As a Local Authority, Borough Council of Wellingborough (BCW) processes a considerable amount of information, including personal and special category data about the residents it serves. The Council recognises that this information is important to its residents and that it has a responsibility to protect the information it holds about them. As such, it takes seriously its responsibilities and ensures that all information collected is used and done so proportionately and safely. When providing effective services, BCW is committed to protecting the privacy and security of those individuals.
This notice explains what we do with information provided to us with and ensure that you remain informed and, where possible, in control of your data. This notice is for guidance only and does not form a contract.
BCW will be process all personal and special category data in accordance with the Data Protection Act 1998 and the General Data Protection Regulation (Regulation (EU) 2016/679). It will only be used for the specified purpose or for purposes that are compatible with that. We will not pass personal or special category data to third parties for commercial purposes.
Information will be shared among officers, councillors and other partner agencies where the law allows or requires it. This is to help improve the service you receive from us and to help us improve on them. We may also be legally required to share your personal data with law enforcement bodies such as the Police, government authorities and other organisations, for the prevention and detection of crime. If you do not wish certain information about you to be exchanged within the Council, you can request that this does not happen in some instances, although this may affect the ability of the Council to provide some services to you.
Any questions you have in relation to this policy or how we use your personal data should be sent to firstname.lastname@example.org or addressed to the Data Protection Officer (DPO), Borough Council of Wellingborough, Swanspool House, Doddington Road, Wellingborough, NN8 1BP.
A copy of the privacy notice can be found in our office reception at Tithe Barn Rd, Wellingborough NN8 1BN or online at www.wellingborough.gov.uk. Alternatively you can telephone general enquiries on 01933 229777 and a copy can be posted out to you.
3. ABOUT US
Your personal and special category data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by BCW as the data controller for the council (ICO registration Z5378185) and the Electoral Registration Officer (ERO) appointed by BCW as the data controller for electoral registration (ICO registration Z5358577).
4. WHAT INFORMATION WE COLLECT
Personal data provided by you
In order for BCW to deliver services in an effective way we will need to collect and process your personal information.
If you use a specific council service, we will usually let you know how that service will use your personal information via separate privacy notices. Please click here for more information.
Our legal obligation
The Data Protection Act 1998 and the EU General Data Protection Regulation ensure that we comply with a series of data protection principles. These principles are there to protect you and they make sure that we:
- Process all personal information lawfully, fairly and in a transparent manner.
- Collect personal information for a specified, explicit and legitimate purpose.
- Ensure that the personal information processed is adequate, relevant and limited to the purposes for which it was collected.
- Ensure the personal information is accurate and up to date.
- Keep your personal information for no longer than is necessary for the purpose(s) for which it was collected.
Keep your personal information securely using appropriate technical or organisational measures.
5. KEEPING YOU IN CONTROL
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights under the Data Protection Act 1998 and EU General Data Protection Regulations, which are as follows:
- The right to be informed via privacy notices such as this.
- The right of access to any personal information the council holds about you. To request a copy of this information you must make a subject access request in writing, either via email to email@example.com or in aletter addressed to the DPO, Borough Council of Wellingborough, Swanspool House, Doddington Road, Wellingborough, NN8 1BP. Please click here for further details.
- The right of rectification; we must correct inaccurate or incomplete data within one month.
- The right to erasure. You have the right to have your personal data erased and to prevent processing unless we have a legal obligation to process your personal information.
- The right to restrict processing. You have the right to suppress processing. We can retain just enough information about you to ensure that the restriction is respected in future.
- The right to data portability. We can provide you with your personal data in a structured, commonly used, machine readable form when asked.
- The right to object. You can object to your personal data being used for profiling, direct marketing or research purposes.
You have rights in relation to automated decision making and profiling, to reduce the risk that a potentially damaging decision is taken without human intervention.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
If you would like further information on your rights or wish to exercise them, please write to our DPO at Borough Council of Wellingborough, Swanspool House, Doddington Road, Wellingborough, NN8 1BP or email the DPO at firstname.lastname@example.org.
We can provide you with a template subject access form which includes guidance on how to make your request (and will help us respond more quickly). Please contact us for a copy of this.
If we already have a legal or regulatory obligation to process data, then we will not generally need to obtain your consent to process the data.
Consent means that individuals have real choice and control over how organisations used their data.
Consent must be explicit, and requires a very clear and specific statement of consent and involve a positive opt-in. Pre-ticked opt-in boxes are now banned.
Individuals may withdraw consent at any time they choose; we will try to make it as clear and straightforward for you to remove your consent where you are able to do so.
If we are unable to offer consent – if we are processing your data for a legal reason or to comply with our statutory duties – then we cannot offer a genuine choice, so asking for consent would be misleading and inherently unfair.
Special category personal data
We collect and store special category personal data (such as information relating to health) about some of our customers. We’ll take extra care to ensure your privacy rights are protected.
Accidents or incidents
If an accident or incident occurs on our property, then we’ll keep a record of this (which may include personal data and special category personal data).
6. HOW WE USE INFORMATION
We only ever use your personal data with your consent, or where it is necessary in order to:
- Carry out our statutory duties and public tasks;
- enter into, or perform, a contract with you;
- comply with a legal duty;
- protect your vital interests;
- for our own (or a third party’s) lawful interests, provided your rights don’t override the these.
BCW will use your personal data for the specified purpose it was collected for (or else for closely related purposes): and at all times within the rules set out in the Data Protection Act 1998. For further information on the lawful basis for processing please click here.
Personal and special category data that we process:
- Personal information relating to identified natural persons used to deliver services such as:
- Human resources, planning applications, access to information requests, legal claims, customer services, electoral and democratic services, housing, revenue and benefits, environmental services, licencing, pensions, community services, parking services, trading standards and more.
- Special category data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and data concerning health or sex life or sexual orientation.
- Health and wellbeing information;
- Research and statistical data to provide intelligence including demographic data, population projections, the economic situation, health and wellbeing information. This personal information is often pseudonymised when an identifier such as name is replaced with a unique number.
Where otherwise permitted under the Data Protection Act 1998.
7. DISCLOSING AND SHARING DATA
Information will be shared among officers, councillors, and other partner agencies where the law allows or requires it. This is to help improve the service you receive and to develop other services. We may also be legally required to share your personal data with law enforcement bodies such as the Police, government authorities and other organisations, for the prevention and detection of crime or fraud. If you do not wish certain information about you to be exchanged within the Council, you can request that this does not happen, although this may affect the ability of the Council to provide some services to you such as:
- District Councils
- Fire Service
Your information may be shared with other relevant teams for the following purposes:
- Respond to any service requests, feedback or complaints
- Allow access to our services and carry out transactions
- Provide you with information regarding our services
- Process job applications
- Send email alerts to users who request them
We sometimes receive personal data about individuals from third parties. For example, if we are partnering with another organisation (e.g. you provide your information to Department of Work and Pensions or other government authorities).
We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.
We will also need to supply your information to organisations we have contracted to provide a service to you.
We will only ever share your information if we are satisfied that our partners or suppliers have sufficient measures in place to protect your information in the same way that we do.
We will not send your information to marketing agencies.
Before sharing information the council will ensure that:
- Privacy Notices are completed if appropriate.
- Technical security such as encryption and access controls are in place to keep information secure.
- Information Sharing Agreements are completed showing the rules to be adopted by the various organisations involved in the sharing exercise.
- Privacy Impact Assessments are completed to assess any risks or potential negative effects.
- Common retention periods and deletion arrangements are set for the information.
Subject access rights are catered for.
BCW will ask its customers to “opt-in” for marketing communications that we may wish to send. This will give you greater control over how we can contact you by giving you the choice as to whether you want to receive these messages and how you want to receive them (email, phone, or post).
You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact email@example.com or write to the DPO, Borough Council of Wellingborough, Swanspool House, Doddington Road, Wellingborough, NN8 1BP.
Newsletters and magazines
Council newsletters and waste collection information are provided as a benefit to our customers. We send these out to all our tenants and registered addresses within the borough.
9. YOUNG PEOPLE
Parental permission: If your child is under 18 then we’ll need permission from you as their parent or guardian for them to enter one of our competitions or to share a picture, photo or story with us. Our photo policy and consent form can be found here.
Information for parents
We take great care to protect and respect the rights of individuals in relation to their personal data, especially in the case of children. If your child is under 18, we’ll only use his or her personal data with your consent. This means that, for example, if your child wants to have his or her name or picture featured in one of our magazines, we’ll need you to confirm you’re happy for us to do so.
We won’t send marketing emails, letters, calls or messages to under 18 year-olds.
10. HOW WE PROTECT DATA
We have implemented a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to, or use or disclosure of your personal information.
Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Each member of staff receives data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
11. Payment security
When making online payments you will be directed to a secure externally hosted payment system.
The council does not store any credit card information taken by our officers during telephone payments.
Some of our premises have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and BCW. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only retained for one month. Unless it is flagged for review CCTV will be recorded over.
BCW complies with the Information Commissioner’s Office CCTV Code of Practice, and we put up notices so you know when CCTV is in use.
Where we store information
BCW stores our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we’ll only allow them to do if your data is adequately protected.
For example, some of our systems use Microsoft products. As a US company, it may be that using their products results in personal data being transferred to (or being accessible from) the US. However, we’ll allow this as we are certain personal data will still be adequately protected (as Microsoft is certified under the USA’s Privacy Shield scheme).
How long we store information
We will only keep your information for as long as it is required to be retained. The retention period is either dictated by law or by our discretion. Once your information is no longer needed it will be securely and confidentially destroyed. For further information on specific retention periods please see our departmental information asset registers.
Where you send us questions or queries we will retain that data for up to 6 months or if you tell us to delete it immediately, whichever comes first, unless the enquiry is required for troubleshooting or for improving services. In these cases we will delete the personal data and store the enquiry.
14. ACCESS TO COUNCIL OFFICIAL INFORMATION
Under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004 you have a right to request any recorded official information held by the council. The information you require may already be publicly available. The council has a duty to make official recorded information availablevia a publication scheme. Before you submit a request please check the publication scheme.
If you need to make a request, it must be done in writing. You can:
- Email: firstname.lastname@example.org; or
Write to: Freedom of Information Officer, Borough Council of Wellingborough, Swanspool House, Doddington Road, Wellingborough, NN8 1BP.
You do not need to say why you want the information. Your request must include your name, and an address for correspondence (if you apply by email, your email address is a suitable address for correspondence). Please ensure you identify the information you want as clearly as possible.
With certain limited exceptions, you are entitled to a response within 20 working days.
It costs nothing to make a freedom of information request. However, the council can refuse to deal with your request if doing so would cost more than £450 (which equates to 18 hours' work). In extreme circumstances, the council may also charge for the cost of photocopying and postage.
You may not get the information you asked for:
- If the council does not hold the information you have requested
- If the information is exempt from disclosure
- if finding the information you have requested would take longer than 18 hours
If we are unable to supply any of the information you have requested, we will tell you the reasons why. For more details please refer to the Information Commissioner's Office website, this can be found at www.ico.org.uk.
You can complain to BCW directly by contacting our DPO using the details set out above. If wish to make a complaint which does not directly relate to your data protection and privacy rights, you can do so in accordance with BCW’s complaint policy which can be accessed here.
If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk
16. Web statistics
Web statistics about your visit to our site are collected automatically. This information is used to help us follow browsing preferences so that we can regularly improve our website. These statistics do not contain personal data.
17. Location awareness
If your experience would be improved by our website knowing your location, we will ask permission to obtain your current location from your device. This can include coordinates, direction of travel and the time the data was recorded. This location data is not tracked and is used in providing specific service requests.
18. E-mails / forms
In some areas of the Council website, we may ask you to register your name and e-mail address. We may also collect personal data from you if you complete any forms or if you contact us with comments or specific requests. The personal data collected will only be used for the specified purpose(s), stated on the form. E-mails to councillors are confidential between yourself and your councillor.
If you are using a public computer and do not wish others to be able to go back to view the details you have typed into a form on the web it is advisable to clear the contents of the form and your cache (temporary internet files) before leaving the computer
19. COOKIES AND LINKS TO OTHER SITES
Links to other sites
Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by emailing email@example.com).
Following a link to www.wellingborough.gov.uk from another website
Although we make reasonable efforts to keep the information on this website up-to-date and accurate, we make no representations, warranties or guarantees whether express or implied that the content on our site is accurate, complete or up-to-date. BCW, its employees or agents will not be held responsible for any loss, damage or inconvenience caused as a result of reliance on such information.