ADOPTED MARCH 2023
Introduction
1. Your personal data – what is it?
2. Council information
3. Legal basis for processing personal data
4. Sharing your personal data
5. How long do we keep personal data
6. Your rights and your personal data
7. Use of cookies
8. Transfer of data abroad
9. Further processing
10. Changes to this policy
11. Contact details
Introduction
This policy has been issued by Corringham Parish Council in order to comply with the requirements of the General Data Protection Regulations (GDPR) which came into force in May 2018.
Corringham 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.
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. Corringham Parish Council has notified the Information Commissioner that it holds personal data about individuals.
1. 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, photograph, videos, email address or postal address). Identification can be by directly using the personal data itself or by combining it with other information which helps to identify a living individual.
The processing of data is governed by legislation to personal data which applies in the United Kingdom including the General Data Protection Regulations (the ‘GDPR’) and other local legislation relating to personal data and rights such as the Human Rights Act.
2. Council Information
This privacy policy is provided to you by Corringham Parish Council which is the data processor for your data.
The Council’s address is:
Clerk to the Council
Corringham Parish Council
c/o 22 Middle Street
Corringham
DN21 5QS
We will always respect the privacy of individuals who browse our website and leave contact details with us. Please read our privacy policy carefully as it contains important information about what to expect when we collect personal information about you and how we will use (“process”) that data. Corringham Parish Council does not track your activity as an individual.
The Council will process some or all of the following personal data where necessary to perform its tasks:
i. Titles, names, aliases, photographs
ii. Contact details such as telephone numbers, addresses and email addresses
The council will comply with data protection law. This says that the personal data we hold about you must be:
i. Used lawfully, fairly and in a transparent way.
ii. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
iii. Relevant to the purposes we have told you about and limited only to those purposes.
iv. Accurate and kept up to date.
v. Kept only as long as necessary for the purposes we have told you about.
vi. Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data from loss, misuse, unauthorised access and disclosure.
We use your personal data for some or all of the following purposes:
i. 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;
ii. To confirm your identity to provide some services;
iii. To contact you by post, email and telephone;
iv. To prevent and detect fraud and corruption in the use of public funds and where necessary for the law enforcement functions;
v. To enable us to meet all legal and statutory obligations and powers including any delegated functions
vi. To promote the interests of the Council;
vii. To maintain our own accounts and records;
viii. To seek your views, opinions or comments;
ix. To notify you of changes to our facilities, services, events and staff, councillors and role holders;
x. 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;
xi. To process relevant financial transactions including grants and payments for goods and services suppled to the Council.
3. What is the legal basis for processing your personal data ?
The Council has always required a legal basis to processing personal data. The General Data Protection Regulations include five lawful basis for local Councils. It is possible for more than one to apply at the same time. The five basis are:
i. Compliance with legal obligations: The Council is a Parish Council and has certain powers and duties. 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 policy sets out your rights and the Council’s obligations to you in detail.
ii. Contractual Necessity: We may also process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.
iii. Consent: Sometimes the use of your personal data requires your consent. On these occasions we will first obtain your consent to that use.
iv. Vital Interest: It is possible to process personal information to protect an individual without their consent e.g. in a life or death situation where emergency contact information is needed.
v. Public Interest: When the Parish Council is acting in the public interest, personal data may be processed if it is necessary to undertake the tasks.
4. Sharing your personal data:
The Council will implement appropriate security measures to protect your personal data. This section of the Privacy Policy provides information about the third parties with whom the Council may share your personal data. These third parties also 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 may need to share your data with some or all of the following (but only when necessary):
i. West Lindsey District Council
ii. Contractors
We may ned to share your personal data we hold with them so that they can carry out their responsibilities to Corringham Parish Council. If we work together for a joint purpose that involves your personal data we are joint data controllers. This means those involved are all responsible to you for how we process your data. If there is no joint purpose then each data controller is independent and is individually responsible to you.
5. 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 current best practice to keep financial records for a minimum period of eight 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 a personal injury claim 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.
6. 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.
i. The right to be informed – e.g. through this policy.
ii. The right to access personal data we hold on you. At any time, you can request the data we hold on you as well as why we have it, who has access to it and where it was obtained from. We will respond to requests within one month of receiving them. There is no charge for the first request.
iii. 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 we will update it.
iv. The right to have your personal data deleted – If you feel we should no longer be using it or are using it unlawfully. When we receive your request we will then either confirm that it has been deleted or explain why it cannot be deleted e.g. because we need it to comply with a legal obligation.
v. The right to object to processing of your personal data or to restrict it to certain purposes only – You can request us to stop processing your data or ask to restrict what we do with it. When we receive your request, we will let you know if we are able to comply or if we have a legal obligation to continue.
vi. The right to data portability – You can request that we transfer data to another controller. Where this is feasible, we will do this within one month of receiving your request.
vii. The right to withdraw your consent – To the processing at any time for any processing of data to which consent was obtained. Please use the contact details below to do this.
viii. 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 to casework@ico.org.uk or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
7. Use of cookies
Our website is powered by Jadu. Cookies are only used to ensure it runs correctly. They are not used for tracking purposes but just to hold site information for the duration of your browsing session. We do not use any third party, tracking, advertising cookies.
8. 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 United Kingdom/European Union. Our website is accessible from overseas so on occasion some personal data (for example in a village magazine) may be accessed from overseas.
9. Further Processing
If we wish to use your data for a new purpose not covered by this privacy policy, then we will provide you with a Privacy 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 prior consent to the new processing.
10. Changes to this policy
We keep this Privacy Policy under regular review and we will place any updates on the Village Council website.
11. Contact Details
Please contact us if you have any questions about this Privacy Policy or the personal data we hold about you or to exercise all relevant rights, queries or complaints:
Data Processor
Corringham Parish Council
22 Middle Street
Corringham
DN21 5QS
e-mail – clerkcorringhampc@gmail.com