Trowbridge Town Council Privacy Notice

1. Introduction

We collect and use personal information where this is necessary to perform a contract with you or to provide you with information about our services.

When we collect, store, and delete your data, we do so in line with The General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Trowbridge Town Council is the data controller for any data collected, stored, and processed by Trowbridge Town Council, Trowbridge Museum, the Civic and Active Trowbridge.

Trowbridge Town Council is registered with the Information Commissioner’s Office (ICO) for the purpose of processing personal data.

This Privacy Notice explains what personal information we collect about you, how we use it and how it is protected.

2. Information We Collect

We may collect, store, and use the following categories of personal information about you, where this is relevant to the service provided or purchase made:

  • Name
  • Address(es)
  • Telephone number(s)
  • Email address(es)
  • Payment details
  • CCTV footage
  • Photographs/ and or video recordings
  • Anonymised information or technical information such as IP addresses and cookies

We may also collect, store, and use the following special category personal data, where this is necessary and lawful:

  • Medical
  • Gender

3. How We Collect Your Data and the Purpose of Processing

We will only collect and use your personal information where the law allows us to do so and only for the purposes for which it was collected. In some circumstances, more than one lawful basis for processing may apply.

How we collect your data and the purpose of processing

Lawful bases for processing

When you visit the website

Consent & Legitimate Interests

When you contact the Council, whether by telephone, via the contact form on our website, or by email

Legitimate Interest, Contractual, Legal Obligation, Public Task

When you visit the Council in person

 

Legitimate Interest, Contractual, Legal Obligation, Public Task

When you pay for a service that the Council provides.

·       Hire of Trowbridge Park

·       Hire a pitch for the Wednesday market or a Town Council event

·       Rent an allotment

·       Lease a venue

·       Lease a burial plot

·       Hire a garage

 

Contractual, Legal Obligation

CCTV Images – Civic Centre, Walkers Yard, Longfield Community Centre and Trowbridge Museum

To view our CCTV Policy, please click here. This also sets out our lawful basis for processing and data retention periods

CCTV Images –Town Centre

To view our CCTV Policy, please click here. This also sets out our lawful basis for processing and data retention periods

When we investigate any complaints, legal claims, or significant incidents, including health and safety concerns or incidents

Legal Obligation, Legitimate Interest

When you apply for a grant or to receive a core grant from the Council

Contractual, Legitimate Interest

When you complete a nomination form

Legitimate Interest

Civic activity

·       Booking the Mayor

·       Mayoral cadet application form

·       Invitation to a Civic Event

·       Completing the booking form for the Civic Dinner

·       Remembrance service invitation / Attendance

Legitimate Interest, Contractual

When you enter a competition

Legitimate Interest

Where you request information from the Council

Legal Obligation

To speak at a Council meeting

Public Task, Legal Obligation

To create an account or report an issue on MyTrowbridge app

Contractual, Legitimate Interest

Where we make a payment to you for a service or product

Contractual

Where you have consented to receive e-newsletters containing updates and events from the Town Council

Consent

Where you sponsor an event, roundabout, Civic dinner or another Council service

Contractual

Database list for business and community group contacts

Legitimate Interest

Submitting an event through the website

Consent, Legitimate Interest

Where we investigate a complaint or feedback

Legitimate Interest

Where you request to be placed on a waiting list for an allotment

Legitimate Interest

When we hold cemetery records including full burials and ash interments, as well as all holders of the Exclusive Right of Burial Deeds for each grave and ashes plot

Public Task, Legal Obligation

Where you are a useful contact for work or maintenance purposes, a contractor, a local business owner, a member of a community group, a community volunteer, or hold a position within the town

Legitimate Interest

 

Where you complete a survey, consultation or feedback form

Consent

When you submit a speed limit change request or other request for the Council to consider a matter and, where appropriate, refer it to another public authority.

Public Task, Legitimate Interest

4. Online Meetings

For the purposes of providing a public forum, Trowbridge Town Council uses Microsoft Teams.

At present Microsoft (MS) Teams is not able to be configured to obscure the names of attendees to the public meeting.

You can join the meeting via the meeting link which can be found on our website under Meeting Calendar. Please be aware your name (or TEAMS account name), will be viewable to those attending.

If you do not wish to share this information, we will be able to provide the telephone number to the meeting which can be used to dial into the meeting, in this case your information will not be publicly available. Please note – if you wish to address the councillors at the meeting, then your name will be recorded in publicly available minutes.

Trowbridge Town Council will only use your telephone number for the purposes of attending a meeting and we will only retain such information for the period that is required for the meeting.

5. Data Sharing and Transferring

Trowbridge Town Council uses third-party processors to collect, process, and store personal data securely and in compliance with the UK GDPR and the Data Protection Act 2018.

Our data processors are:

We may be required, for the purposes of prevention or detection of crime, to share personal data with the police or other organisations with statutory or official authority.

We may also share personal data with other public bodies including local authorities and the police, where this is necessary. In doing so, we share a statutory responsibility to cooperate, safeguard, and promote the welfare of children within the area.

Sharing information plays a crucial role in identifying and responding to abuse, neglect, or exploitation, and in supporting children’s welfare and educational outcomes. Schools, colleges, and school clubs may lawfully share, retain, hold, and use information for these purposes.

Personal data may also be shared internally with the Council’s Community Engagement & Governance Manager where necessary, for example in relation to a complaint or the exercise of your individual data protection rights.

Safeguarding and Protection of Individuals at Risk

The Council may share personal information with the Police, local authorities, safeguarding partners, regulatory bodies, or other relevant agencies where it is necessary to protect a child, young person, vulnerable adult, or another individual at risk of harm, or where disclosure is otherwise required or permitted by law. Any such sharing will be undertaken in accordance with the UK GDPR, the Data Protection Act 2018, and the Council’s Safeguarding Policy.

6. Social Media

7. Retention

We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to meet any legal, accounting, or reporting requirements. Details of the retention periods applicable to different categories of persona data are set out in our Retention Guide, which is available here: Information Governance

To determine the appropriate retention period, we consider the volume, nature, and sensitivity of the personal data, the potential risk of harm arising from unauthorised use or disclosure, the purposes for which the data is processed and whether those purposes can be achieved by other means, as well as any applicable legal or regulatory requirements.

In some circumstances, we may anonymise personal data so that it can no longer be associated with you. Where this occurs, we may use such information without further notice to you.

8. Your Rights

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your relationship with the Council.

You have the right to:

  • Request access to your personal information (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 it is being processed lawfully.
  • Request correction to the personal information that we hold about you. This enables you to have any incomplete or inaccurate information corrected.
  • Request restriction of processing, including requesting that records are not destroyed where you require them, and they are approaching the end of their retention period.
  • Request the transfer of your personal information to another organisation.
  • Right to be informed about the collection and use of your personal data.
  • Right to Erasure. Personal data may be erased in certain circumstances where consent is withdrawn, or the individual rights outweigh those of the Council.
  • Right to Object to processing in certain circumstances such as where it is processed in the public interest or for legitimate interests.

If you wish to request access to your personal data, request a restriction on the destruction of your data, or request the transfer of your personal information to another party, please contact the Community Engagement & Governance Manager.

If you wish to make a change to the data we hold about you, please contact Information Governance.

You will not be required to pay a fee to access your personal information or to exercise any of your data protection rights. However, we may charge a reasonable fee if you request additional copies of the same information.

In the limited circumstances where we rely on your consent to collect, process, or share your personal information for a specific purpose, you have the right to withdraw that consent at any time. To withdraw your consent, please contact the Community Engagement and Governance Manager.

Once we have received notification that consent has been withdrawn, we will no longer process your personal information for the relevant purpose unless we have another lawful basis for doing so.

9. Contact details

Community Engagement & Governance Manager
Trowbridge Town Council
St. Stephens Place
Trowbridge
BA14 8AH

informationgovernance@trowbridge.gov.uk
01225 765072

Data Protection Officer
One West
i-west@bathnes.gov.uk
01225 395959

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.  However, they would normally expect you to have raised your complaint with us in the first instance.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk
0303 123 1113

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