Full Privacy Notice

If you apply to work for us (directly or indirectly via third-party platforms such as Indeed) in any role we will collect your name, age, address, email address, telephone number, gender, applicable screening checks such as DBS and right to work (where permitted by law), employment history (including references) and interview records.

We may also collect, process and store Special Category Data about you for employment purposes (authorised by law) under Article 9 of the UK GDPR and Schedule 1, Condition 1 of the UK GDPR. Special Category Data includes, for example, information about an individual’s health, racial or ethnic origin, religious or philosophical beliefs, biometric data (where it is used for identification purposes) or sexual orientation. Screening checks may also include criminal record checks where permitted by law. This information is normally sourced from you direct although we can also receive this from recruiters, third-party agencies or background check providers. We will only process this sensitive information where it is necessary, and any processing will be done in accordance with our obligations under Data Protection Laws. We will process your personal data for the purposes of progressing your application as required by law or regulatory requirements, so not all of the purposes for which we process your personal data will apply to you all of the time.

We may also use Special Category Data about you in order to make reasonable adjustments during the application process.

Once received by Redruth Town Council, we securely store this information on our internal systems. We may also share your information with:

• suppliers who undertake background screening on behalf of Redruth Town Council (right to work checks, criminal checking bureaus, etc.);
• former employers and academic institutions (such as universities, colleges, etc.) in validating information you have provided; and
• other third-party suppliers (or potential suppliers) who provide services on our behalf.

In addition, we will keep the details of your application and any additional information provided to us by you or others during your application for up to one year following application so that we can keep you informed of future opportunities that you may be interested in. Following this period of retention, and where you are not otherwise engaged by the Council, we shall securely delete your personal data held for this purpose. If you do not wish for us to keep your details for this reason, please let contact us.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Please note, if you are successful, this section of our privacy notice shall cease to apply and you will instead be subject to our Employee, Worker, Volunteer and Contractor Privacy Notice.

Redruth Town Council engage many different types of volunteers, including but not limited to Home Library Volunteers, Library and Information Volunteers, Digital Champions, Asset and Facilities Volunteers and Events Volunteers (such as Festival, Summer Reading Challenge and Duke of Edinburgh). Firstly, we would like to say a big thank you to you for volunteering with us.

If you apply to volunteer with us we will collect your name, age, address, email address, telephone, gender, details of any applicable screening checks (your participation in the same is done by consent) from you directly. Relevant experience (including references) and records relating to your volunteer application or placement. Volunteers under the age of 16 years old will also be required to provide the name and contact details of a parent/guardian If you are a volunteer for the Youth Council, please visit ‘I am a member or prospective member of the Youth Council’ for more information on how we process your personal data.

There may be circumstances where we obtain your information from the Volunteer Network Directory held by Redruth Town Council, enabling us to contact you regarding volunteering opportunities that may be of interest to you. We have assessed this activity to form part of our Public Task under Data Protection Laws.

With your Explicit Consent, we may also collect, process and store Special Category Data about you. Special Category Data includes, for example, information about your health, racial or ethnic origin, religious or philosophical beliefs, biometric data (where it is used for identification purposes) or sexual orientation. Screening checks may also include criminal record checks (undertaken with your consent) where your volunteering activities legally require this additional level of safeguarding. This information is normally sourced from you direct although, we can also receive this from third-party agencies or background check providers. In either case, you provide the same to us with your explicit consent. We will only process this sensitive information where it is necessary and always in accordance with our obligations under Data Protection Laws. We will process your personal data for the purposes of assessing your suitability as a volunteer and managing our volunteering relationship, so not all of the purposes for which we process your personal data will apply to you all of the time.

We may also use Special Category Data about you in order to make reasonable adjustments during the volunteer application process or while you are volunteering with us.

Once received by Redruth Town Council, we securely store this information on our internal systems. Sharing will occur between internal departments, limited to what is required for the volunteer management process. We may also share your information with:

• suppliers who undertake background screening on behalf of Redruth Town Council (right to work checks, criminal checking bureaus, etc.);
• Cornwall Council (if you are a volunteer for the Library);
• former employers and academic institutions (such as universities, colleges, etc.) in validating information you have provided; and
• other third-party suppliers (or potential suppliers) who provide services on our behalf.

In addition, we will keep the details of your volunteer application and any additional information provided to us by you or others during your application for up to one year following application so that we can keep you informed of future volunteer or career opportunities that you may be interested in. Following this period of retention, where you are not otherwise engaged by the Council, we shall securely delete your personal data held for this purpose. If you do not wish for us to keep your details for this reason, please let contact us.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Please note, if you are successful, this section of our privacy notice shall cease to apply, and you will instead be subject to our Employee, Worker, Volunteer and Contractor Privacy Notice.

The Redruth Town Council building is open for use by members of the public, including both adults and children. However, to access many of the systems or facilities within the building, you may be required to give your personal data to us. This will include:

• Applying for membership to Redruth Library or issuing temporary passes;
• Booking a place on library events and workshops;
• Attending or participating in library activities, events, workshops, reading schemes or other services aimed at children and young people;
• Receiving a library service such as “Home Library” or digital assistance;
• Providing tourism information under “Discover Redruth”;
• Provide feedback on library services;
• Law enforcement and debt recovery.

Due to the nature of Library services, we process personal data relating to both adults and children under the age of 18. This may include children who attend the Library, apply for or use library membership, take part in events, workshops, reading schemes or other activities, receive digital assistance, or otherwise use Library services.

In most cases, this personal data is held by Redruth Town Council, on behalf of Cornwall Council, as its Data Processor and contractor, under its statutory duties under the Public Libraries and Museums Act 1964. This means that Cornwall Council are data controller and have overall responsibility for your personal data held by us for library purposes. For more information on how your personal data is used for library purposes, please visit the Cornwall Council Libraries Privacy Notice Libraries Privacy Notice – Cornwall Council. However, there will be limited circumstances when Redruth Town Council will act as controller on respect of your personal data provided to the Library. For example, when using your feedback to improve our contracted library services or when using your image on Redruth town council marketing platforms.

In most cases, we will collect your name, address, email address, telephone number. Depending on the service, we may require additional information such as age and gender. This personal data will be used to provide you with membership or library services. We may also collect the same personal data where you request digital support which we explain further below. This data is collected to allow us to perform our obligations in the contract between you and us to provide our library services. We primarily store your information in Cornwall Council systems and within Redruth Town Council systems. You can terminate your membership with the library at any time or contacting redruth.library@liscornwall.org.uk, otherwise your membership will lapse every two years (although your information may be held for longer for archiving and legal purposes).

Library events

Library events may be attended by adults, children and families. If photography or recording takes place at a Library event, we will take appropriate steps to inform attendees, and where children are involved we will consider whether additional safeguards or permissions are required.

Home Library

If you are in receipt of home library delivery services, in addition to the types of personal data outlined above, we may also require additional information to enable home delivery by our volunteers. This additional information typically includes emergency contact information, specific requirements including information relating to health conditions or disabilities, your interests and reading preferences and, where applicable, information relating to referring agency or organisation (where applicable) and information about your home (such as access requirements, potential hazards, or other details necessary to ensure the safety of volunteers during delivery). This information is solely used to provide you with home library services and will be stored predominantly on Cornwall Council’s systems (although there are limited circumstances where information may be stored on Redruth Town Council systems, such as information regarding employees or volunteers conduct and engagement). Special categories of data are processed with yours, or your authorised person’s, specific consent and can be withdrawn at any time. Please note, where information is withdrawn, this may limit the services we can provide to you.

Digital Assistance including the Digital Champions Scheme

If you are in receipt of digital assistance services such as help with printing, undertaking tasks on the public network computers or the Digital Champions Scheme, we will need to process your personal data to:

• subscribe you to the Digital Champions Scheme and
• provide you with the digital support you need.

Depending on the types of support you need, this means that our staff may see various categories of highly sensitive and confidential information during your support sessions, including information relating to your personal circumstances.

The Digital Champions Scheme is arranged and administrated by Redruth Town Council and any data, including Special Category Data, will only be process with your Explicit Consent. Redruth Town Council, will store and hold information to enrol you to the Digital Champions Scheme. We do not store, copy or use your personal data to gain access to any of your accounts, documents or sensitive information without your explicit consent, and only while you are physically present with us during the support sessions. We take appropriate measures to ensure your information is handled by our staff securely at all times. Access to your data is strictly limited to staff who need it in order to provide the support you have requested.

Signposting and assistance

Redruth Town Council (including staff in the Library) may offer assistance to members of the public to help them understand their individual rights and support their wellbeing, including signposting locating local support services (such as Citizens Advice Bureau and local support charities) as part of its Public Task. For more information on how we process your data for this purpose please visit “You receive signposting or support assistance from Redruth Town Council or the Library”

Alongside running a wide range of community events, we will often work with local traders and charities to help support local businesses and charitable activities throughout our events and festivals.

When applying to Redruth Town Council to become a Festival or Event Trader, we will use your name, trading address, telephone number and email address to perform our contract with you as an actual or prospective Trader at one of our Festivals or Events. We may also ask that you supply business information including your insurance details and necessary public liability and risk assessments.

Your name and email address will automatically be added to our Trader Contact List meaning you will hear from in in future regarding similar festivals and events. This communication is assessed to be in the Council’s legitimate interest, but we will give you an opportunity to opt out of communications during your application process and in each communication thereafter. You can withdraw your name and email address from the Trader Contact List at any time by contacting us. We primarily store your information in our systems (described above) and in our newsletter platform, Brevo.

Redruth Town Council is committed to encouraging young people to take an active role in democratic engagement and community representation. It also has statutory duties to provide information to the public, including its young people. To achieve this Public Task, we operate a Youth Council designed to give young people a meaningful platform to express their views, learn about their community, influence local issues and contribute to the development of community initiatives.

When a young person applies to become, or is appointed as, a member of the Youth Council we will use the young person’s name, school, email address, date of birth and phone number to engage with the young person as an actual or prospective Youth Council Member.

For young people under the age of 16, we will require a parent or guardian’s authority to apply for membership. We will also require the email address of a parent/guardian to circulate agendas and summons via email.

With the young person’s explicit consent, or a parent/guardian’s consent if under the age of 16, we may also collect information to facilitate your child’s attendance to Redruth Town Council premises, and their participation in the Youth Council – such as medical data, allergy information, dietary restrictions, disability information and accessibility needs. Please note, where such information is not provided, this may limit a Youth Council member’s ability to participate fully in the Youth Council.

With your express consent (or the express consent of a parent/guardian where you are under 16 years old), this information may also be used to inform your school about Youth Council activities (for example, where you are unable to attend school due to your observation of your Youth Council duties).

We will also require a parent or guardian to give their name and contact details to support your application and act as a primary point of contact during your membership of the Youth Council. For more information on how we process ‘next of kin’ personal data, please click here.

In order to promote the Youth Council, we may also use images of Youth Council members on our website, our Social Media Channels and other promotional materials. At the point of application, we will ask Youth Council members (or, for young persons aged under 16 years old, their parents/guardians) to give their consent in respect of our use of their image in such materials. These preferences can be varied or withdrawn at any time by contacting us.

You are a young person involved in the Summer Reading Challenge

Redruth Town Council, through the Library, supports children’s literacy, learning and community participation. The Summer Reading Challenge is designed to encourage children and young people to read, participate in Library activities and engage with Library services.

When a young person takes part in, or is registered for, the Summer Reading Challenge, we may use the young person’s name, age or date of birth, library membership details, reading progress and relevant contact details to administer the Challenge and support their participation.

For young people under the age of 16, we may require a parent or guardian’s authority to register or participate, depending on the way the Challenge is being delivered and the information being collected. We may also require parent or guardian contact details so that we can communicate about participation where necessary.

With the young person’s explicit consent, or a parent or guardian’s consent if under the age of 16, we may also collect information needed to support safe participation in Library activities connected with the Summer Reading Challenge, such as medical information, allergy information, disability information or accessibility needs. Please note, where such information is not provided, this may limit a young person’s ability to participate fully in some activities.

We may use this information to administer the Summer Reading Challenge, record participation and progress, communicate with parents or guardians where necessary, and support safe attendance at related Library activities.

Where parent or guardian contact details are provided, we will use them only where necessary to support the young person’s participation or communicate about the Summer Reading Challenge unless otherwise permitted by law.

In order to promote the Summer Reading Challenge and Library activities, we may also use images of participants on our website, our social media channels and other promotional materials. We will ask participants, or where applicable their parents or guardians, to give consent for this use. These preferences can be varied or withdrawn at any time by contacting us.

In most cases, this personal data is held by Redruth Town Council on behalf of Cornwall Council as its data processor and contractor for library services. Where Redruth Town Council uses personal data for its own purposes, such as local promotion of Library activities or Council communications, Redruth Town Council will act as controller for that specific processing.

Wanting to learn more about the Redruth Town Council CCTV Scheme

Redruth Town Council operates the Redruth Town Council CCTV Scheme (the CCTV Scheme), a partnership of local councils working together to create an efficient, cost-effective CCTV provision to Participant Councils enabling them to work with relevant law enforcement agencies in the prevention and detection of crime in their local areas. As well as managing and operating the Scheme, Redruth Town Council public CCTV infrastructure is also connected to the Scheme as a Scheme Participant.

Scheme Participants, including Redruth Town Council, have assessed the data protection impacts of the CCTV Scheme and each confirm that the CCTV Scheme is necessary to meet their respective legal obligations as a public body, particularly under Section 31 Local Government and Rating Act 1997 and, where applicable or working in conjunction with Cornwall Council, Section 163 of the Criminal Justice and Public Order Act 1994 (and other legislation). It also complies with the Surveillance Camera Code 2021. The CCTV Scheme processes personal data for this purpose. The CCTV Scheme operates under the Scheme Code of Practice.

Redruth Town Council endeavours to display clear signage at each location to inform individuals of CCTV use.

Our CCTV cameras have the potential to capture the following categories of data:

• Personally identifiable information including static and moving images of individuals, likeness, appearance, behavioural data and movement patterns.
• Location data
• Vehicles (motorised and non-motorised) including their registration numbers
• Date, time, and location of recordings
• special categories of data including race, ethnicity, religious beliefs, political beliefs, philosophical beliefs, health data and biometric identifiers; and
• criminal offence data.

Disclosures of CCTV Footage and related data will be made to emergency services, local crime reduction partnerships and Law Enforcement Agencies, including but not limited to, Trading Standards, HMRC, Devon and Cornwall Police and Cornwall Council (where it exercises a law enforcement function), in accordance with the Scheme Code of Practice. Disclosures may also be made with members of the public (where legally entitled) or insurance companies under strict data protection and freedom of information procedures. Data sharing with those agencies shall occur through use of secure transfer systems, including but not limited to digital evidence management systems adopted by the Police or other secure/encrypted means.

Redruth Town Council’s CCTV Scheme operations also rely on the assistance of its third-party IT support contractors based in the UK. These contractors may, where necessary, access the CCTV Scheme systems for the purpose of providing IT support. Such access shall be limited to the extent necessary to provide the support.

The CCTV Scheme does not transfer CCTV Footage out of the UK, unless required to disclose to Law Enforcement located out of the jurisdiction.

Attending Redruth Town Council Events

Many of our events may involve processing your personal data as an attendee. For example, we may use your personal data to administer the ticketing of the event, in event photography. We may also share this information with our third-party printing suppliers, event support contractors (such as caterers in the event of food allergies and preferences) and co-hosting organisations. Information, such as ticketing information, may reach us via event arrangement platforms such as Eventbrite. Normally, this information is processed to perform a contract with you (where you purchase a ticket). Otherwise, it is collected to achieve our Public Task or in the legitimate interests of Redruth Town Council.

Redruth Town Council may take photographs or video recordings of the event for the purposes of archiving and future promotions of the event or Council across social media channels (Meta, You Tube, TikTok), our website or in local news publications. If someone can be recognised from a photograph it is usually considered their personal data and subject to the requirements of Data Protection Laws.

There may be circumstances where photography and/or records are taken to assist us with the exercise of our public duty (and is therefore subject to the Public Task lawful basis). However, we may also process photographs and recordings outside of the scope of our Public Task, such as promotion and marketing, where we assess there to be a legitimate interest.

For library events, both Redruth Town Council and Cornwall Council may act as independent controllers in respect of your image used for their promotional purposes. Redruth Town Council may also host ‘joint’ events with partners, in which case the relevant partner organisation may also collect and use your personal data (including photography) for its own purposes. Where this applies, we will seek to identify the partner organisation in relevant transparency notices and direct you to its privacy information where reasonably practicable.

Attendees will be made aware of photography and recording this through appropriate signage at the entrance to the event or an announcement during the event commencement. If you do not wish to appear in photography or footage, please inform the photographer at the event or contact the Council.

Volunteering or Performing at a Redruth Town Council Event (such as the Festival)

Redruth Town Council organises several public festivals and events each year and regularly seeks volunteers and participants for those events. This can include musicians, artists and performers of any age (including children).

Calls for volunteers and participants are normally made by Redruth Town Council via its website, marketing materials and social media channels. We typically collect this data and store this using Google Forms. We will ask for information necessary to facilitate your volunteering or participation – for volunteers this is set out under “I am a Volunteer for the Council or Library’ above.

For participants, such as musicians, workshop hosts and performers, we will request information such as name, contact details, age and information/examples of their offering (such as pictures of art, video of performance or audio for music). In some circumstance, we may consider it necessary to obtain further information from you such as CV, evidence of security screening (where your workshop or participation would require you to engage with children or vulnerable adults) or references. Where a participant is under the age of 16 years old, we will also request parental/legal guardian details and authority to participate. Such information is normally stored on Redruth’s systems and within Google Forms.

This section shall not apply to Traders and we direct you to “I am a Festival or Event Trader”.

Wanting to learn more about the Town Market

Redruth Town Council operates Redruth Town Market in conjunction with other local organisations. It has the legal power to establish and administrate a market under its public powers. Personal data collected by Redruth Town Market for this purpose may include names and contact details for people expressing an interest in hearing our the Town Market; along with trader information (please see “I am a Festival or Event Trader”) for more information on how we use your data.

When you visit any website managed by Redruth Town Council (redruth-tc.gov.uk or discoverredruth.co.uk), we may automatically collect your personal data to gather analytics, improve services and functionality and enable you to contact us. This data may include internet protocol (IP) address, your login data (if applicable), browser type and version, time zone setting, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. We collect this information as it is necessary for our legitimate interest to keep our website updated, relevant and effective. We also use this information to further develop our public engagement strategy.

There may be separate occasions when collection of data, such as assessing effectiveness of our community engagement projects and services, is required to meet our Public Task under Data Protection Laws

We collect this personal data by using cookies and other similar technologies. Please see our cookie notice for further details.

Redruth Town Council’s websites may contain links to third-party website(s) or social media channels. These are supplied for information only and Redruth Town Council cannot be held responsible for any content, or privacy practices of those external third parties. We encourage you to take steps to verify the third-party and review their privacy notices.

We do not currently operate an account registration and profile function on our websites.

Redruth Town Council uses social media platforms to share updates, promote community events and initiatives and engage with residents. When you visit any social media page managed by Redruth Town Council – such as Redruth Town Council Facebook, Redruth Library Tik Tok, Instagram, You Tube and Redruth Town Mayor (jointly managed by the Council and the Mayor – we may receive your personal data through your comments, messaging, tagging or other interactions.

We process this information as we have assessed it necessary to perform our Public Task (to communicate with the community and respond to enquiries). Please be aware that social media platforms are public environments, meaning anything you post may become visible to others depending on your and Redruth Town Council’s privacy settings. Posts and comments may also remain on our social media feeds unless you or we take action to remove them (which is not always fully effective, particularly where content has been shared with others). For this reason, we strongly discourage sharing any sensitive or personal information via social media. We also encourage you to consider the impact of your content on yourself and the wider community. You must also be aware that, while social media channels connect you to our accounts, they process your personal data and operate as independent controllers. We encourage you to review the privacy policies of the platforms you use. We cannot be held responsible for your use of social media to connect with or contact Redruth Town Council.

If we need further details to respond to your enquiry, we may ask you to contact us through a more secure channel.

While we welcome active and respectful community engagement, Redruth Town Council will not tolerate any form of abuse, threatening behaviour or offensive language/behaviour across its social media pages. Content of this nature, including any identifiable information connected to the communication, shall be immediately reported to the relevant law enforcement agency. Redruth Town Council may also take steps to block your profile or account from any further interaction with our social media channels.

In many cases, our social media channels may be used to communicate about specific Redruth Town Council services or responsibilities. Where this applies, please refer to the relevant section of this privacy notice alongside this one.

Redruth Town Council’s social media channels may contain links to third-party website(s) or social media channels. These are supplied for information only and Redruth Town Council cannot be held responsible for any content, or privacy practices of those external third parties. We encourage you to take steps to verify the third-party and review their privacy notices.

Allotments

Redruth Town Council’s allotments are leased to, and managed by, the Redruth Amateur Growers Association (RAGA). Redruth Town Council does not process the personal data of allotment applicants and users and we instead direct you to the Association for more information on how your personal data is used for this purpose email:redruthaga@gmail.com.

Bus Shelters, Parks and Open Spaces, Public Conveniences, Redruth Community Centre

Redruth Town Council holds the public duty to provide public services in respect of Bus shelters, parks and open spaces, public conveniences, Redruth Community Centre (please see “Redruth Community Centre”). In order to service this requirement, we may use personal data belonging to the public (please see “You wish to report an issue related to a Council Service”), and to contractors we appoint to assist us in the maintenance of those facilities (please see our Employee, Worker, Volunteer and Contractor Privacy Notice available by direct request).

CCTV and Community Safety Initiatives

For the detection and prevention of crime in its area, Redruth Town Council has the statutory power to:

• Install and maintain any equipment;
• Establish and maintain any scheme; or
• Assist others to install and maintain any equipment or to establish and maintain any scheme.

Redruth Town Council, together with other contracted Participant Councils, exercise this power through the operation of the Redruth Town Council CCTV Scheme. More information on how we process public personal data for CCTV purposes can be found under ‘Redruth Town Council CCTV Scheme’.

In compliance with our Public Task, we may also participate in local safety initiative, such as Business Improvement Districts or assist with Cornwall Council with its statutory law enforcement activities, including the work of Anti-Social Behaviour Officers. This may involve the processing and, where necessary, sharing of personal data, including but not limited to CCTV Footage or data derived from such footage. Where relevant, Redruth Town Council will put in place data sharing and data processing agreements to support such activities.

You wish to report an issue related to a Council Service

Redruth Town Council maintains public conveniences in New Cut Car Park, park and open spaces, bus shelters, tourist information and footpaths. We will ask for your name and contact details when you raise any report regarding these services so that we may contact you with updates. We have assessed this activity to form part of our Public Task under Data Protection Laws. If you do not wish to receive updates, you may raise a report anonymously. Where necessary to maintain the service, we may share your report with our third-party contractors.

Where you raise a report in respect of services not maintained by Redruth Town Council, such as abandoned vehicles, benefits enquiries, council tax enquiries, dog fouling, highway matters, waste management, street cleaning and lighting, we shall forward your report to the relevant authority (normally Cornwall Council). This disclosure is made as part of our public duty.

You need to make a payment to the Council

You may be required to make a payment to the Council in respect of services (or other payments). When processing any payment, the Council will collect and store financial and transactional data such as bank account details, payment card details, services you have purchased from us, and information about how you use our website, products and services. This information will be shared with our bank and, where applicable, our third-party payment processing suppliers.

We take steps to minimise storage of personal payment details on the Redruth Town Council IT System, and where necessary, retention will occur in accordance with our Retention Policy.

How Redruth Town Council works with Schools

Redruth Town Council regularly engages with local Schools to keep them updated on council function, library outreach, local initiatives and events that might be of interest to its students (such as workshop dates and parade engagement). We have assessed this activity to form part of our Public Task under Data Protection Laws. To achieve this, we maintain a list of School officers who are happy to receive such communications. Any recipients are welcome to opt-out of communications at any time.

You are a member of the Press

Redruth Town Council regularly engage with local press to keep them updated on Council functions, news and activities. We have assessed this activity to form part of our Public Task under Data Protection Laws. To achieve this, we maintain a list of press outlets and recipients who are happy to receive communications, with those recipients being welcome to opt-out of communications at any time.

You subscribe to, or appear in, our Council publications (including Redruth Record)

Redruth Town Council publish a quarterly community publication called the Redruth Record, designed to promote local engagement and share news, updates and opportunities with residents.

When you choose to submit content for inclusion in the publication, we will collect your name, contact details and the information you provide in your submission (such as event details, images or news items). The information is used to review, prepare and publish your submission in the publication, with the publication being in support of our Public Task.

Images, sensitive information or stories featuring identifiable individuals will only be included where we have a lawful basis (and, where necessary, the statutory conditions) to do so. If your submission contains details about another person, please ensure you have their permission before providing their information. We may ask that you obtain a written consent from the individual prior to publication.

Submissions are made via the designated Google Form, with is linked and promoted through our website and social media channels. Information is stored on Redruth Town Council’s systems and within Google Forms. We process personal data only for the purpose of managing, editing and publishing the publication and to contact you to discuss any proposed inclusion (where necessary). Your submission will be handled in accordance with the Publication Terms and Conditions.

You may seek to withdraw a submission. Where a submission is requested for withdrawal, we shall use reasonable endeavours to remove the content from our publication. However, there may be deadlines making withdrawal incapable of being actioned (for example, the publication has already been sent to print or circulated). We urge you to consider this prior to making a submission.

You receive signposting or assistance from Redruth Town Council or the Library

Redruth Town Council is under a legal duty to assist voluntary organisations to provide for individuals advice and assistance in relation to their individual rights.

This activity may include, discussing and directing you to appropriate services external services such as Citizens Advice Bureau. We have assessed this activity to form part of our Public Task under Data Protection Laws. There may be occasions where the personal data shared by you constitutes Special Category Data or confidential information and our lawful basis for processing this information is your Explicit Consent.

You may ask that we liaise with third parties on your behalf. This could be charities, branches of local government, law enforcement, support services or crisis lines. To enable this sharing activity, in most cases we will ask for your consent. However, a lack of consent shall not impede staff from liaising with third parties where it is in your (or another’s) vital interests or where we have a legal duty.

Business Liaison

Redruth Town Council employs a Business Liaison Manager to provide support to business owners and officers within the community. In providing this service, our Business Liaison Manager and Redruth Town Council is likely to process business owners name, contact details, address, business address and other sensitive or confidential categories of data including but not limited to financial information, business operations, staffing matters and details or details relating to challenges impacting your business.

We process this information to enable our Public Task of supporting local economic activity and to assist businesses in access guidance, resources and relevant services. Any information you provide will only be used for the purpose of delivering support to your business and will not be shared outside Redruth Town Council unless the recipient is one of our approved third-party contractors or processors, we are required by law or where professional advice is necessary. In such cases, we will endeavour to minimise the data where possible.

You are (or work on behalf of) a Grant Applicant or Recipient

Redruth Town Council provides, administers and monitors grants to support local community, cultural, charitable and public interest activities. If you apply for, receive or are connected with a Council grant, we may collect and use personal data to assess eligibility, consider the application, make a decision, administer any grant award, make payments, monitor use of funds, meet audit and financial reporting requirements, and deal with any queries, complaints or recovery action.

The personal data we process may include the applicant’s name, role or position, organisation name, contact details, address, bank or payment details, information contained in the grant application, supporting documents, correspondence, monitoring reports, evaluation information and records of any funding decision. Where an application is made on behalf of an organisation, we may also process personal data relating to officers, trustees, committee members, project leads, referees, beneficiaries or other individuals named in the application or supporting materials.

We have assessed this activity to form part of our Public Task under Data Protection Laws, including the Council’s functions in supporting local community initiatives and ensuring proper stewardship of public funds. Where we need to process financial records, accounting information, audit records or information required for transparency and governance purposes, we may also process personal data to comply with our legal obligations. In limited circumstances, a grant application may include Special Category Data, for example where information is provided about health, disability, accessibility needs or community characteristics. We ask applicants not to provide this type of information unless it is necessary for the grant application or monitoring requirement. Where Special Category Data is provided, we will only use it where we have an appropriate lawful basis and condition under Data Protection Laws, and we will minimise the information used wherever possible.

Grant applications and related records may be shared internally with Council officers and Councillors involved in the grant decision-making, governance, finance, audit or monitoring process. We may also share information with professional advisers, auditors, banks, payment providers, insurers, other public authorities, funders, law enforcement agencies or regulators where this is necessary and lawful. Where may use third-party systems or suppliers to administer grants, those suppliers will be required to handle personal data in accordance with our instructions and appropriate contractual safeguards.

As a public authority, we may publish limited information about grant awards for transparency, accountability and public reporting purposes. This may include the name of the recipient organisation, the amount awarded, the purpose of the grant and the relevant Council decision. We will not normally publish personal contact details, bank details or unnecessary personal information.

If you provide personal data about another individual within a grant application or monitoring report, please ensure that the individual is aware that their information has been provided to us and direct them to this privacy notice where appropriate.

Grant records will be retained in accordance with the Council’s Retention Policy, including any periods required for audit, financial management, public accountability, complaint handling or legal purposes.

You wish to participate in the National Databank Scheme

Redruth Town Council may participate in the National Databank Scheme, which is run by Good Things Foundation through local Digital Inclusion Hubs to provide free mobile SIM cards and mobile data to people who are experiencing data poverty or who otherwise need support to access the internet. The scheme is intended to support digital inclusion by helping eligible individuals stay connected and access online services.

If you ask to participate in, or receive support through, the National Databank, we may collect and use your name, contact details, age confirmation, information about your eligibility for the scheme, details of the support requested or provided, and records of any SIM card, voucher or data package allocated to you. We may also record practical information needed to help you use the SIM card or access digital support.

We will process your personal data for the National Databank Scheme with your consent. This means that, where you ask to participate in the scheme, we will use the minimum personal data necessary to check eligibility, administer the allocation of a SIM card, voucher or data package, provide related support, and keep appropriate records. You may withdraw your consent at any time by contacting us, but this may affect our ability to provide, continue or evidence the support available through the scheme.

We ask that you do not provide Special Category Data unless it is necessary to explain your eligibility or support needs. Where Special Category Data is provided, such as information about health, disability or accessibility needs, we will only use it with your explicit consent and where it is necessary for the purpose for which it was provided. We will minimise the information used wherever possible.

We will share relevant information with Good Things Foundation, participating mobile network providers, and any third-party systems or suppliers used to administer the National Databank, but only where this is necessary and lawful to confirm eligibility, allocate or activate support, provide assistance, keep appropriate records, or comply with scheme administration requirements. Good Things Foundation and participating network providers may also process your personal data for their own purposes, and you should refer to their privacy information where this applies.

Records relating to National Databank support will be retained in accordance with the Council’s Retention Policy, including any periods required for audit, scheme administration, complaint handling or legal purposes.

Special assistance

If you need special assistance when visiting Council premises, we will ask for your name, contact details and any relevant health information so that we can make the best possible arrangements for you. We will only use this information with your consent, as required by Data Protection Laws (Article 6 and 9). If you choose not to give consent, you can still share general details that would assist your visit but please note that the help we can provide may be limited. For information on accessibility to our buildings, contact us in advance.

CCTV

When you visit a Council owned or maintained premises, your image, sound and movements may be captured by our CCTV systems. CCTV data captured can include (but is not limited to images, video and sound) gathered by Closed Circuit Television, Automatic Number Plate Recognition and other surveillance technologies installed at our premises. We collect this data as the Council has assessed there to be a legitimate interest in maintaining the security of Council property, safeguard its visitors, contractors and its staff and prevent crime or damage.

Where necessary, Redruth Town Council conducts appropriate impact assessments to ensure that its use of CCTV is lawful, fair and transparent.

Building Access Controls

The safety and security of our staff and visitors is very important to us. To achieve this, we will collect and store personal data of visitors including their name, job role, entry time and exit time, as well as who they are visiting, within our sign-in records, and we will also use such information to issue (and record) ID badges which must be visual throughout your visit. We do so as part of our legal obligation to protect your wellbeing in the event of an incident or fire on our premises, and to ensure the continued wellbeing of our staff. These controls are typically administered by the library front desk.

Redruth Community Centre

Redruth Community Centre is owned by Redruth Town Council but is run and managed by the Redruth Community Association. For information on how they use your personal data, please contact the Centre or Association directly.

Redruth Town Council welcomes constructive feedback and is committed to improving its services to meets the needs of the community. When you choose to submit your feedback or make a report, we will collect your name and contact details so that we can respond to you and keep you updated on any arising action points. Providing this information is entirely optional and you may give feedback anonymously if you would prefer.

We process this information as part of our Public Task to you as it helps us to understand, review and improve the services we provide. Your information will only be used for this purpose and will not be shared outside Redruth Town Council unless there is a reason discussed in this notice, we are required by law to share your information or we need to obtain professional advice. We will only share the minimum necessary to deal with your feedback.

In some circumstances, your feedback may relate to matters that fall outside Redruth Town Council’s responsibilities. Where this happens, and to ensure your feedback is handled accurately and effectively, we may need to pass it to the appropriate organisation, such as Cornwall Council. In this case, all information provided to us will be shared in full so that the receiving body has the context required to address the feedback appropriately. For more information on reporting a public services issue, rather than general feedback, please see “You wish to report an issue with a public service”.

All feedback is stored securely and handled in line with our obligations under Data Protection Laws. While we welcome constructive feedback, Redruth Town Council will not tolerate any form of abuse, threatening behaviour or offensive language. Communications of this nature, including any identifiable information connected to the communication, shall be reported to the relevant law enforcement agency.

Redruth Town Council regularly conducts surveys as part of its public duties to engage with the community and understand public views. For example, we may ask for feedback about our events or local initiatives, and we undertake from time to time a “Residents Survey”. Participation is on a voluntary basis and we typically use online platforms such as Google/Microsoft Forms or Qualtrics or paper form (distributed through our Library) to compile responses, and invitations to participate are normally made to you in-person, through our website, marketing materials and our social media channels.

Our surveys are designed to gather general insights, rather than information relating to a specific individual and we have implemented technical and organisational measure to minimise personal data collection wherever possible. There may be occasions where we require your personal data, such as asking for your name and contact information where you have specifically requested follow-ups to your survey entries. We have assessed this activity to form part of our Public Task under Data Protection Laws There may also be occasions when special categories of personal data are collected to meet our objective, such as seeking feedback on our accessibility measures at events. This information is supplied by you with your explicit consent and is freely withdrawable at any time.

For information regarding our Resident’s Survey, this can be found below.

Please note that once submitted, we may use your responses to form aggregated, non-personal data to assist with current or future Council activities. Any withdrawing your consent will not apply to any aggregated datasets which have been created from your responses.

Some of our third-party survey suppliers (including Google, Qualtrics etc) are based, or may transfer data, outside of the UK to restricted countries. Such suppliers have been assessed as suitable for the Council’s use, and the Council has ensured that appropriate safeguards are in place to protect your personal data. Safeguards may include adequacy decisions, the use of standard contractual clauses or an International Data Transfer Agreement, or other lawful transfer mechanism.

Resident Survey

As part of the Council’s public duties to understand the demographics and needs of local residents (and improve services), we may circulate surveys to residents in hard-copy or electronically (via third-party software such as Qualtrics, Google Forms etc). These surveys are entirely voluntary and will typically collect information such as your age-band, gender, ethnicity, postcode and whether you or anyone in your household has a disability. You are free to decline to answer any question you wish. Where possible, your personal information will be anonymised before being used by the Council (and any lawfully instructed third parties) to evaluate feedback. We have assessed this activity to form part of our Public Task under Data Protection Laws, however any Special Category Data supplied by you is given with your Explicit Consent and is freely withdrawable at any time.

Prize Draws

By way of thanks for your time and participation in our surveys and other events/activities run by the Council, we may invite you to enter a prize draw. For this we will also ask you for your email address and name, both of which are mandatory requirements to enter the prize draw.

This activity is separate to any public task described above and, where possible, the email address and name shall be separated from your data collected for the purpose of performing our Public Task (for example, your resident survey entry). We will ask for your consent to participate in this prize draw, which you may withdraw at any time by contacting us.

The Council promote several communication channels involving direct communications. These communications are normally sent using our third-party supplier, Brevo. Our lawful basis for sending you such communications will depend on the communication itself, for example:

Council-Related Communications

You may receive unsolicited information regarding Council Services (such as notice of change or updates) and publicity around the Council’s functions which are sent as part of our public duty. You may opt-out of such communications at any time.

Enterprise Marketing

There may be limited circumstances when Redruth Town Council uses your personal data to send direct marketing promoting commercial enterprises of the Council, such as paid-for events or fundraising. This is normally done with your consent which you can withdraw at any time by unsubscribing or contacting us directly. We may use analysis of those marketing activities to study how recipients engage with our marketing materials (open rates, bounce back rates etc) and improve/inform our marketing strategy. We have assessed this analysis to be in Redruth Town Council’s legitimate interest.

For previous attendees to our commercial events, we may use your name and contact information to contact you about similar events. We have assessed those communications to be in our legitimate interest by promoting the Council’s commercial ventures and we circulate those emails in compliance with our duties under the Privacy of Electronic Communication Regulations 2003 by offering you the opportunity to opt-out at the point of data collection and in every communication of this nature thereafter.

Other Newsletters

As a newsletter subscriber you have provided your consent to receive the newsletter until such time as you opt-out. In accordance with the accuracy and data minimisation principles, we may automatically remove subscribers who do not engage with our newsletter.

If you have been named as a next of kin by one of our employees, workers or volunteers, we will collect and store your name and contact details. This information is provided to us by the individual who named you and will be used for emergency contact purposes (when contacting you is in the person’s vital interests) or to meet our legal obligations in relation to health and safety. We will only share your details outside the Council in the case of an emergency or when required by law.

Redruth Town Council works with a wide range of local organisations to support community initiatives. This includes Redruth Revival CIC, Redruth Community Association and Redruth Chamber of Commerce. In most cases, the information shared between the organisations will be non-personal data. However, there may be occasions where an organisation shares personal data with the Council so that we can assist them in delivering their services or achieving their community objectives. Where personal data is shared with us, we will agree appropriate data-sharing or data processing arrangements with the originating Data Controller (the third-party organisation) to ensure that all processing is lawful, fair and secure in line with legal requirements. Where we lawfully source personal data indirectly from you, such as through publicly available records, partner organisations, event platforms or social media, we commit to providing you privacy information within one month unless an exemption applies.

For more information on how each organisation uses your data, please visit the relevant privacy notices available on their respective websites, some of which have been listed below, or by contacting us direct:

• Home – Redruth Revival
• Redruth Chamber
• Redruth Community Centre | Facebook

The Council does not routinely share personal data it holds with third-party organisations. We may, however, share findings and insights, research outcomes, statistical information that has been anonymised of all identifying features or is of a a non-personal nature.

This section applies where you are a supplier, prospective supplier, service provider, professional adviser or business contact of Redruth Town Council, and we process personal data about you in that capacity. It does not apply where you are engaged personally as an employee, worker, volunteer, councillor, officer or contractor of the Council. Those individuals are covered by the separate Member, Officer, Volunteer and Contractor Privacy Notice.

We may collect and use personal data relating to suppliers and supplier contacts so that we can assess, enter into and manage contracts, receive goods or services, process invoices and payments and otherwise maintain appropriate records to comply with audit and financial reporting requirements, manage complaints or disputes, and protect the Council’s legal, financial and operational interests. The personal data we process may include names, job titles, work contact details, business addresses, correspondence, tender or quotation information, insurance details, professional registrations, accreditations, bank or payment details, purchase order and invoice records, contract records, delivery information, meeting notes, service performance information and records relating to complaints, incidents or disputes.

Most supplier-related processing to be necessary for the performance of a contract with you, or to take steps before entering into a contract. Where we process supplier information to meet procurement, financial management, audit, transparency, tax, accounting, health and safety or statutory reporting requirements, we may also rely on compliance with our legal obligations or the performance of our Public Task. Where necessary, we may rely on legitimate interests, for example to manage supplier relationships, obtain professional advice and protect the Council’s legal and commercial position.

Supplier information may be shared internally with Council officers and Councillors where needed for procurement, contract management, governance, finance, audit, service delivery or decision-making purposes. We may also share supplier information with the categories of third parties already described in this notice, including banks, online payment providers, professional advisers, insurers, auditors, IT support services, website and software providers, secure document disposal services, couriers, fraud prevention agencies, credit reference agencies, other public authorities, regulators and law enforcement bodies where this is necessary and lawful.

If you provide personal data about your staff, subcontractors, representatives or other individuals as part of a supplier relationship, you should ensure that those individuals are aware that their information may be provided to us and direct them to this privacy notice where appropriate. Where the individual is working with us in a contractor capacity and is covered by the separate Member, Officer, Volunteer and Contractor Privacy Notice, please refer them to that notice instead.

Emergencies, community safety and emergency planning

In rare situations, we may need to use your personal information to protection a person’s life or prevent serious harm. This maybe you or another person. This could involve sharing details with emergency services and other necessary third parties. We will only process and share the minimum information necessary to respond to the emergency. We will never use this information for any other purpose unless lawfully permitted and we will keep adequate records of any data shared for this purpose.

We may also use your personal data to assist Redruth Town Council’s limited public duties in respect of emergency planning and community safety. We have assessed these activities to form part of our Public Task under Data Protection Laws For this. Such activities may process personal data – of varying categories and minimised where possible – to enable us to:

• identify vulnerable individuals within the community that may require extra support;
• identify the best communication strategies for use in an emergency;
• make arrangements for providing information to emergency services (such as geography, infrastructure and critical resources);
• information relating to local resources, volunteers and individuals that may assist in an emergency;
• provide training to volunteers (please see “You are a volunteer of Redruth Town Council for more information); and
• circulate public safety communications such as fire safety and awareness, flood readiness and climate measures.

There may be occasions where we may instruct a third-party, such as project consultants, contractors or specialist service providers, to assist us with these duties and, potentially gather this information (including personal data) on our behalf. Such third parties act under our direction and are required to comply with strict contractual and technical safeguards to ensure your data is handled lawfully, securely and only for the purpose specified by Redruth Town Council.

Council Legal Obligations

An addition to this privacy notice, where the Council is legally required to collect personal data to fulfil statutory duties, we will inform you of this at the point of collection.

Health and safety

We may process your personal data to meet our statutory requirements in respect of health and safety. For example, should you suffer an injury while visiting one of our premises, we will need to make a record of this and our responsive actions. This is necessary to comply with the Council’s legal obligations. We may also use this information to exercise and defend our legal rights.

Statutory obligations as a Local Authority

As a local authority, we are subject to many legal obligations that require us to process certain personal data to meet those duties. The obligations derive from laws that govern how a Council should operate and deliver services to the community, including but not limited to the Local Government Act 1972 (and 1997), Local Government and Rating Act 1997. We collect and use the minimum information necessary to meet these requirements and always in compliance with Data Protection Laws. Such duties will include but is not limited to:

• to keep and maintain records, including Council and third-party archiving of Council Records;
• to convene and hold meetings;
• to provide buildings for offices and for public meetings and assemblies;
• create and maintain a Neighbourhood Plan;
• participate in local resilience initiatives and forums;
• conduct Council-led projects and feasibility studies; and
• execute any formal consultative roles in respect of planning such as responding to planning consultations, executing neighbourhood planning responsibilities and any other statutory duty or notification duties relating to land use, development proposals and local infrastructure, where processing personal data is necessary for the Council to understanding potential impacts on the community and discharge its legal duties;
• the maintenance of official records such as minutes of meeting, registers and statutory returns;
• complying with transparency and accountability requirements, such as responding to Freedom of Information (FOI) and Environmental Information Regulations (EIR) requests;
• encourage visitors to Redruth and the provision of conference facilities and encouragement of use of those facilities;
• financial and compliance auditing and reporting; and
• supporting democratic processes such as maintaining elections or consultations required by law.

There may be occasions where we may instruct a third-party, such as project consultants, contractors or specialist service providers, to assist us with these duties and, potentially gather this information (including personal data) on our behalf. Such third parties act under our direction and are required to comply with strict contractual and technical safeguards to ensure your data is handled lawfully, securely and only for the purpose specified by Redruth Town Council.

• To administer and protect Redruth Town Council’s systems (including its Websites and Social Media).

Redruth Town Council, together with its lawfully appointed third-party suppliers and data processors, process personal data to keep Council system’s secure, efficient and protected against fraud or misuse. To achieve this, we may:

• share data held by the Council with our IT support teams and website providers to troubleshoot issues and to maintain security and functionality at all times;
• hold or obtain data from third-party software providers comprising part of Council systems. Third-party suppliers are heavily vetted to ensure compliance with data protection compliance and we impose strict contractual terms to protect data flowing through the third-party system;
• we may share data with professional advisers to protect the Council’s legal and financial interests, for example during audits or when seeking legal advice;
• where physical delivery of documents or equipment is required, we may share minimal contact details with trusted couriers to complete the delivery and
• conduct troubleshooting, data analysis, testing, system maintenance, support reporting and hosting of data a necessary to meet our public duty and comply with our legal obligations.

To manage payments, fees and charges (including the collection and recovery of money owed to us)

Under its legal powers, Redruth Town Council may, for the promotion and protection of the interests of the inhabitants of their area, institute or defend any legal proceeding, and do anything which is facilitative, conducive or incidental to the discharge of any of its functions. Under these power, Redruth Town Council may use your personal data to manage and process payments, fees and charges (including collection and recovery of public funds owed to the Council). For this purpose, Redruth Town Council may use a person’s name, contact details, registered residential address, bank details, card details and any other information reasonably required to verify identity, issue invoices, receive payments or take recovery action on outstanding amounts.

Under the Data Protection Laws your rights are:

• To be informed – We must make this privacy notice (sometimes referred to as a privacy notice) available to you and be transparent about how we process your data.
• Access – Subject to lawful exemptions available to the Council, you are entitled to know what details we hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. You can find out if we hold any of your personal data by following the procedure set out within our Data Subject Right Policy. Such requests should be made using the contact details provided in this notice. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing. Our response will:
• confirm that your data is being processed;
• verify the lawfulness and the purpose of the processing;
• confirm the categories of personal data being processed;
• confirm the type of recipient to whom the personal data have been or will be disclosed; and
• let you have a copy of the data in format we deem suitable or as reasonably required by you.
• Disclosure of personal data shall be subject to various lawful exemptions.
• Rectification – We are obliged to correct or update your details.
• Erasure – This is also known as the right to be forgotten. You have the right to require us to erase your personal data under specific circumstances.
• Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data in certain circumstances.
• Portability – You have the right to obtain the personal data that you have provided to us in a commonly used machine-readable format and reuse it with a different provider.
• Object – You have the right to object to us processing your data in certain circumstances. You have an absolute right to stop your data being used for direct marketing, but in other circumstances we may still be allowed (or required) to process your personal data if we can show you that we have a compelling reason for doing so.
• Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
• Withdraw consent. Where you have given us consent to process your personal data, you can withdraw that consent at any time. This is normally achieved by contacting us using the details set out in this notice, or by following the opt-out links in electronic messages where relevant. We do not penalise individuals who wish to withdraw consent and we act on withdrawals of consent as soon as we can.

If you wish to make a request to exercise any of the above rights, we ask that you follow the procedure set out within our Data Subject Rights Policy. If you unsure how to make a request to exercise your rights, please contact our team using the details below and we will assist with your request.

Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by Data Protection Laws and as summarised above.

If you agree and your request is simple, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

We keep our privacy notice under regular review. This version was last updated on the date given under Document Controls above. A summary of our recent changes can also be found under Document Controls above.

Adequacy Regulations / Decision: The term ‘adequacy’ originated in the EU. It describes countries (or territories or sectors in a country) or international organisations which the European Commission has assessed as having an “essentially equivalent” level of data protection to that of the EU. The term is similarly used in the UK to describe countries (or territories or sectors in a country) or international organisations, that the UK government has assessed as having a level of data protection that is “not materially lower” than provided for by UK law.

Aggregated Data: statistical data about several people that has been combined to show general trends or values without identifying people within the data.

Anonymised data: Information that has been altered to render the data incapable of identifying individuals.

Automated decision-making: A decision made solely by automated means, without human intervention.

Criminal Offence Data: Personal data relating to criminal convictions, offences and related security measures. This covers information about offenders or suspected offenders in the context of criminal activity, allegations, investigations and proceedings.

CCTV Footage, Participant Councils: Shall have the definition given to it within the Redruth Town Council CCTV Scheme Code of Practice available here.

Cookies: Small text files placed on your device when you access our websites (and some third-party platforms) to support functionality, analytics and performance.

Data Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data Processor: means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Data Protection Laws: The Data (Use and Access) Act 2025 (DUAA), the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), as amended from time to time. Note: DUAA is a new law in the process of implementation. It does not significantly alter the existing data protection regime in the UK but supplements it by creating clarity and strengthening certain provisions.

Lawful Bases: Contractual obligation means processing that is necessary to comply with our obligations arising out of a contract, for example, where you have bought services from us we will use the personal data you provide to fulfil our contractual obligations.

Lawful Bases: Legitimate Interest means in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. Where we use legitimate interests we will record our decision and reasoning. We rely on legitimate interest where processing does not, in our opinion, adversely (and disproportionately) affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest services or obtaining your feedback on our services.

Lawful Bases: Consent means processing your personal data where you have given us clear, informed and specific permission to do so. You may withdraw your consent at any time (see “Your Rights” above), and we will cease processing your personal data for that purpose unless we are permitted or required to continue under another lawful basis.

Lawful Bases: Legal obligation We may process your data where we it is necessary for us to do so to comply with the law.

Lawful Bases: Public Task Where it is needed: ‘in the exercise of official authority’. This covers public functions and powers that are set out in law; or to perform a specific task in the public interest that is set out in law.

Lawful Bases: Vital Interests Where we need to protect your vital interests (or someone else’s vital interests).

Pseudonymised Data: Personal data that has been processed to an extent where is can no longer be attributed to a specific person without additional information kept separately or securely.

SCCc/IDTAs: Both the Standard Contractual Clauses (SCCs) and IDTAs are approved safeguards/agreements to enable the lawful transfer of personal data where adequacy regulations are not in place.

Special Category Data: Personal data that reveals information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data or information about a person’s sex life or sexual orientation.

Special Category Data: Legal obligation We may process your data where we it is necessary for us to do so to comply with the law.

Special Category Data: Public Task Where it is needed: ‘in the exercise of official authority’. This covers public functions and powers that are set out in law; or to perform a specific task in the public interest that is set out in law.

Special Category Data: Vital Interests Where we need to protect your vital interests (or someone else’s vital interests).

Pseudonymised Data: Personal data that has been processed to an extent where is can no longer be attributed to a specific person without additional information kept separately or securely.

SCCc/IDTAs: Both the Standard Contractual Clauses (SCCs) and IDTAs are approved safeguards/agreements to enable the lawful transfer of personal data where adequacy regulations are not in place.

Special Category Data: Personal data that reveals information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data or information about a person’s sex life or sexual orientation.