Privacy Policy
Internet Privacy and Cookies Policy
FRINTON AND WALTON TOWN
COUNCIL
GENERAL PRIVACY NOTICE
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 FRINTON AND WALTON TOWN COUNCIL which is the data controller for your data.
Other data controllers the council works with:
·
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 and sexual life or
orientation.
How we use sensitive
personal data
·
We
may process sensitive personal data including, as appropriate:
information
about your physical or mental health or condition in order to monitor sick
leave and take decisions on your fitness
for work;
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.
·
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;
·
To
process relevant financial transactions including grants and payments for goods
and services supplied to the council
·
To
allow the statistical analysis of data so we can plan the provision of
services.
Our processing may also include the use
of CCTV systems for the prevention and prosecution of crime.
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.
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.
1)
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.
·
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 email, or by post (see Contact Details
below).
7)
The right to lodge a complaint with the Information
Commissioner’s Office.
·
You
can contact the Information Commissioners Office on 0303 123 1113 or via email
https://ico.org.uk/global/contact-us/email/ 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 our web
page www.essexinfo.net/Frinton-and-walton-town-council. This Notice was last updated in February
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, Frinton
and Walton Town Council, The Council House, Triangle Shopping Centre,
Frinton-on-sea, Essex, CO13 0AU.
Email: events@columbinecentre.co.uk
9
ACCESSIBILITY STATEMENT FOR COLUMBINE CENTRE
Contents
Accessibility statement for www.columbinecentre.co.uk
Contacting us by phone or visiting us in person
Technical information about this website’s accessibility
Non accessible content
How we tested this website
What we’re doing to improve accessibility
Accessibility statement for www.columbinecentre.co.uk
This website is run by Frinton and Walton Town Council. We want as many people as possible to be able to use this website. For example, that means you should be able to:
change colours, contrast levels and fonts
zoom in up to 300% without the text spilling off the screen
navigate most of the website using just a keyboard
navigate most of the website using speech recognition software
listen to most of the website using a screen reader (including the most recent versions of JAWS, NVDA and VoiceOver)
We have endeavoured to make the website text as simple as possible to understand.
AbilityNet has advice on making your device easier to use if you have a disability.
How accessible this website is
We know some parts of this website aren’t fully accessible:
Text Alternatives for non-text content.
Image text - a change in how we add Bold text from <b> to <strong>
Font references - Google standard font needs removing.
Add a document language coding - to identify that the text is in English.
Add more contrast and colour per page.
What to do if you can’t access parts of this website
If you need information on this website in a different format like accessible PDF, large print, easy read, audio recording or braille:
Email: fawtc@btconnect.com
Call: 01255676666
We’ll consider your request and get back to you in 28 days.
Reporting accessibility problems with this website
We’re always looking to improve the accessibility of this website. If you find any problems that aren’t listed on this page or think we’re not meeting accessibility requirements, contact:
Email: fawtc@btconnect.com
Call: 01255676666
Enforcement procedure
The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you’re not happy with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS).
Contacting us by phone or visiting us in person
The Columbine Centre has audio induction loops, or if you contact us before your visit, we can arrange a British Sign Language (BSL) interpreter.
Technical information about this website’s accessibility
Frinton and Walton Town Council is committed to making its website accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.
This website is partially compliant with the Web Content Accessibility Guidelines version 2.1 AA standard, due to the non-compliances listed below.
Non accessible content
Some content is non-accessible for the following reasons:
Text Alternatives for non-text content.
Image text - a change in how we add Bold text from <b> to <strong>
Font references - Google standard font needs removing.
Add a document language coding - to identify that the text is in English.
Add more contrast and colour per page.
Non-compliance with the accessibility regulations
Some images don’t have a text alternative, so the information in them isn’t available to people using a screen reader. This doesn’t meet WCAG 2.1 success criterion 1.1.1 (non-text content).
We are considering adding text alternatives for all images by September 2020. When we publish new content, we’ll make sure our use of images meets accessibility standards.
Navigation and accessing information
There’s no way to skip the repeated content in the page header (for example, a ‘skip to main content’ option). This doesn’t meet WCAG 2.1 success criterion 2.4.1 (bypass blocks).
It’s not always possible to change the device orientation from horizontal to vertical without making it more difficult to view the content. This doesn’t meet WCAG 2.1 success criterion 1.3.4 (orientation).
It’s not possible for users to change text size without some of the content overlapping. This doesn’t meet WCAG 2.1 success criterion 1.4.4 (resize text).
Interactive tools and transactions
We’ve assessed the cost of fixing the issues with navigation and accessing information, and with interactive tools and transactions. We believe that doing so now would be a disproportionate burden within the meaning of the accessibility regulations. We will make another assessment later in the year.
PDFs and other documents
Many of our older PDFs and Word documents don’t meet accessibility standards - for example, they may not be structured so they’re accessible to a screen reader. This doesn’t meet WCAG 2.1 success criterion 4.1.2 (name, role value).
Some of our PDFs and Word documents are essential to providing our services. For example, we have PDFs with information on how users can access our services, and forms published as Word documents. By September 2020, we plan to either fix these or replace them with accessible HTML pages.
The accessibility regulations don’t require us to fix PDFs or other documents published before 23 September 2018 if they’re not essential to providing our services.
Any new PDFs or Word documents we publish will meet accessibility standards.
How we tested this website
This website was last tested in August 2019 using an online checking tool https://achecker.ca/checker/index.php to give a rough idea of the changes required. That tool is using WCAG 2.0. The test was carried out by the website designer.
We tested:
Our main website platform, available at www.columbinecentre.co.uk
Please note that we are considering a proposal from the website designer to bring this site up to WCAG 2.1 AA standard and make it fully compliant with the Accessibility Regulations 2018.
This statement was prepared on 9th September 2019 and is the first such statement.
