EAST WITTERING & BRACKLESHAM PARISH COUNCIL – GENERAL PRIVACY NOTICE
YOUR PERSONAL DATA – WHAT IS IT?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual (e.g. a list of staff may contain personnel ID numbers rather than names but if you use a separate list of the ID numbers which give the corresponding names to identify the staff in the first list then the first list will also be treated as personal data). The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.
WHO ARE WE?
This Privacy Notice is provided to you by East Wittering & Bracklesham Parish Council which is the data controller for your data.
Other data controllers the council works with:
• Local authorities
• Community groups
• Charities
• Other not for profit entities
• Contractors
• Credit reference agencies
We may need to share your personal data we hold with them so that they can carry out their responsibilities to the council. If we and the other data controllers listed above are processing your data jointly for the same purposes, then the council and the other data controllers may be “joint data controllers” which mean we are all collectively responsible to you for your data. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller.
A description of what personal data the council processes and for what purposes is set out in this Privacy Notice.
THE COUNCIL WILL PROCESS SOME OR ALL OF THE FOLLOWING PERSONAL DATA WHERE NECESSARY TO PERFORM ITS TASKS:
• Names, titles, and aliases, photographs;
• Contact details such as telephone numbers, addresses, and email addresses;
• Where they are relevant to the services provided by a council, or where you provide them to us, we may process information such as gender, age, marital status, nationality, education/work history, academic/professional qualifications, hobbies, family composition, and dependants;
• Where you pay for activities such as use of a council hall or room, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
• The personal data we process may include sensitive or other special categories of personal data such as criminal convictions, racial or ethnic origin, mental and physical health, details of injuries, medication/treatment received, political beliefs, trade union affiliation, genetic data, biometric data, data concerning and sexual life or orientation.
• How we use sensitive personal data
We may process sensitive personal data including, as appropriate:
• information about your physical or mental health or condition in order to monitor sick leave and take decisions on your fitness for work;
• your racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation;
• in order to comply with legal requirements and obligations to third parties.
• These types of data are described in the GDPR as “Special categories of data” and require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.
• We may process special categories of personal data in the following circumstances:
• In limited circumstances, with your explicit written consent.
• Where we need to carry out our legal obligations.
• Where it is needed in the public interest.
• Less commonly, we may process this type of personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
DO WE NEED YOUR CONSENT TO PROCESS YOUR SENSITIVE PERSONAL DATA?
In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive personal data. If we do so, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
THE COUNCIL WILL COMPLY WITH DATA PROTECTION LAW. THIS SAYS THAT THE PERSONAL DATA WE HOLD ABOUT YOU MUST BE:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
WE USE YOUR PERSONAL DATA FOR SOME OR ALL OF THE FOLLOWING PURPOSES:
• To deliver public services including to understand your needs to provide the services that you request and to understand what we can do for you and inform you of other relevant services;
• To confirm your identity to provide some services;
• To contact you by post, email, telephone or using social media (e.g., Facebook, Twitter, WhatsApp);
• To help us to build up a picture of how we are performing;
• To prevent and detect fraud and corruption in the use of public funds and where necessary for the law enforcement functions;
• To enable us to meet all legal and statutory obligations and powers including any delegated functions;
• To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments and generally as necessary to protect individuals from harm or injury;
• To promote the interests of the council;
• To maintain our own accounts and records;
• To seek your views, opinions or comments;
• To notify you of changes to our facilities, services, events and staff, councillors and other role holders;
• To send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other new projects or initiatives;
• To process relevant financial transactions including grants and payments for goods and services supplied to the council
• To allow the statistical analysis of data so we can plan the provision of services.
• Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.
WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
The council is a public authority and has certain powers and obligations. Most of your personal data is processed for compliance with a legal obligation which includes the discharge of the council’s statutory functions and powers. Sometimes when exercising these powers or duties it is necessary to process personal data of residents or people using the council’s services. We will always take into account your interests and rights. This Privacy Notice sets out your rights and the council’s obligations to you.
We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with the use of hall rental facilities, or the acceptance of an allotment garden tenancy
Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use.
SHARING YOUR PERSONAL DATA
This section provides information about the third parties with whom the council may share your personal data. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary):
• The data controllers listed above under the heading “Other data controllers the council works with”;
• Our agents, suppliers and contractors. For example, we may ask a commercial provider to publish or distribute newsletters on our behalf, or to maintain our database software;
• On occasion, other local authorities or not for profit bodies with which we are carrying out joint ventures e.g. in relation to facilities or events for the community.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 7 years to support HMRC audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations as a public authority. The council is permitted to retain data in order to defend or pursue claims. In some cases the law imposes a time limit for such claims (for example 3 years for personal injury claims or 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
YOUR RIGHTS AND YOUR PERSONAL DATA
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
THE RIGHT TO ACCESS PERSONAL DATA WE HOLD ON YOU
At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within one month.
There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee.
THE RIGHT TO CORRECT AND UPDATE THE PERSONAL DATA WE HOLD ON YOU
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
THE RIGHT TO HAVE YOUR PERSONAL DATA ERASED
If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.
When we receive your request, we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it for to comply with a legal obligation).
THE RIGHT TO OBJECT TO PROCESSING OF YOUR PERSONAL DATA OR TO RESTRICT IT TO CERTAIN PURPOSES ONLY
You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.
THE RIGHT TO DATA PORTABILITY
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
THE RIGHT TO WITHDRAW YOUR CONSENT TO THE PROCESSING AT ANY TIME FOR ANY PROCESSING OF DATA TO WHICH CONSENT WAS OBTAINED
You can withdraw your consent easily by visiting this website https://gdpr-info.com/data-protection-contact-form/ or email.
THE RIGHT TO LODGE A COMPLAINT WITH THE INFORMATION COMMISSIONER’S OFFICE.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
TRANSFER OF DATA ABROAD
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. [Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas].
FURTHER PROCESSING
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
CHANGES TO THIS NOTICE
We keep this Privacy Notice under regular review and we will place any updates on this web page www.ewbpc.org.uk. This Notice was last updated in May 2018.
CONTACT DETAILS
Please contact us if you have any questions about this Privacy Notice or the personal data we hold about you or to exercise all relevant rights, queries or complaints at:
The East Wittering & Bracklesham Parish Council Data Protection Officer: GDPR-Info Ltd Email: dpo@gdpr-info.com
Terms and Conditions of Use
- This web site is owned and run by East Wittering and Bracklesham Parish Council
- This website was designed by Access –by Design, http://www.access-bydesign.com
- This document governs the use of the services and privacy provided on the East Wittering and Bracklesham Parish Council Website
- The East Wittering and Bracklesham Parish Council Website is committed to safeguarding your privacy online. The purpose of this document is to inform you of terms of use of the website and what personal information the East Wittering and Bracklesham Parish Council Website collects and the purposes for which it uses this information.
- Please read this document carefully.
- If you are not happy with our terms, conditions and privacy as laid out in this document, please do not use the East Wittering and Bracklesham Parish Council Website
- If you wish to contact East Wittering and Bracklesham Parish Council concerning any matter relating to your personal information then please contact us in writing.
- These terms and conditions may be modified by from time to time so please check occasionally. Continued use of the website by you will constitute your acceptance of any changes or revisions of this document that may happen.
The Website.
- All material on this website belongs to East Wittering and Bracklesham Parish Council Website or its website designers, licensors or third-party contractors.
- All images are copyrighted, either from stock image licensing, graphic design from Access –by Design (as designers) or East Wittering and Bracklesham Parish Council Website, itself.
- You may retrieve and display content from this website for your own personal, non-commercial use.
- You may not in any way make commercial or other unauthorised use, by publication, re-transmission, distribution, performance, caching or otherwise, of material obtained through this website
- You acknowledge that the original designers, Access –by Design, do not endorse the content of this site after the initial design period has expired (i.e. when the site goes ‘live’)
- You acknowledge that the original designers, Access –by Design or East Wittering and Bracklesham Parish Council Website cannot be held responsible for the contents of any website linked to from this website
- Using hyperlinks to any other service or site from this website is done at your sole risk.
Material
- Any third party website, company or organisation other than the original designer, Access-by Design that links to this web site must not: do any of the flowing;
- create a frame or any other browser or border environment around the content of this site;
- imply that East Wittering and Bracklesham Parish Council Website is endorsing it or its products or services;
- use any of East Wittering and Bracklesham Parish Council logo or images displayed on East Wittering and Bracklesham Parish Council Website web site without permission from East Wittering and Bracklesham Parish Council
- infringe any intellectual property or other right of any person;
- Be a web site that contains content that could be construed as distasteful, offensive or controversial.
- RSS may be used but under strict accreditation of source
- East Wittering and Bracklesham Parish Council Website reserves the right to request that any link in breach of these terms be removed and to take whatever other action it deems appropriate.
Copyright
- Access-by Design respects the intellectual property of others, and we ask our clients to do the same. If East Wittering and Bracklesham Parish Council Website has used copyrighted material in the ongoing development of its own site, Access-by Design cannot be held responsible for this. However, as clients are informed of copyright and the internet, we trust that it is usually done in ignorance.
- The clients of Access – by Design websites (including East Wittering and Bracklesham Parish Council) are not web designers and may make mistakes in ignorance.
- If you believe that your work has been copied and is accessible on East Wittering and Bracklesham Parish Council web site in a way that constitutes copyright infringement, or that the web site contains links or other references to another online location that contains material or activity that infringes your copyright, we would ask affected parties to simply contact East Wittering and Bracklesham Parish Council to remove offending material, rather than taking aggressive action.
- If no response can be had from East Wittering and Bracklesham Parish Council Website, please contact Access-by Design at: http://www.access-bydesign.com
Disclaimer of Warranty and Limitation of Liability
In using this website:
- You acknowledge that you are using the website at your own risk. The website is provided “as is,” and to the extent permitted by applicable law, East Wittering and Bracklesham Parish Council Website, Access –by Design and its affiliates hereby expressly disclaim any and all warranties, express and implied, including but not limited to any warranties of accuracy, reliability, title, merchantability, non-infringement, fitness for a particular purpose or any other warranty, condition, guarantee or representation, whether oral, in writing or in electronic form, including but not limited to the accuracy or completeness of any information contained therein or provided by the website
- East Wittering and Bracklesham Parish Council and Access –by Design and its affiliates have taken steps to provide a reliable, secure and fast service. However, neither East Wittering and Bracklesham Parish Council Website nor its affiliate do represent or warrant that access to the website will be uninterrupted or that there will be no failures, errors or omissions or loss of transmitted information, or that no viruses will be transmitted on the service.
- There are links on East Wittering and Bracklesham Parish Council Website to third party web sites which East Wittering and Bracklesham Parish Council Website has no control over. East Wittering and Bracklesham Parish Council Website accepts no responsibility or liability for any third party practices on third party websites. East Wittering and Bracklesham Parish Council Website advises you to carefully read 3rd party privacy statements prior to the use of any third party website.
- East Wittering and Bracklesham Parish Council Website and its affiliates shall not be liable to you or any third parties for any direct, indirect, special, consequential or punitive damages allegedly sustained arising out of;
- your access to or inability to access the website, including for viruses alleged to have been obtained from the website;
- your use of or reliance on the website or any of the information or materials available on the website regardless of the type of claim or the nature of the cause of action, even if advised of the possibility of such damages.