Consultation Portal Privacy Notice

Tunbridge Wells Borough Council
Mount Pleasant Road
Royal Tunbridge Wells
Kent
TN1 1RS

Email: dataprotection@tunbridgewells.gov.uk

Telephone: 01892 526121

We collect information from you when you visit our website; also when you contact us in writing, speak to us on the phone, by email or any other type of electronic communication, or talk to us face to face.

Information for account registration

To participate in some of the activities you will be asked to register with the website. In the course of registering, you will be asked to provide a user name, which will be what people see if you make a comment on the website. We recommend using an anonymous user name.

You will be asked to provide an email address to create an account which will enable you to take part in some engagement and consultation activities, as well as saving your questionnaire response to complete later. It will also mean you can choose to receive updates on specific or general engagement and consultation activities.

You will be asked to submit your user name and email address to sign into your account on the website.

We may collect equalities data such as your age, gender, ethnic origin and if you have a disability.  We may also collect the postcode or area you live in when you provide it to us on the registration form. We also ask you the topics you are interested in. This information is optional and you do not have to provide it to create an account.

Please note that you are able to browse any publicly accessible sections of this website completely anonymously without signing up.

Engagement and consultation information

This is the content you create as part of your interactions with this website. It can include:

• responses to questionnaires and polls, comments on discussion forums, documents, maps, idea boards, stories and guestbooks or questions asked through the Q&A tool
• equalities data collected through questionnaire response - age, sex, ethnicity, religion, sexuality, disability, pregnancy or maternity or if you are a Carer
• employment and education details
• postcode collected through questionnaire response.

We ask you not to provide information that will identify you in your responses and comments on this website.

You do not need to submit any equalities or postcode information if you do not want to. Any information you do give will be used to see if there are any differences in views for different groups of people, and to check if services are being delivered in a fair and reasonable way.

No personal information which can identify you, such as your name or email address, will be used in producing reports. We will follow our Data Protection policies to keep your information secure and confidential. Your equality data will be anonymised (registration information will be removed) before it is shared with other teams in TWBC or to external organisations who have been commissioned on individual projects to undertake analysis and reporting on our engagement and consultation activities. Please note, permanently anonymised, aggregated data is no longer considered personal data and therefore privacy rights no longer apply.

Usage information

IP addresses are collected for website security purposes by Bang the Table who provide the software for this website. This information will not be linked to your responses and registration information.

We also use Google Analytics to view data related to our website’s traffic and activity. This information may include page visits, length of visit, browser (e.g. Edge, Chrome etc.) or device type (e.g. desktop, mobile etc.) and the site you were on before you clicked over to this website.

IP addresses are held within the Google Analytics platform, which is separate from this website and will not be linked to your responses and registration information.

We collect this information in order to:

• facilitate your participation in our consultation and engagement activities
• understand your views about a particular topic or TWBC activity
• analyse consultation and engagement activity
• respond to enquiries and comments
• understand how users interact with the website and improve how our website functions
• allow you to save your questionnaire responses to complete another time.

We will use your information to:

• inform TWBC’s future strategy, policy, service design and budget planning
• undertake equalities monitoring
• authenticate and verify your account (through your email address)
• communicate information to you about engagement and consultation opportunities, events and other initiatives, if you have requested to be kept informed
• remind you to update your account information
• inform you of the outcome of the engagement and consultation activities, if you have requested updates
• to contact you if you object to a Traffic Regulation Order or in other consultations where we are required to contact you
• protect the integrity of discussion from individuals and groups who may attempt to unduly influence the outcomes of the consultation process
• provide access to private areas of the website for invited users

We may use your postcode to analyse the geographical spread of responses and in some cases to understand in more detail how responses are impacted by location.

We may use your postcode to carry out a type of profiling to estimate which one of a number of lifestyle groups you are most likely to fall into. We do this using geodemographic segmentation tools. We do not make any decisions about individual service users based solely on automated processing, including profiling.

We may share your personal data and feedback with those listed below. In some cases that may include your user name and email address:

• services within the Council who are responsible for the management of the engagement or consultation activity
• a third-party supplier who has been contracted to independently analyse the consultation responses. Registration information (user name and email address) will be removed before data is shared
• organisations such as schools and academies with whom we may be consulting in partnership or on behalf of
• county, district or borough councils or government departments with whom we may be consulting in partnership or on behalf of. Registration information (user name and email address) will be removed before data is shared.
• We will share personal information with law enforcement or other authorities if required by applicable law.

Any personal information provided that could identify you will be removed before consultation results are published.

Bang the Table’s moderators do not have access to your user information stored on this website. Moderators are only able to view publicly visible user names and text or image based contributions for the express purposes of moderating those elements. If you feel a comment or contribution on the site is in breach of the rules you are within your right to alert the moderators through the “alert moderator” link near the comment you believe needs to be escalated to the moderation team. Alerting a moderator will not reveal your identity to the person who posted the comment.

What are your rights in relation to the personal information we process?

• Access – you can request copies of any of your personal information that is held by the council.
• Rectification – you can ask us to correct any incorrect information.
• Deletion – you can ask us to delete your personal information. The council can refuse to delete information if we have a lawful reason to keep this. Please email consultations@tunbridgewells.gov.uk
• Portability – you can ask us to transfer your personal data to different services or to you.
• Right to object or restrict processing – you have the right to object to how your data is being used and how it is going to be used in the future.
• Right to prevent automatic decisions – you have to challenge a decision that affects you that has been made automatically without human intervention, for example an online form with an instant decision.

Where we rely on your consent, you can withdraw your consent at any time.  The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

You can do this by:

• clicking on unsubscribe on any emails received from Let’s talk Kent
• updating your registration profile
• clicking on cookie management buttons when accessing the website
• contacting TWBC directly at consulations@tunbridgewells.gov.uk

The personal information you provide to create an account (register) will be kept unless it has been inactive for more than two years.

We will hold any personal information provided by you as part of engagement or consultation activity for up to six years following the closure of a consultation.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

While no online service is completely secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take all reasonable measures to do so.

We want to ensure any information we hold is accurate. You can help us by promptly informing us of any changes to the information we hold about you.

This website is moderated by Bang the Table’s moderation team who provide support to ensure participants are safe from malicious, inflammatory, and illegal materials. If you post something to this website, which is removed by the moderators, you will receive a notification via email informing you of the decision. You will be informed as to which of the moderation rules you are in breach of and asked to review and resubmit your contribution. Moderators do not have access to your user information stored on this website. Moderators are only able to view your publicly visible user name and text or image contribution for the express purposes of moderating those elements.

If you are accessing online services and are aged 13 or under‚ please get your parent/guardian's permission beforehand whenever you provide us with personal information.

We use cookies to record information about your visits to the website. We may collect information based on your browsing (click stream) activities. This information includes pages browsed, projects viewed, tools used, document downloads and video views. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This information is used to improve how the website functions and to understand how users interact with it.

Some of these cookies are 'strictly necessary' to provide the basic functions of the website and cannot be turned off, while others, if present, have the option of being turned off by users.

If you would like to make a complaint regarding the use of your personal data you can contact our Data Protection Officer:

Email: dataprotection@tunbridgewells.gov.uk

For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner's Office (ICO) at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

Alternatively, visit the Information Commissioner's Office website or email casework@ico.org.uk.