��վ Borough Council privacy notice

April 2018

��վ Borough Council (CBC) is registered as a 'Data Controller' with the Information Commissioner’s Office, Registration Number Z5327706.

We are fully committed to protecting your privacy when you use our services. We comply with the Data Protection Act and 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.
This privacy notice explains how we use information about you and how we protect your privacy.

Our Data Protection Officer (DPO) is Siraj Choudhury, Town Hall, The Boulevard, ��վ, West Sussex RH10 1UZ.

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

In order for you to register, receive and use council services, we need to collect and use personal information from you. We also need to collect and use personal information about people we work with in order to operate and carry out our functions. This may include internal departments, contractors, suppliers, external partners and agencies who are involved in delivering services on our behalf. In addition we may be required 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 your information for as long as it is needed for the service that you have requested and remove it when that purpose has been met. In the case of an online information service such as email alerts this will be when you no longer wish to receive the service and choose to opt out.

Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person. For example, this could be your name and contact details

Some information is ‘special’ and needs more protection due to its sensitivity. It is often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal your:

Sexuality and sexual health
Religious or philosophical beliefs
Ethnicity
Physical or mental health
Trade union membership
Political opinion
Genetic/biometric data
Criminal history

We may need to use some information about you to:

Deliver services and support to you
Manage services we provide to you
Train and manage the employment of our workers who deliver those services
Help investigate any worries or complaints you have about your services
Keep track of spending on services
Check the quality of services
Help with research and planning of new services

There are a number of legal reasons why we need to collect and use your personal information. Generally the legal basis for processing by CBC as a public authority will be:

To perform a function or provide a Service required by Statue (Article 6(1) (e) of the GDPR)
To comply with a legal obligation (Article 6(1) (c) of the GDPR)
Where the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (Article 6(1) (b) of the GDPR)
Where disclosure is in the vital interests of yourself or another person (Article 6(1) (d) of the GDPR
With your explicit consent (Articles 6(1) (a) and 9(2) (a) of the GDPR

If we have consent to use your personal information, you have the right to remove it at any time. If you want to remove your consent, please email the Data Protection Officer and tell us which service you are using so we can deal with your request.

Where we can, we’ll only collect and use personal information if we need it to deliver a service or meet a requirement.

We don’t sell your personal information to anyone else. Nor will we share your personal data with third parties for marketing purposes.

The law gives you a number of rights to control what personal information is used by us and how it is used by us.

We would normally expect to share what we record about you with you whenever we assess your needs or provide you with services.

You also have the right to ask for all the information we have about you and the services you receive from us. When we receive a request from you in writing, (Subject Access Request) we must give you access to everything we’ve recorded about you.

We can’t let you see any parts of your record:

Which contain confidential information about other people
If we think that giving you the information may stop us from preventing or detecting a crime

This applies to personal information that is in both paper and electronic records. If you ask us, we’ll also let others see your record unless one of the points above applies.

You should let us know if you disagree with something written on your file.

We may not always be able to change or remove that information but we’ll correct factual inaccuracies.

In some circumstances you can ask for your personal information to be deleted, for example:

Where your personal information is no longer needed for the reason why it was collected in the first place
Where you have removed your consent for us to use your information (where there is no other legal reason for us to use it)
Where there is no legal reason for the use of your information
Where deleting the information is a legal requirement

Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure.

Please note that we can’t delete your information where:

We’re required to have it by law
It is used for freedom of expression
It is required for public health purposes in the public interest
It is for, scientific or historical research, or statistical purposes where it would make information unusable
It is necessary for legal claims

You have the right to ask us to restrict what we use your personal information for where:

You have identified inaccurate information, and have told us about it
We have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether

When information is restricted it can’t be used other than to securely store the data and with your consent to handle legal claims and protect others, or where it’s for important public interests of the UK.

Where restriction of use has been granted, we’ll inform you before we carry on using your personal information.

You have the right to ask us to stop using your personal information for any council service. However, if this request is approved this may cause delays or prevent us delivering that service.

Where possible we’ll seek to comply with your request, but we may need to hold or use information because we are required to by law.

You have the right to ask for your personal information to be given back to you, or another service provider of your choice in a commonly used format. This is called Data Portability.

This only applies if we’re using your personal information with consent (not if we’re required to by law), or for the performance of a contract and if decisions were made by a computer (i.e. by automated means) and not a human being.

It’s likely that data portability won’t apply to most of the services you receive from us.

You can ask to have any computer made decisions explained to you, and details of how we may have ‘risk profiled’ you.

You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you’ve consented to it.

You have the right to object in certain situations if we are processing your data based on the performance of a task in the public interest/ in the exercise of official authority if you are being ‘profiled’. Profiling is where decisions are made about you based on certain things in your personal information.

If and when we use your personal information to profile you, in order to deliver the most appropriate service to you, you will be informed.

We use a range of organisations to either store personal information or help deliver our services to you.

Sometimes we have a legal duty to provide personal information to other organisations. This is often because we need to give that data to courts, including if the court orders that we provide the information.

We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information in order to find and stop crime and fraud; or if there are serious risks to the public, our staff or to other professionals.

For all of these reasons the risk must be serious before we can override your right to privacy.

We’ll do what we can and take all reasonable steps to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them.

Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it.

Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong.

Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches).

If your personal data needs to be transferred outside of the EEA we will make sure that an adequate level of protection is in place.

Personal data will not be kept for longer than is necessary in relation to the purposes for which they were collected.
There is often a legal reason for keeping your personal information for a set period of time.

Our individual services will list how long your information may be kept for. This ranges from months for some records to a number of years for more sensitive records.

Individual services processing your personal data will have their own dedicated privacy notice.

If you have any worries or questions about how your personal information is handled please email our Data Protection Officer.

For independent advice about data protection, privacy and data sharing issues visit the Information Commissioner’s Office website.

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