Version Control:
Document Name	General Privacy Notice
Version	V1
Author	Lindsey Wood, Parish Clerk, Aubrey Colman
Date approved by Council	4.6.18
Revised date

Who are we?
This Privacy Notice is provided to you by West Knoyle Parish Council  which is the data controller for your data.

West Knoyle Parish Council is registered as a “Data Controller” with the Information Commissioner’s Office Registration Number A8355614

The council is fully committed to protecting your privacy when you use our services. We comply with the General Data Protection Regulation (GDPR).

We ensure that your personal data is processed fairly, kept safe and secure and retained for no longer than is necessary.

The Privacy Notice explains how we use information about you and how we protect your privacy.

West Knoyle Parish Council does not require to appoint a Data Protection Officer but has appointed a Data Controller who is Mrs. Lindsey Wood, Parish Clerk.

If you have any concerns or questions about how we look after your personal information please email the Data Controller.

What is the lawful basis for processing your personal data?  

West Knoyle Parish Council is a public authority and has certain powers and obligations. Most of your personal data is processed for compliance with legal obligations which include the discharge of the council’s statutory functions and powers. Where there is no statutory duty or power the Council relies on the consent of the individual.

In order to register, receive and use Council services, the Council needs to collect and use personal information from you. Further the Council needs to collect and use personal information about people with whom it works in order to operate and carry out its functions, this may include councillors, contractors, suppliers, external partners and agencies who are involved in delivering services on their behalf. In addition the Council may require by law to collect and use information in order to comply with the requirements of central Government.

The personal information that we collect from you must be handled and dealt with properly however it is collected, recorded and used whether it is on paper, in computer records or recorded by other means.

We will hold this for as long as it is needed for the service that you have requested and remove it when that purpose has been met.

The Councils Right to Process Information

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

Processing is with the 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 case
exercise of official authority vested in the controller

 

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, video, email address or address).  Identification can be made 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 rights such as the Human Rights Act.

Other data controllers the council works with:

• Local authorities
• Community groups
• Charities
• Other not for profit entities
• Contractors/suppliers

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, photograph, videos;
• Contact details such as telephone numbers, addresses, and email addresses;
• Where you pay for activities such as use of a council premises, recreational facilities, open space bookings, burial plots, allotments, financial identifiers such as bank account numbers, payment/transaction identifiers, policy numbers, and claim numbers.

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 from loss, misuse, unauthorised access and disclosure

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 to process and the reason we need it, so that you can carefully consider whether you wish to consent.

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,
sometimes the use of your personal data requires your consent. To ensure we can use your data we will need your consent.
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;
• 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.

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, 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.

• • 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 telephone, email, or by post (see Contact Details below).  You will be asked to provide identification.
  • 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.

Security and performance
We use a third-party service to maintain the security and performance of our website
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Use of Cookies
This website site currently uses cookies as part of its basic functionality, to anonymously record numbers of visitors to the site and which pages they visit, and for features that intergrate third-party services such as social media feeds.
Third Party Organisations
We will never, sell, rent or trade your personal information to any third party for marketing or any other reasons.
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.
Data Protection Officer (DPO)
West Knoyle Parish Council is not required to appoint a DPO, but has appointed a Data Controller which is the Parish Clerk
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on this web page www.https://westknoyle.org.  This Notice was last updated in June 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 Data Controller,
Mrs. Lindsey Wood, Parish Clerk
West Knoyle Parish Council,
Duchy Manor,
Springfield Road,
Mere,
Wiltshire.
BA12  6EW
Email: lindseywood@merewilts.org