Welcome to the Surrey Heath Borough Council (“SHBC”) privacy notice. We wrote this to explain how Surrey Heath is complying with both the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA).
SHBC respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. [Alternatively you can download a pdf version of the policy]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this Privacy Notice
This privacy notice aims to give you information on how Surrey Heath Borough Council collects and processes your personal data through your use of Council services, including any data you may provide through this website.
It is important that you read this privacy notice and any other notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Surrey Heath Borough Council is the data controller and responsible for looking after your personal data (collectively referred to as ”SHBC”, “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the DPO using the details set out below.
Contact details for DPO
Full name: Mrs. Karen Limmer
Name or title of DPO: Head of Legal Services
Email address: firstname.lastname@example.org
Postal address: Surrey Heath House, Knoll Road, Camberley, Surrey, GU15 3HD
Telephone number: 01276 707100
As part of Surrey Heath’s transparency and accountability, when dealing with people’s data both the Council and the Councillors are registered with the Information Commissioner’s Office. View details for the Council’s registration. Each Councillor is registered independently to allow Councillors to consider residents in their local wards personal information when representing them. View details for each Councillor by searching for the Councillors particular name.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, it is usually a requirement of the ICO that we have had the opportunity to satisfy your concerns before you approach them so please contact us in the first instance.
Changes to the Privacy Notice and your duty to inform us of changes
This version was last updated on 25 May.
Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you and how your data is collected
Personal data, or personal information, means anything that will identify you.
We may collect, use, store and transfer different kinds of personal data about you; the type of data we are likely to collect includes:
- Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
- Contact Data includes [billing address, delivery address, email address and telephone numbers].
- Financial Data includes [bank account and payment card details].
- Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
- Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
- Usage Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
- Marketing and Communications Data includes [your preferences in receiving marketing form us and our third parties and your communication preferences].
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
Technical Data from the following parties:
Analytics providers and search information providers such as Google based outside the EEA and Site Improve.
3. How we use your personal data
We will only use your personal data for limited purposes. Most commonly, we will use your personal data in the following circumstances:
- Where we need to comply with a legal or regulatory obligation and the Council is under a legal duty, for example collecting Council Tax.
- Where it is necessary to perform our Public Task in order to deliver public services (or those of a third party where there is a data sharing agreement) and your interests and fundamental rights do not override those interests.
- Where we are involved in a contract and processing is required, for example a contract of employment or a contract to provide services.
Where a persons vital interests are at stake and the Council must carry out the activity to protect them from harm.
- Where it is entirely optional and consent is given freely in respect of the processing of your information, for example you have asked to be kept up-to-date with a public consultation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications where you have agreed to this. You have the right to withdraw consent to marketing at any time by contacting us.
We only do limited marketing where you have signed up to receive it; usually through emails, bulletins or brochures and you can choose to unsubscribe at any time.
Where you unsubscribe from receiving marketing messages, this will not apply to personal data provided to us as a result of provision of statutory services to you.
4. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the ICO of a breach where we are legally required to do so.
5. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Each department will have its own separate policy. Please click on the link to the relevant department to read more about this.
6. Data sharing
We often enter into data sharing agreements with third parties who deliver public services on our behalf. Instead of entering into specific data sharing agreements some are done via the Surrey Multi-Agency Information Sharing Protocol (MAISP) which provides a common understanding for all the agencies in Surrey to work to and is recommended for use where there is no context-specific protocol – all members of MAISP are bound by its principles.
Sharing information about individuals between public authorities is often essential if we need to keep people safe, or ensure they get the best services. This sharing must only happen when it is legal and necessary to do so and adequate safeguards are in place to protect the security of the information.
Prevention of fraud and crime
We also collect, use and share Personal Data to other bodies responsible for auditing and administering public funds, or where undertaking a public function in order to detect fraud and protect public funds. For example, we participate in the Cabinet Office’s National Fraud Initiative which compares computer records, usually personal information, to locate data differences as these may indicate potentially fraudulent claims and payments. View further information regarding the National Fraud Initiative’s data matching exercise
7. Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request and in order to assist us in carrying out this function we need as much information as possible to identify you and to identify the data you are specifically referring to. email@example.com
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Please click on the links to access web forms:
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
All legitimate requests should receive a response within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Data Controller
Person who controls and directs the data.
- Data Processor
Can only use the data in ways directed by the data controller.
- Lawful basis for processing
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Personal data
Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
- Statutory / Statute Law
Required, permitted, or enacted by statute law.