PUBLOW WITH PENSFORD PARISH COUNCIL

 Privacy and Data Protection Policy

 Policy effective from 12th June 2023

Publow with Pensford Parish Council recognises its responsibility to comply with the General Data Protection Regulations (GDPR) 2018, which regulates the use of personal data. This does not have to be sensitive data; it can be as little as a name and address.

General Data Protection Regulations (GDPR)

The GDPR sets out high standards for the handling of personal information and protecting individuals’ rights for privacy. It also regulates how personal information can be collected, handled and used. The GDPR applies to anyone holding personal information about people, electronically or on paper. Publow with Pensford Parish Council has also notified the Information Commissioner that it holds personal data about individuals.

When dealing with personal data, Publow with Pensford Parish Council staff and members must ensure that:

• Data is processed fairly, lawfully and in a transparent manner

This means that personal information should only be collected from individuals if staff have been open and honest about why they want the personal information.

• Data is processed for specified purposes only

This means that data is collected for specific, explicit and legitimate purposes only.

• Data is relevant to what it is needed for

Data will be monitored so that too much or too little is not kept; only data that is needed should be held.

• Data is accurate and kept up to date and is not kept longer than it is needed

Personal data should be accurate, if it is not it should be corrected.  Data no longer needed will be shredded or securely disposed of.

• Data is processed in accordance with the rights of individuals

Individuals must be informed, upon request, of all the personal information held about them.

• Data is kept securely

There should be protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Storing and accessing data

Publow with Pensford Parish Council recognises its responsibility to be open with people when taking personal details from them. This means that the Clerk and Parish Councillors must be honest about why they want a particular piece of personal information.

Publow with Pensford Parish Council may hold personal information about individuals such as their names, addresses, email addresses and telephone numbers. These will be securely kept at the Clerk’s Home Address and are not available for public access. All data stored on the Office computer will be password protected. Once data is not needed any more, is out of date or has served its use and falls outside the minimum retention time of Council’s document retention policy, it will be shredded or securely deleted from the computer.

Publow with Pensford Parish Council is aware that people have the right to access any personal information that is held about them. Subject Access Requests (SARs) must be submitted in writing (this can be done in hard copy, email or social media).  If a person requests to see any data that is being held about them, the SAR response must detail:

• How and to what purpose personal data is processed
• The period Publow with Pensford Parish Council tend to process it for
• Anyone who has access to the personal data

The response must be sent within 30 days and should be free of charge.

If a SAR includes personal data of other individuals, Publow with Pensford Parish Council must not disclose the personal information of the other individual.  That individual’s personal information may either be redacted, or the individual may be contacted to give permission for their information to be shared with the Subject.

Individuals have the right to have their data rectified if it is incorrect, the right to request erasure of the data, the right to request restriction of processing of the data and the right to object to data processing, although rules do apply to those requests.

Please see “Subject Access Request Procedure” for more details.

Confidentiality

Publow with Pensford Parish Council Clerk & Parish Councillors must be aware that when complaints or queries are made, they must remain confidential unless the subject gives permission otherwise. When handling personal data, this must also remain confidential.

Privacy Notice 

 When you contact us:

The information you provide (personal information such as name, address, email address, phone number, organisation) will be processed and stored to enable us to contact you and respond to your correspondence, provide information and/or access our facilities and services. Your personal information will be not shared or provided to any other third party.

The Parish Council’s Right to Process Information

General Data Protection Regulations Article 6 (1) (a) (b) and (e)

Processing is with consent of the data subject or Processing is necessary for compliance with a legal obligation or processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Information Security

Publow with Pensford Parish Council has a duty to ensure the security of personal data. We make sure that your information is protected from unauthorised access, loss, manipulation, falsification, destruction or unauthorised disclosure. This is done through appropriate technical measures and appropriate policies. Copies of these policies can be requested.

We will only keep your data for the purpose it was collected for and only for as long as is necessary. After which it will be deleted. (You may request the deletion of your data held by Publow with Pensford Parish Council at any time).

Children

We will not process any data relating to a child (under 13) without the express parental/ guardian consent of the child concerned. 

Access to Information

You have the right to request access to the information we have on you. You can do this by contacting our Data Information Officer, details below.

Information Correction

If you believe that the information we have about you is incorrect, you may contact us so that we can update it and keep your data accurate. Please contact our Data Information Officer, details below.

Information Deletion

If you wish Publow with Pensford Parish Council to delete the information about you please contact our Data Information Officer, details below.

Right to Object

If you believe that your data is not being processed for the purpose it has been collected for, you may object. To object, please contact our Data Information Officer, details below.

Rights Related to Automated Decision Making and Profiling

Publow with Pensford Parish Council does not use any form of automated decision making or the profiling of individual personal data.

Our CCTV and ANPR Systems

We operate an Automatic Number Plate Recognition (ANPR) camera system, which includes real time traffic monitoring, to record details of vehicles using public roads in order to help prevent crime, to assist the police with any enquiries and to provide evidence.

This processing is lawful and necessary for our legitimate interests or the legitimate interests of a third party.

Who we share your information with

We may disclose ANPR data in response to requests from the police and other statutory law enforcement agencies.

We do not share or sell ANPR information with any other organisation.

The Data Protection Act 2018 allows disclosure of CCTV and ANPR data to the police.

We deal with each request with on a case-by-case basis. This is to ensure that any such disclosure is lawful and in accordance to the Data Protection Act 2018.

How we look after your ANPR data

Data is stored at point of capture on the ANPR device.

We hold the data for 31 days at most on the ANPR device.

If we extract data, we will securely store it on an external hard drive only for as long as the police require and/or share it securely with the police.

Only designated individuals will have access to ANPR data held by us, and only for the purposes outlined in this privacy policy.

Our Parish Council websites

The following relates specifically to any of our websites: 

While visiting our websites you do not have to identify yourself or divulge personal information.

When we might collect your information through our websites

 We may collect information about you in the following ways, amongst others:

• • When you use or register with our website
  • If you subscribe to one of our mailing lists
  • When you use our website enquiry forms
  • When you send us an email containing your details
  • From other sources, including when you interact with us by email, phone or letter

If you choose to give us your details, you decide the amount of information you wish to provide. If you complete any of our online forms, we will provide a means to give your consent to our collecting and retaining the information you provide. Details will be stored securely on our web server and are not available for public access. All data stored on our web server will be password protected and accessible only to the Parish Council or its authorised web contractors.   

Consent and Opting-In to receive our website communications

You give your consent to us recording your information and to communicating with you in the following ways: 

1. 1. When you subscribe to our website mailing lists you provide contact information (such as your name and e-mail address), geographic information (such as your postcode), and sometimes other details about you and your interests. By subscribing, you consent to us adding your name to our mailing list. We will send you an automated email, which will provide an “opt-in” link. Your subscription to our mailing list becomes active only when you accept the “opt-in” link.

1. 1. We may add your subscription manually with your prior written consent. We will keep a record, where given, to evidence your consent.

How you can terminate or withdraw your consent to receive our website communications

Your consent will remain in effect until we receive your notice of withdrawal or until you are no longer eligible to receive communications from us, whichever occurs first.  At your own discretion, you may withdraw your consent at any time by using the unsubscribe link on any email we send to you. If we cannot provide an unsubscribe link we will provide an alternative method to unsubscribe.

 How we use geolocation data

Our websites do not automatically store or capture your personal information without your consent; but our web servers automatically capture your IP address; and the location of your computer and network.  We use geolocation data for systems administration, troubleshooting and site improvement purposes.

 How we use cookies

Our websites automatically ask you to consent to the use of cookies on the first occasion you visit them.  We use cookies to tailor your experience according to your preferences. We will only access the information that we store in your cookie file. We will not access any information stored in a cookie by other websites. Our cookies do not contain any personally identifiable information. To learn more about how we use cookies please visit www.publow-with-pensford-pc.gov.uk/cookies/.

Links to external websites

Our websites may provide links to external sites that we think may interest you. External websites are outside the scope of this privacy policy. We are not responsible for the protection or privacy of any information you provide whilst visiting them. If you use external links, you should exercise caution and look at the privacy policy applicable to the website in question. We are not responsible for the content of external websites and links to them do not necessarily imply our endorsement.

 How we might track our website communications

To analyse and evaluate the efficacy of our communications we may track and record subscriber activity. Our tracking statistics do not contain any personal information. Examples of tracked activity may include; opening and forwarding emails, clicking links in emails, times, dates and frequency of activity. 

 Keeping your website subscription up to date

We do our best to keep your personal information accurate and up-to-date. Please let us know when your contact details change or if you believe information we hold on you is incorrect or incomplete. If you wish to update your website subscription, or if you think your details are incorrect, you may amend them by using the “update your profile information” link on messages we send you or please write to or email our Data Information Officer at the address below. We will promptly correct any information you tell us is incorrect.

Conclusion

 In accordance with the law, we only collect a limited amount of information about you that is necessary for correspondence, information and service provision.  We do not use profiling; we do not sell or pass your data to third parties. We do not use your data for purposes other than those specified. We make sure your data is stored securely. We delete all information deemed to be no longer necessary. We constantly review our Privacy Policy to keep it up to date in protecting your data. (You can request a copy of our policies at any time).

Complaints

If you have a complaint regarding the way your personal data has been processed you may make a complaint to Publow with Pensford Parish Council, Data Information Officer, details below and the Information Commissioner’s Office casework@ico.org.uk  Tel: 0303 123 1113.

Data Information Officer

Helen Richardson, Parish Clerk

Publow with Pensford Parish Council

10 Watts Corner

Glastonbury

BS6 8FD

 

Phone: 01458 741336

Mobile: 07899 970173

Email: clerk@publow-with-pensford-pc.gov.uk