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, 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 (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 other legislation relating to personal data and
rights such as the Human Rights Act.
Who are we?
This Privacy Notice is provided to you by St Ives Town Council which is the data controller for your
data.
Other data controllers the Council works with:
- other data controllers, such as local authorities
- Community groups
- Charities
- Other not for profit entities
- Contractors
- Credit reference agencies
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, and 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, marital status, nationality, education/work history,
academic/professional qualifications, hobbies, family composition, and dependants; - Where you pay for activities such as use of a Council hall, financial identifiers such as bank account
numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim
numbers; - The personal data we process may include sensitive or other special categories of personal data
such as criminal convictions, racial or ethnic origin, mental and physical health, details of injuries,
medication/treatment received, political beliefs, trade union affiliation, genetic data, biometric data,
data concerning sexual life or orientation.
How we use sensitive personal data
We may process sensitive personal data including, as appropriate:
- your racial or ethnic origin or religious or similar information in order to monitor compliance with
equal opportunities legislation; - in order to comply with legal requirements and obligations to third parties.
These types of data are described in the GDPR as “Special categories of data” and require higher
levels of protection. We need to have further justification for collecting, storing and using this type
of personal data.
We may process special categories of personal data in the following circumstances: - In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations.
- Where it is needed in the public interest.
Less commonly, 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
capable of giving your consent, or where you have already made the information public.
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 and the reason we need it, so that you can carefully consider whether you wish to
consent.
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.
3 - 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 to protect personal data from loss, misuse, unauthorised
access and disclosure.
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 (e.g., Facebook, Twitter,
WhatsApp); - To help us to build up a picture of how we are performing;
- 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;
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. We will first obtain your consent to
that use.
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, we may ask a commercial provider to publish
or distribute newsletters on our behalf, or 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.
All paper copies of data will be kept in a locked cupboard if required to be kept and shredded when
no longer needed. All data documents containing personal data will be password protected.
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.
2. 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.
3. 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.
5 - 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).
4. 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.
5. 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.
6. 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).
7. The right to lodge a complaint with the Information Commissioner’s Office.
- If you think your data has been misused or that St Ives Town Council has not kept it secure,
you should contact us to tell us. If you are unhappy with the responses or if you need any
advice you can contact the Information Commissioners Office on 0303 123 1113 or via live
chat at https://ico.org.uk/global/contact-us/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. [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.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on this web page.
This notice was last updated in August 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, St Ives Town Council, Town Hall, Market Hill, The Old Riverport, St Ives, Cambs,
PE27 5AL
Email: clerk@stivestowncouncil.gov.uk
Responsible Officer: Town Clerk
Date Effective From: November 2022
Review Date: November 2023
Author: Town Clerk
Date Last Amended: August 2028
