Data 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 from 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. 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 (GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.
This Privacy Notice sets out what personal data the council processes and for what purposes.
Queen’s Park Community Council will comply with data protection law. This law 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. This includes ensuring that appropriate technical and security measures are in place to protect your personal data from loss, misuse, unauthorised access and disclosure.
We may use your personal data for some or all of the following purposes:
- To help us deliver public services. This includes helping us understand residents’ needs in order to provide the services that you request, to understand what we can do for you, and to inform you of other relevant services;
- To confirm your identity for the provision of services;
- To contact you by post, email, telephone or using social media;
- To help us to monitor our performance in providing services to residents, and to allow the statistical analysis of data so we can plan and improve services;
- To prevent and detect fraud and corruption in the use of public funds and where necessary for the purposes of law enforcement;
- 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 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 activities and services of the council and to notify you of changes to our facilities, services, events and staff, councillors and other role holders;
- To maintain our own accounts and records;
- To seek your views, opinions or comments;
- 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.
What kinds of personal data do we process?
The council will process some or all of the following personal data where necessary to perform its tasks:
- Names, titles, 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, nationality, education/work history, academic/professional qualifications, ethnic origin, interests (e.g. in volunteering), family composition, and dependants;
- Where you pay for activities or services, or we pay you for activities or services – financial identifiers such as bank account numbers and payment or transaction identifiers.
How we use sensitive personal data
Sensitive personal data requires high levels of protection and we need to have full justification for collecting, storing and using it. We may process sensitive personal data in certain circumstances, including:
- to monitor compliance with equal opportunities legislation and duties
- to comply with legal requirements and obligations to third parties
- in limited circumstances, with your explicit written consent
- where necessary in order to carry out our legal obligations
- where it is needed in the public interest.
In exceptional circumstances, 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 in a position to give your consent, or where you have already made the information public.
Do we need your consent to process your sensitive personal data?
In certain 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.You have the right to withdraw that consent at any time by contacting QPCC.
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 legal obligations 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. Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use.
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 performing at a festival, or the acceptance of an allotment garden tenancy.
Personal data that is shared with organisations
This Privacy Notice is provided to you by Queen’s Park Community Council which is the data controller for your data. The council works with other data controllers, including:
- suppliers and contractors. For example, we may ask a commercial provider to publish or distribute newsletters on our behalf, or to maintain our website;
- other local authorities, housing associations or other not for profit bodies with which we are carrying out joint ventures e.g. in relation to facilities or events for the community.
We may need to share personal data with these other data controllers so that they can carry out their roles in relation to our work. 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.
If we are processing your data jointlywith other data controllers 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 what is done with your data. Where your data is being processed independently by any data controller then each is independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to make a complaint, you should do so directly to the relevant data controller.
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 it is being used unlawfully, 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 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).
- 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. Note that the QPCC website is also accessible from overseas which means that some personal data (for example in a newsletter) could be accessed from overseas.
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. Updates will be published onour website www.queensparkcommunitycouncil.gov.uk. This Notice was last updated in January 2019.
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, please contact:
The Data Controller, Queen’s Park Community Council
Office 1, Beethoven Centre, Third Avenue, London W10 4JL
Tel: 0208 960 5644
Policy prepared as draft based on NALC toolkit, March 2018, by Chief Officer, QPCC. Revised May 2018, Jan 2019