Privacy Notices - Switch on to Swindon Privacy Notice

This Notice relates to the use of any data collected or used by ‘Switch On To Swindon’ (SOTS) by Swindon Borough Council and its partners. SOTS is a business network of over 600 passionate Ambassadors. The SOTS Board is a public / private informal partnership with members including large corporates and SMEs. Swindon Borough Council provides the platforms and processes and seed funds SOTS activity, with Ambassadors asked to support projects. The SOTS brand is used to promote Swindon as the destination of choice to live, work and invest and a number of Ambassadors now provide time, support and case studies to share these positive messages. The Council and its partners communicate regularly with the Ambassadors about projects and events and to ask for information and support.

A Privacy Notice is a statement issued by an organisation which explains how personal and confidential data about individuals is collected, used and shared.

As the administrator of the Switch On To Swindon network and Board, Swindon Borough Council will act as a “Data Controller” for any personal data that you provide to us.  We will ensure that the data given to us is processed in line with our Data Protection Act 2018 (DPA 18) and the EU General Data Protection Regulations. (GDPR)

From time to time, your data will be shared with companies and organisations which provide services for the Ambassador Network as requested by the Switch On To Swindon Board e.g. event organisers.

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).

On behalf of the Switch On To Swindon (SOTS) Board and network, Swindon Borough Council collects a range of data about you during the engagement in the network. This includes:

• Your name, address and contact details and business name and address and contact details.
• For the purposes of events / meetings we may collect and share accessibility and / or dietary requirements.
• If you have provided information and / or imagery from your company for the purposes of promoting Swindon, we will store and use it as such.

If you have paid for a SOTS service e.g. campaign sponsorship, your payment details will be collected according to financial regulations.

On behalf of Switch On To Swindon, Swindon Borough Council complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

We may need to use some information about you:

• to deliver services and support to you;
• to manage those services we provide to you;
• to train and manage the employment of our workers who deliver those services;

to help with research and planning of new services.

The law allows collection and use of your personal information through contract, consent and the legitimate interests of maintaining Switch On To Swindon services and providing you with sufficient information to manage membership of and activities within the Ambassador network.

If we have consent to use your personal information, you have the right to remove it at any time. If you want to remove your consent, contact DataProtection@Swindon.gov.uk and tell us which service you are using so we can deal with your request.

On behalf of Switch On To Swindon, Swindon Borough Council uses a range of partner organisations to either store personal information or help deliver our services to you. Where we have these arrangements there is always an agreement in place to make sure that the organisation complies with data protection law.

We will do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we will only make them available to those who have a right to see them.

Examples of our security include:

• Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code, or what is called a 'cypher'. The hidden information is said to then be 'encrypted'.
• Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong.

Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches).

Personal Information will be kept by Swindon Borough Council on behalf of Switch On To Swindon Board and Network for up to 1 year after you have ceased to be Ambassador Network members.

If you have purchased a Switch On To Swindon service e.g. campaign sponsorship, your information will be held within financial regulations e.g. for minimum 7 years.

The law gives you a number of rights to control what personal information is used by us and how it is used by us.

• You can ask for access to the information we hold on you:
  • We would normally expect to share what we record about you with you whenever we assess your needs or provide you with services.
  • However, you also have the right to ask for a copy of all the information we have about you and the services you receive from us. When we receive a request from you in writing, we must give you access to everything we have recorded about you, however, we cannot let you see any parts of your records that contain: 
    • confidential information about other people
    • data a professional thinks will cause serious harm to you or someone else’s physical or mental wellbeing; or
    • if we think that giving you the information may stop us from preventing or detecting a crime.
  • This applies to personal information that is in both paper and electronic records. If you ask us, we will also let others see your record (except if one of the points above applies).
  • If you cannot ask for your records in writing, we will make sure there are other ways that you can.
  • If you have any queries about access to your information contact DataProtection@Swindon.gov.uk.
• You can ask to change information you think is inaccurate
  • You should let us know if you disagree with something written on your file.
  • We may not always be able to change or remove that information but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
• You can ask to delete information (right to be forgotten)
  • In some circumstances, you can ask for your personal information to be deleted, for example: 
    • Where your personal information is no longer needed for the reason it was collected in the first place.
    • Where you have removed your consent for us to use your information and where there is no other legal, legitimate or lawful reason for us to keep it.
    • Where there is no legal reason for the use of your information.
    • Where deleting the information is a legal requirement.
  • Where your personal information has been shared with others, we will do what we can to make sure those using your personal information comply with your request for erasure.
  • Please note that we cannot delete your information where:
    • we are required to have it by law
    • it is used for freedom of expression
    • it is used for public health purposes
    • it is used for, scientific or historical research, or statistical purposes where it would make information unusable
    • it is necessary for legal claims
• You can ask us to limit what we use your personal data for
  • You have the right to ask us to restrict what we use your personal information for where:
    • you have identified inaccurate information, and have told us of it
    • where we have no legal reason to use that information, but you want us to restrict what we use it for rather than erase the information altogether
  • When information is restricted, it cannot be used other than to securely store the data and with your consent to handle legal claims and protect others, or where it is for important public interests of the UK.
  • Where restriction of use has been granted, we will inform you before we carry on using your personal information.
  • You have the right to ask us to stop using your personal information for any council service. However, if this request is approved this may cause delays or prevent us from delivering that service to you.
  • Where possible we will always seek to comply with your request, but we may need to hold or use information because we are required to by law.
• You can ask to have your information moved to another provider (data portability)
  • You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.
  • However, this only applies if we are using your personal information with consent (not if we are required to by law) and if decisions were made by a computer and not a human being. 
  • It is likely that data portability will not apply to most of the services you receive from the Council. 
  • You can ask to have any computer made decisions explained to you, and details of how we may have 'profiled' you.
  • You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you have consented to it.
  • You also have the right to object if you are being 'profiled'. 'Profiling' is where decisions are made about you based on certain things in your personal information. For example, your health conditions.
  • If the Council uses your personal information to profile you, in order to deliver the most appropriate service to you, you will be informed.

If you have concerns regarding automated decision-making, or profiling, please contact our Data Protection Officer who will be able to advise you about how we are using your information. 

In the event that you wish to complain about the way that your personal data has been handled by Swindon Borough Council, you should write to the Data Protection Officer and clearly outline your case. Your complaint will then be investigated in accordance with our customer complaint procedure.

If you remain dissatisfied with the way your personal data has been handled, you have the right to complain to the Information Commissioner’s Office at www.ICO.org.uk. You may refer the matter to the Information Commissioner’s Office whose contact details are below:

Information Commissioner’s Office,  Wycliffe House,  Water Lane,  Wilmslow,  Cheshire,  SK9 5AF Email: casework@ico.org.uk

This website also contains information on data protection and your rights and remedies.

You are under no statutory obligation to provide personal data to Swindon Borough Council on behalf of Switch On To Swindon. However, if you do not, we will be unable to provide Switch On To Swindon services.

A yearly audit will take place on personal data to ensure that we remain legally compliant in accordance with current data protection legislation.