Privacy policy

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.

Sensitive personal data is “special categories of data” and requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.

The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the Data Protection Act 2018 (DPA 2018), UK General Data Protection Regulation (UK GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.

A description of what personal data the council processes and for what purposes is set out in this Privacy Notice.

Who are we?

This Privacy Notice is provided to you by BOLLINGTON TOWN 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

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.

How Bollington Town Council uses your personal data

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 dependents;
• Where you pay for activities such as use of a council hall or allotment rental, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;

How we use sensitive personal data

Sensitive personal data or special categories of personal data is 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.

• 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.

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);
• 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 promote transparency of council meetings;
• 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;

Use of services accessed through our website’s online facilities may require you to provide specific types of information.

Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.

Google Analytics

We use Google Analytics on our website to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect anonymous information, including the number of visitors, where visitors came from and the pages they visited.
The council will not use this information to identify individual users or to match it with further data on an individual user. Should you wish to opt out, edit the website cookie preferences.

Google’s data privacy and safeguarding data

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 sports facilities, or the acceptance of an allotment garden tenancy.

We may take photographs or video recordings of events organised by the council to post on our social media, our website, newsletters or share with the local media or other third parties for publication. In such circumstances, the council will erect signs advising of photography/videography at the event. The legal basis in which we process your personal data in these circumstances is public interest, pursued by us to promote awareness of the council’s services.

We may re-share social media posts for the purposes of communicating about local businesses, services, activities, amenities and facilities within and around Bollington. The legal basis on which we process your personal data in these circumstances is legitimate interest, pursued by us to raise public awareness of what’s available in Bollington.

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 8 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.

1. 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. Please note that this request must be made in writing to the Town Clerk.
   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.
2. 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.
3. 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).
4. 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.
5. 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.
6. 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 telephone, email, or by post
7. 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 or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Transfer of Data Abroad

We do not usually transfer personal information overseas. Any contracts with providers who might host personal information outside the European Union have appropriate clauses to ensure adequate technical and organisational security measures are in place by the provider.

[Our website and social media 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.

Use of data processors

Data processors are third parties who provide elements of our service for us. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Changes to this notice

We keep this Privacy Notice under regular review and we will place any updates on the website

This Notice was last updated in August 2022.

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 Data Controller, Bollington Town Council

Subject Access Requests must be made in writing to:
The Town Clerk
Bollington Town Hall
Wellington Road
Bollington
Cheshire
SK10 5JR
Email: [email protected]

Phone: 01625 572985

DPO: JDH Business Services Ltd