support service for advice and guidance.
You can request to access your information at any time by printing out and completing the subject access request form. You can also contact us to request a form be posted to you. 

In most cases we cannot charge a fee to comply with a subject access request, however, where the request is considered manifestly unfounded or excessive we may charge a “reasonable fee” for the administrative costs of complying with the request.

We can also charge a reasonable fee if you request further copies of your data following a request.  We must base the fee on the administrative costs of providing further copies. 

If we have doubts about your identity we may ask you for more information reasonably needed to verify your identity and to locate the data. Where this is the case the period for responding to the request begins when we receive the additional information.

This means you should provide us with proof of your identity and information which will assist the data controller in locating your personal data.  This may include a driving licence, passport or a recent utility bill. At least one of the documents must contain a photograph and at least one must contain a home address. To assist us in locating the personal data 
any relevant reference numbers, account numbers, dates of correspondence and details of employees you have dealt with.  

You can post your documents to us at the address provided on the form or can make an appointment with our Information Governance Team to come in to County Hall and see someone.  Please note we will not be able to see you without an appointment.

Once your request has been processed we will endeavour to respond to you within a month.
Adult social care is managed for the Council by Northumbria Healthcare Foundation Trust therefore those wishing to access adult social care records should submit an access to records application direct to the Trust.

Applications should be made to:

Information Governance Team,
Computer Services Department,
Northumbria Healthcare NHS Foundation Trust,
Northumbria House,
Silver Fox Way Cobalt Business Park,
Newcastle upon Tyne,
NE27 0QJ

Click here for Northumbria's website, you can find their application form under the Your rights section.
The occupational health service delivered by Northumbria Healthcare NHS Foundation Trust has been redesigned to offer more appointments and acess to a multidisciplinary team of healthcare professionals in a timely and convernient way.

Former and current council staff wishing to access occupational health record information should contact the occupational health service on 01670 529213 for advice and guidance.

The consent form for release of occupational health records can be downloaded here.  The completed form should be sent to the occupational health service, their postal address is:

Occupational Health Service
Wansbeck General Hospital
Woodhorn Lane
Ashington
NE66 9JJ
Schools are independent data controllers and, therefore, responsible for the information they hold.

Schools retain information on pupils in order to support their teaching and learning, to monitor and report on progress and to provide appropriate pastoral care. This includes contact details, national curriculum assessment results and attendance information.

Other data, including ethnicity, special education needs and relevant medical information is also retained. Occasionally, schools are required to provide this data to various government agencies.
The Freedom of Information Act (2000) became fully effective from 1 January 2005, giving you the right to request information from the council.

A great deal of information is already available and you do have a right of access to information retained.

However, we may refuse access in certain circumstances. These are covered in the act and protect against the disclosure of information that would harm commercial interests, information provided in confidence, personal information and other important interests for the council.

Requests for information should be directed to the Information Governance Team.
All requests should be in writing and contain as much information as possible to enable us to supply you with the precise details needed. If you have any difficulty with this, please call 0345 600 6400.

Written requests can be made to:

Information Governance Team
Northumberland County Council
County Hall
Morpeth
Northumberland
NE61 2EF

Email: FOI@northumberland.gov.uk
  • You must include your name and contact details.
  • You should be as precise as possible when making a request.
  • You do not need to give a reason.
  • You should not request personal information. Click here to find out why.
  • You may need to pay a fee. If so, you will be notified in advance.
  • You should tell us how you want to receive the information and we will try to provide information in this format.
  • to supply information, wherever possible, and to do so within 20 working days of you making the request
  • to supply all requested information, unless it falls within an exemption in the act. If this is the case, you will be informed.
You have a right to an internal review if we cannot supply the requested information. To do this, please write to the Information Governance Team at the above address, either via email or letter.

Please note that vexatious and repeated requests, or applications made with the aim of frustrating the council’s operations may be refused. We may also refuse to supply information where it is considered to be exempt under the act.

For more information on these exemptions, or any part of the act, please contact us:

Information Governance Team
Northumberland County Council
County Hall
Morpeth
Northumberland
NE61 2EF

Or, alternatively:

The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Who can request information?
Anyone can make a request.

What qualifies as a valid request for information?
Requests made in writing, via post or email, qualify. However, it must state the full name of the person requesting, as well as an address for correspondence and a description of required information.

Do we need to comply with the Freedom of Information Act?
We are a public authority, therefore the act applies to us. As defined in the act itself, this includes companies wholly owned by us.

How do we comply with the Freedom of Information Act?
We are obligated to provide information through our publication scheme and under general rights of access.

What is a publication scheme?
This classifies what information we are expected to publish and what we can charge. There are seven classes of information. Who has to have a publication scheme?
All public authorities are required to have a publication scheme.

What should we do to maintain our publication scheme?
Information should be reviewed/maintained by authors on a regular basis.

How quickly should we respond to a request under the act?
We should respond within 20 working days of the receipt of request, advising whether we hold the information. In some cases we must issue a refusal notice stating under which exemption we have refused and why. If we are required to consider the public interest test, then we must also provide that reasoning.

What is the public interest test?
With regards to qualified exemptions, information still may be withheld if we consider the public interest in withholding is greater than the public interest in disclosing.

What should we do if we do not hold the information?
We advise if we don’t hold the information. The information may have been destroyed in line with retention schedules or it may be held elsewhere.

In what circumstances may we refuse a request for information?
We can refuse a request where an exemption applies, where the cost of complying exceeds the appropriate cost limit or if it is vexatious or repeated.

What is the cost limit for a request?
The cost limit for requests is £450. We calculate the cost of staff time at £25 per hour, per person and look at:
  • dealing with the information
  • whether we hold the information
  • locating and retrieving it
The time taken to consider exemptions is not included.

What happens when the cost limit is not exceeded?
When a cost limit is not exceeded, the only charges we pass on are those associated with providing the information, such as photocopying and postage.

What happens when the cost limit is exceeded?
If the cost to comply with requests exceeds the cost limit, then we do not need to comply with the request. If this is the case, we will issue a refusal notice. We may ask for refined information to bring it within the cost limit or may provide the information without charge. This is at our discretion.

How can we request payment?
We issue a fees notice within 20 working days from receipt of request. If we issue this, then the time for responding stops until the payment is cleared. If we do not receive the fee within three months, we are not required to comply with the request.

What is a vexatious request?
A request likely to cause distress, disruption or irritation without justified cause. It is the request that is vexatious, not the person who requests, or the consequences of the disclosure. History and context is always taken into account.

What is a repeated request?
Where a request has been complied with, we are not obliged to comply with identical or substantially similar requests from the same person, unless reasonable time has passed. The interval considered is 60 working days.

Does the Freedom of Information Act apply to personal data?
The act gives people the right to access information held by us but not a right to their own personal data.
Whilst a great deal of information is readily available on our website, the council wishes to be more transparent. Therefore, we are now publishing our FoI questions and answers backdated to August 2017. Please note, information may be redacted or withheld in line with the exemptions covered in the Act.

New questions and their answers will be added on a regular basis and can be viewed here.
This publication scheme advises the public about how to get the information they seek from the council.

This model publication scheme has been prepared and approved by the information commissioner. It may be adopted without modification by any public authority without further approval and will be valid until further notice.
This scheme commits an authority to make information available to the public as part of its normal business activities. Information covered is included in the classes of information mentioned below, where this information is held by the authority.

The scheme commits an authority:
  • to proactively publish, or otherwise make available, information. This includes environmental information, held by the authority, and falls in with the classifications below.
  • to specify information held by the authority and falls within the classifications below
  • to proactively publish, or otherwise make available, information in line with the statements contained within this scheme
  • to produce and publish the methods by which the specific information is made routinely available, so it can be identified and accessed by members of the public
  • to regularly review and update the available information under this scheme
  • to produce a schedule of fees charged for access to information made proactively available
  • to make the publication scheme available to the public
  • to publish any dataset held by the authority that has been requested, and any updated versions it holds, unless the authority is satisfied that it is not appropriate to do so
  • to publish the dataset, where practicable, in an electronic form that is capable of re-use, and if any information in the dataset is a relevant copyright work and the public authority is the only owner
  • to make the information available for re-use under a specified licence
The underlined terms are defined in 11(5) and 19(8) of the Freedom of Information Act.
Who we are and what we do
We deal with organisational information, locations and contacts, constitutional and legal governance.

What we spend and how we spend it
We provide financial information relating to projected and actual income and expenditure, tendering, procurement and contracts.

What our priorities are and how we are doing
We give details of strategy and performance information, plans, assessments, inspections and reviews.

How we make decisions
We tell you of policy proposals and decisions, decision-making processes, internal criteria and procedures, and consultations.

Our policies and procedures
We disclose current written protocols for delivering our functions and responsibilities.

Lists and registers
We provide information held in registers required by law and other lists and registers relating to the functions of the authority.

The services we offer
We give you advice and guidance, booklets and leaflets, transactions and media releases.

What we don't disclose
The classes of information will not generally include:
  • information, the disclosure of which is prevented by law, or exempt under the Freedom of Information Act, or is otherwise properly considered to be protected from disclosure
  • information in draft form
  • information that is no longer readily available as it is contained in files that have been placed in archive storage, or is difficult to access for similar reasons
The authority will indicate clearly to the public what information is covered by the scheme and how it can be obtained.

Where it is within the capability of a public authority, information will be provided on a website. Where it is impracticable to do so, or when an individual does not wish to access information through a website, the authority will indicate how it can be obtained and provide it by other means.

In exceptional circumstances, some information may be available by viewing in person. Where this is specified, contact details are provided. Appointments to view the information will be arranged.

Information will be provided in the language in which it is held, or in another language that is legally required. Where an authority is legally required to translate information, it will do so.

Obligations under disability and discrimination legislation, or any other legislation, to provide information in other formats will be adhered to when providing information in accordance with this scheme.
The purpose of this scheme is to make the maximum amount of information readily available at minimum inconvenience and cost to the public. Charges made by the authority for routinely published material will be justified, transparent and kept to a minimum.

Material published and accessed via a website is provided free of charge but charges may be made for information supplied by other means subject to a charging regime, specified by parliament.

Charges may be made for actual disbursements incurred, such as:
  • photocopying
  • postage and packaging
  • the costs directly incurred as a result of viewing information
Charges may be made for information provided under this scheme where they are legally authorised. They are in all circumstances, including general principles of the right of access to information held by public authorities, justified and in accordance with a published schedule of fees, which is readily available to the public.

Charges may also be made for making datasets (or parts thereof) that are relevant copyright works available for re-use. These charges will be in accordance with either regulations made under section 11B of the Freedom of Information Act, or other enactments.

If a charge is to be made, confirmation of payment due will be given before the information is provided. This may be requested prior to provision of the information.
Information held by a public authority that is not published under this scheme can be requested in writing, when its provision will be considered in accordance with provisions of the Freedom of Information Act.
A publication scheme dictates the information that a public authority should routinely make available by committing the council to publish information to the public as part of its normal business activities.

The Information Commissioner’s Office has developed a model publication scheme for local authorities, classifying the information at a high level and stating what it expects to be routinely provided.
Northumberland County Council is committed to:
  • proactively publishing, or otherwise making available, information, including environmental information, as well as information routinely made available so that it can be easily accessed by members of the public
  • specifying the information which falls into the classes below
  • reviewing and updating information on a regular basis
  • making the scheme available to the public
Classes of information
Here you will find information pertaining to the structure of the council, alongside opening times, councillor information and contact details.
The environmental information regulations 2004 allow members of the public to request environmental information from public authorities such as Northumberland County Council.

The information covered can be divided into the following six main areas:
  • the state of the elements of the environment, such as air, water, soil, land, fauna (including human beings)
  • emissions and discharges, noise, energy, radiation, waste and other such substances
  • measures and activities such as policies, plans and agreements affecting or likely to affect the state of the elements of the environment
  • reports, cost benefit and economic analyses
  • the state of human health and safety, contamination of the food chain
  • cultural sites and built structures (to the extent they may be affected by the state of the elements of the environment)
If an exception listed below applies, we may choose to refuse the request and withhold the information. All exceptions are subject to the public interest test, meaning we must explain why the public interest test in withholding information outweighs the public interest in disclosing information.

Exceptions include denying disclosure because:
  • the information is not held by the authority
  • the authority cannot ascertain the nature of the request
  • the request is 'manifestly unreasonable'
  • the information is 'unfinished or in the course of being completed'
Certain exceptions require proof of the harm that would be caused by releasing the information. Information can, for example, be withheld if release would adversely affect:
  • defence, international relations, national security and public safety
  • the course of justice or the confidentiality of proceedings
  • intellectual property rights
  • 'interests of the supplier of the information', where supply was voluntary
  • commercial confidentiality
  • the protection of the environment
Personal information will be dealt with under the Data Protection Act 1998. Personal information of a third party may be exempt if release would breach the data protection principles.
If we receive a request from a member of the public for environmental information on any of the areas mentioned above, we are legally obliged to provide it, usually within 20 working days. If we withhold the information requested as a result of one of the exceptions, we must explain why and give the relevant reasons for refusal.

The council may charge a reasonable amount for some requests.
We obtain, create and manage a large amount of information relating to council services, customers and partners.

We are committed to both the concepts of transparency and open government but recognise the importance of protecting the privacy of our customers. We intend to achieve this by ensuring we have clear, understandable rules about the information we collect, hold, share and dispose of.

Our aim is to ensure we have the correct information, allowing us to improve customers’ service and by managing that information effectively and efficiently, to provide the best value services for customers.

These pages are intended to provide information about how the council manages records and information and our policies and standards governing how we obtain, create, keep, share, use and dispose of information, as well as details about how long we keep information, how we plan to improve information management and how performance is monitored.

Having a records management and disposal policy, and records retention schedule, are a requirement of the lord chancellor’s code of practice on the management of records, issued under section 46 of the Freedom of Information Act 2000.
When a member of staff declares a document is a record of a particular business activity, task or project, a decision must be made regarding how long that record should be kept. How long the council keeps information before disposal depends on the type of information, legal requirements and business need.

The length of retention for a record will often be decided by legislation, administrative need or evidential need and the details of this period are listed on a retention schedule that staff can consult when trying to determine how long they should keep a record.

Some retention schedules may include disposal instructions for records that have reached the end of their administrative life. The records management and disposal policy, and records retention schedules, may also include instruction for transferring records to the archive service for permanent preservation.
The council’s records management policy, and records retention schedules, are a work in progress but can still be used to assist staff preparing records for storage. The policy and schedule are reviewed regularly.
The council’s schedules are based on a list of statutory and discretionary business functions, activities and processes. Each specific retention and disposal policy applies to all records that support business activity and process described in the schedule. The retention policies contained in the schedules apply to all records and data, irrespective of media or format, the system and storage location in which they are held.

Our schedules have been developed by the information governance office in collaboration with services responsible for the functions, services needing to use/access records and legal services. These are the definitive policy for retaining records within Northumberland County Council

Please note that due to coming structure changes the following documents will be reviewed and may change.

Corporate resources Fire & Rescue Local services Wellbeing and community health services
Northumberland County Council aims to be transparent and provide accessible information to individuals about how their personal data will be used through a privacy notice.

Our full privacy notice is available here.

In addition to this notice, you may also be provided with a service specific privacy notice where appropriate. Consent can be withdrawn at any time by contacting 01670 623599.

We keep our privacy notice under regular review. This privacy notice was last updated on 30 April 2018.
This section tells you about how we use information on children and young people in line with the Data Protection Act 1998.

We use personal data and information about children and young people to enable us to:
  • carry out specific functions for which we are responsible
  • get statistics which inform our decisions (for e.g. about school funding and performance targets).
The statistics are used in such a way that individual children can’t be identified.
Schools in England are legally required to pass certain information for pupils aged 13 to 19 to the provider of youth support services in their area.

The school must provide the pupil’s:
  • name
  • date of birth
  • address and name of parent(s) or guardian(s)
  • any further information relevant to the support services' role
Primary care trusts (PCTs) use information about pupils for research and statistical purposes, to develop, monitor and evaluate the performance of local health services. These statistics don’t identify individual pupils. 

It’s necessary for certain health information about children to be kept for a set period of time, as determined by the Department of Health. Health information could include height and weight and requires the primary care trust to maintain children's names and addresses for this purpose.

PCTs may also provide both us and individual schools with aggregated health information, which does not identify individual children.
We hold information about young people living in our area, including their education and training history, to support the provision of their education up to the age of 20. Information is held beyond this age for those with a special education need or disability. 

Educational institutions and other public bodies, including the Department for Education (DfE), police, probation and health services, may pass information to us to help us to do this.

We share some of the information we collect with the DfE to enable them to:
  • produce statistics
  • assess our performance
  • determine the destinations of young people after they have left school or college
  • evaluate government funding programmes
We may also share information with post-16 education and training providers to secure appropriate support for them. We may also share data with educational establishments, which shows what their pupils go on to do after the age of 16.
For children under 16, a parent or guardian can ask that no information other than their child's name, address and date of birth (or their own name and address) be passed to a local authority or youth support services provider. This right transfers to the child on their 16th birthday. 

Pupils and/or a parent/guardian will need to inform the school if this is what they wish.
Northumberland Supporting Families Partnership aims to help families who face multiple and complex problems through existing services and through intensive family support.
Your child's early years setting will collect information from you, and may receive information about your child from a previous school or setting. The law requires the setting to pass some of this information (and personal data) to Northumberland County Council and the Department for Education (DfE).

Northumberland County Council holds this personal data and uses it to:

·         Ensure that the early years setting receives appropriate funding, including supplementary payments for
          children with special educational needs
·         Meet funding requirements for early years places in Northumberland
·         Ensure there are sufficient early years places in Northumberland to support your child's teaching and
          learning
·         Assess how well the early years setting is doing
·         Ensure that the setting is administrating the funding or free entitlement appropriately
·         Enable us to carry out other specific functions for which we are responsible, such as school admissions
          and children's centres

Access to information is conducted on a strictly need to know basis. We hold the information securely and confidentially. We may securely share the information across the council or with our commissioned partners. We retain information according to our document retention policy before we securely dispose of or delete the information from our electronic systems.

Right of access to personal information
You may make a request to Northumberland County Council for any personal information we hold about you. This will need to be made in writing. Further information can be found in our data protection section above. If you want to see a copy of any information held by the setting about you or your child, please contact them directly.