Privacy Policy

Data Protection and Privacy Policy

In carrying out its role as the group responsible for steering the process of making the Chetwynd: The Toton & Chilwell Neighbourhood Plan (CTTCNP), the Chetwynd: The Toton & Chilwell Neighbourhood  Forum (CTTCNF) will be holding data electronically. It may also process some of this data to provide evidence in support of the Plan.

For these reasons the CTTCNF is subject to Data Protection legislation, particularly in respect of any personal data it holds.

This page describes the data that the CTTCNF will hold, what it will do with the data, who has access to the data and in what form, and what you can ask us to do with any data that relates to you.

Data Use

The primary personal data that we store and use are email addresses to enable us to contact anyone who may wish to comment or contribute in the making of the CTTCNP. The CTTCNP is a community plan and so community engagement is central to the task of making it. The CTTCNF will keep a list of email addresses that may also have associated names linked to them. We will not generally store postal addresses linked to names or email addresses unless they have been supplied directly by the person concerned. Currently this is approx. 80% of people on the master spreadsheet which is only available to Data Controller (Graham Heal) and used to evidence the spread of people engaging with the plan process.

Emails

All emails will be handled by nominated people within the CTTCNF who have access to designated *.cttcnf@gmail.com accounts through which all email correspondence from the CTTCNF will take place. We will also use an automated email service (Mailchimp) to help the process of distributing information. Consent to use this will be collected via specific process.

If you contact us by email we will reply (if required) and this and any subsequent emails will remain within the email system however, if the content of the email requires further discussion by the CTTCNF then the content will be de-personalised before being passed on for discussion.

Your Comments

All comments made to the CTTCNF will have all personal details removed before being put into any public forum or being processed by the CTTCNF or it’s consultants. Paper notes on which comments are written will be kept as evidence until the CTTCNP has been made (although they would normally contain no personal data or identifiers). Comments made by email will be retained in the email system in their original form as evidence.

Other data storage

The master spreadsheet containing membership details, held by the Data Controller, is stored separately from other data on an encrypted PC.

We store documents which we or our consultants have written together with other documents relevant to the task on a secure Google Drive system to which only members of the CTTCNF steering group have full access. The vast majority of these documents contain no personal data, most are available elsewhere in the public domain. Some of these will be made available to the public through the CTTCNF website at http://cttcnf.org.uk as ‘view only’ items. None of these publicly available documents should contain any personal data or identifiers except of CTTCNF members or consultants.

End of process

When the CTTCNP has been formed, examined and put to a referendum the CTTCNF should cease to function and all data will become the property of the Nottinghamshire County Council. If the CTTCNP has been approved by referendum then personal data will be removed at this point. If the CTTCNP has been rejected then the NCC may seek to continue to progress a Plan in another form with a re-formed group in which case all data will become the responsibility of this new body for the duration of its existence and it will operate under the same conditions as described here unless and until it publishes a replacement operating statement.

The Legal Bits

Website, Cookies, Privacy Policy and Google Analytics

We do not use cookies on this website, however the underlying website construction (Word Press) does include a tool that allows us to see how many people visit the site, how they arrive, and what geographic region they probably visit from (e.g. UK, Russia, Canada, etc). This tool uses Google Analytics which requires us to put this notice on the website:

“We will not, and we will not assist or permit any third party to, pass information to Google that Google could use or recognise as personally identifiable information. We will have and abide by an appropriate Privacy Policy (this page) and will comply with all applicable laws, policies, and regulations relating to the collection of information from Visitors. We must post a Privacy Policy and that Privacy Policy must provide notice of our use of cookies that are used to collect data. We must disclose the use of Google Analytics, and how it collects and processes data. This can be done by displaying a prominent link to the site “How Google uses data when you use our partners’ sites or apps”.

This link is: www.google.com/policies/privacy/partners/

Lawfulness of Processing Data

We (the CTTCNF) process data for the purpose of exercising the public function of making a Neighbourhood Plan under the Localism Act 2011 and we believe it is necessary for the performance of this task which is being carried out in the public interest.[1]

Consent

We do not need your explicit consent to process data neither do we assume you have given us consent, but we hope that you are content that we hold onto your email address if you contact us by email, or you provide us with data in any other form. However, if you are not content you can ask us to tell you what personal data we hold about you and you may at any time request us to delete this permanently from our systems.

The specific exception is the use of automated email service where we require specific consent to store email address only on Third Party server.

References

[1]These statements are in accordance with the advice from the Information Commissioners Office and can be found by following the links below:

https://ico.org.uk/for-organisations/guide-to-data-protection/conditions-for-processing/

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-bases-for-processing/