Privacy policy

1. Introduction
2. Credit
3. How we use your personal data
4. Providing your personal data to others
5. International transfers of your personal data
6. Retaining and deleting your personal data
7. Amendments
8. Your rights
9. About cookies
10. Cookies that we use
11. Cookies used by our service providers
12. Managing cookies
13. Our details

1. Introduction

  • 1.1 We are committed to safeguarding the privacy of our website visitors.
  • 1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
  • 1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
  • 1.4 In this policy, “we”, “us” and “our” refer to Tilehurst Neighbourhood Plan.

2. Credit

  • 2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).

3. How we use your personal data

  • 3.1 In this Section 3 we have set out:
    • (a) the general categories of personal data that we may process;
    • (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
    • (c) the purposes for which we may process personal data; and
    • (d) the legal bases of the processing.
  • 3.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
  • 3.3 We may process your personal data that is provided by you in the course of the use of our services (“service data”). The service data may include your name, your email address and your IP address. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
  • 3.4 We may process information that you post for publication on our website (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website. The legal basis for this processing is your consent to any applicable terms and conditions associated with the submission and our legitimate interests, namely the proper administration of our website.
  • 3.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent to receive such information by signing up to our list via Mailchimp, any other online sign-up form operated by us, or an offline sign-up form.
  • 3.6 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
  • 3.7 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • 3.8 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
  • 3.9 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  • 3.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

  • 4.1 We may disclose your personal data to any member of our Steering Group insofar as reasonably necessary for the purposes set out in this policy.
  • 4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  • 4.3 Online subscriptions to our email notifications and/or newsletters are handled by our provider MailChimp. Your information is shared only to the extent necessary for processing these subscriptions and ensuring that requests to unsubscribe are honoured. It is held securely on MailChimp servers and deleted when it is no longer required. You can find information about our subscription provider’s privacy policies at https://mailchimp.com/legal/privacy.
  • 4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

  • 5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
  • 5.2 The hosting facilities for our website are currently situated within the EEA. Should it become necessary to host our website outside the EEA, we will use a country that is subject to an “adequacy decision” by the EU Commission. Transfers to any such country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. If we host our website in the United States, we will only use companies that are certified to receive data under the EU-US Privacy Shield.
  • 5.3 Some of our providers, such as Mailchimp, operate globally, and may be located in the United States or other countries that do not provide the same standard of data protection as the EU. When we work with a service provider, we look for a legal mechanism that requires them to protect data to EU standards. For example, the service provider has signed on to the EU-US Privacy Shield, operates under EU-approved binding corporate rules, or is in a country the EU recognises as having adequate data protection laws.
  • 5.4 You acknowledge that personal data that you submit for publication through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

  • 6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
  • 6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • 6.3 We will retain and delete your personal data as follows:
    • (a) Usage data will be kept for as long as is needed for the purposes of analysing the use of our website and services.
    • (b) Publication data will be retained until such time as you may wish to remove your data from the website, either by deleting your comments, or by requesting that we remove the relevant data.
    • (c) Names and email addresses on our mailing lists will be retained until such time as you may wish to unsubscribe from our lists, or until it has been removed by our list provider(s) as a result of failed delivery.
    • (d) Names, email addresses, and/or personal data contained in surveys submitted through our website will be retained until the Neighbourhood Plan is complete, at the end of which period it will be deleted from our systems.
    • (e) Correspondence data will be retained for as long as is necessary for administrative purposes in connection with the original correspondence.
  • 6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

  • 7.1 We may update this policy from time to time by publishing a new version on our website.
  • 7.2 You should check this page from time to time to ensure you are happy with any changes to this policy.

8. Your rights

  • 8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
  • 8.2 Your principal rights under data protection law are:
    • (a) the right to access;
    • (b) the right to rectification;
    • (c) the right to erasure;
    • (d) the right to restrict processing;
    • (e) the right to object to processing;
    • (f) the right to data portability;
    • (g) the right to complain to a supervisory authority; and
    • (h) the right to withdraw consent.
  • 8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
  • 8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
  • 8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
  • 8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • 8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
  • 8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
  • 8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • 8.10 To the extent that the legal basis for our processing of your personal data is:
    • (a) consent; or
    • (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

    and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

  • 8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
  • 8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  • 8.13 You may exercise any of your rights in relation to your personal data by written notice to us.


9. About cookies

  • 9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  • 9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  • 9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

  • 10.1 We use cookies for the following purposes:
    • a) We use cookies to store your preferences in relation to the use of cookies. Cookies used for this purpose are:
      • catAccCookies
    • b) Our website runs on a WordPress platform. WordPress uses cookies for functionality purposes. If you do not allow these cookies then some or all of our website may not function properly. The relevant cookies include:
      • PHPSESSID
      • wordpress_test_cookie

11. Cookies used by our service providers

  • 11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
  • 11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are:
    • _gat
    • _ga
    • _gid
  • 11.3 We use AddThis to provide sharing functionality on our website. This service uses cookies to enable this functionality. You can view the privacy policy of this service provider at https://www.oracle.com/legal/privacy/addthis-privacy-policy.html. The relevant cookies are:
    • __atuvc
    • __atuvs
  • 11.4 Targeting cookies may be set through our site by third party providers. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. Typically, they do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. The relevant cookies may include:

      youtube.com
      SID
      HSID
      demographics
      VISITOR_INFO1_LIVE
      PREF
      APISID
      SSID
      LOGIN_INFO
      YSC
      SAPISID

      addthis.com
      loc
      xtc
      um
      bt2
      mus
      uid
      uvc
      di2
      vc

      google.com
      APISID
      SSID
      NID
      PREF
      SID
      SAPISID
      HSID

      doubleclick.net
      id

12. Managing cookies

13. Our details

  • 13.1 This website is owned and operated by Tilehurst Neighbourhood Plan steering group on behalf of Tilehurst Parish Council.
  • 13.2 You can contact us:
    • (a) by post, at the Parish Office, Highview, Calcot, Reading, RG31 4XD;
    • (b) using our website contact form;
    • (c) by telephone, on 0118 941 8833; or
    • (d) by email, using steering-group@tilehurstpcnp.org.uk

Last updated: 16/01/2019