Data Protection Policy

Overview

At City of Wolverhampton Council we are committed to protecting your privacy. Under UK Data Protection Act 2018 and UK General Data Protection Regulation (Regulation (EU) 2016/679) (UK GDPR) we are required to protect any personal information we hold about you. The privacy of our users is of paramount importance and we will always treat your personal information as confidential.

Our Data Protection Registration number is: Z5569755

Data Protection officer for the Council is: Head of Information Governance and Customer Assurance – Anna Zollino-Biscotti. Contact them on: DPO@Wolverhampton.gov.uk

This privacy notice tells you what to expect when processing your personal information, how it is used, shared and secured.

In the course of our dealings with you, we may collect and process personal information about you in order to provide you with the services you request and to administer our relationship with you. This may involve the sharing of your personal information with other third parties. We will never sell your information to a 3rd party.

Who are we?

In this Privacy Policy, references to we, us or our (or words of similar import) means City of Wolverhampton Council.

For the purposes of this policy we are the data controller in respect of your personal information that we collect, and process as further described in this Privacy Policy.

As described below, we may share your personal information with other organisations that may receive and process your personal information as a data controller in their own right.

The data we process and store

This section provides you with information about:

what personal data we hold and process;
in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;
the purposes for which we may process your personal data; and
the legal grounds on which we process your data.

Events

When you register to attend one of our events, we may collect your personal information. Often events are run in partnership with another organisation. Your data may be collected from a variety of platforms dependent on the event.

How we use this data:
We may use your contact information to send you updates regarding the event, to allow us to understand more about the attendees and to operate the event on the day.

We process your personal data on the basis of consent, we will only send information related to the event that you have registered for, you may be given the opportunity to also opt-in to receive marketing information.
We hold your data in our own database, which is UK hosted.

We will share some of your personal data with selected third parties. This will include our marketing agencies, our email platform provider, third parties who operate data storage/management systems on our behalf. Full details of such third parties can be provided on request (using the contact details in the how you can contact us section below).

International data transfers, when registering for an event via Eventbrite your data will be shared with the them. Further information on the transfer of personal data can be found in their Privacy Policy here: Eventbrite Privacy Policy | Eventbrite Help Centre

Partners and Projects

We have a wide variety of partners across our programs, streams and projects. You or your employer may provide us with your data to allow us to contact you in relation to the services we offer.

How we use this data:
We will use your contact details to contact you and keep you informed of program updates, invitations to events, performance of services and support.

We process your personal data on the basis of legitimate interest, namely the proper administration of our website and business and communications with users. We will only use your data for the purpose it has been given it to us.
We hold your data in our own database, which is UK hosted.

Enquiries

If you get in touch with us via the contact form on the website, via phone, email or face to face at an event we may save the details you provide us in our database. This way, if you get in touch with us in future we can refer to our previous conversations.

The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you.

The legal basis for this processing is our legitimate interests in responding to your enquiry appropriately. We will not contact you or share your details without asking for your consent.

Website Usage

We may process data about your use of the Site ("usage data"). This 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 use.

This data is obtained through our analytics tracking system, Google Analytics.

Often usage data will be aggregated in such a way that it contains no information pertaining to an individual at all: as such is it not actually personal data but we address it in this Notice for completeness’ sake.

We process this data for the purpose of improving our Site.

The legal basis for this processing is our legitimate interests, namely the improvement of our Site.

Social Media

You may come across us on social media through your own networks, or you may be presented with an ad from us. We target ads at audiences that look like they have an interest in our goods and services. We do this to inform, educate and engage new and existing visitors.

More information on how to control the ads on these platforms more information can be found here:

Facebook: https://www.facebook.com/help/1075880512458213/?helpref=hc_fnav
X formally known as Twitter : https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
LinkedIn: https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en
Instagram: https://www.facebook.com/help/instagram/519522125107875

If you contact us via these channels, please be aware that we have no control over the data provided while on the platforms.

Your enquiry data may be transferred to our database as detailed in enquiry data section.

Other Processing and Data Sharing

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.

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.

We may disclose your personal data to our 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.

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.

Security

We follow strict security physical and logical/technical procedures in the storage and disclosure of information that you have given to us, in order to prevent, as far as possible, any unauthorised access. However, no data transmission over the internet, and no data stored on equipment that is connected to the internet (such as our Website servers) can be entirely secure, so we are unable to provide any guarantee that information stored by us will not be subject to unauthorised access. The use of our Website is at your own risk.

Opt-Out of Communications

You may opt-out of receiving communications at any time by clicking unsubscribe in emails or by contacting us using the details below.

International Transfers

We do not transfer any of your data outside of the European Economic Area unless otherwise stated above.

Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an "adequacy decision" with respect to the data protection laws of the country to which it is transferred, or (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.

How we use Cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use cookies to:

Remember your preferences when using our website
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs, such as remembering the last product you viewed. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website

The legal basis for this processing is our legitimate interests, namely the improvement of our Site.

Retaining and Deleting Personal Data

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. 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. Our data retention policies can be provided upon request using the details below.

Your Rights

You have the following rights in respect of the personal data we hold about you:

a right of access to such data;
a right to object to processing that is likely to cause or is causing you damage or distress;
a right to restrict processing;
a right to decisions made by automated means, including profiling;
a right to have inaccurate personal data rectified, blocked, erased (‘right to be forgotten’) or destroyed; and
a right to claim compensation for damages caused by a breach of relevant data protection legislation.

If you wish to exercise any of these rights, please contact us using the details set out below.

Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data.

Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.

Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. We will analyse each request for erasure and we will agree if there is no legitimate reason to retain the data to the normal retention period, at which point we will instruct anonymization of the data.

Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it 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 our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.

Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.

Your right to data portability. Where you have given us consent to process your personal data for the performance of a contract, you have a legal right to receive a copy of the personal data we hold about you. We will not be accepting Data Portability files from other third-party companies/individuals. When a data request is made of us we will make available all applicable personal data to you in a .CSV file or alternative machine-readable format agreed by us to be passed to the appropriate third party on your instruction. We will not however process your data in this way if we believe that it may pose a threat to the security of the data.

Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.

Automated data processing. Your rights in relation to automated decision making and profiling are explained clearly here by the Information Commissioner’s Office

Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.
You have a right to lodge a complaint with the Information Commissioner’s Office via https://ico.org.uk/concerns/

How you can contact us

If you wish to exercise any of these rights, or you have any questions regarding this policy our data protection team can be contacted via:

E-mail: data.protection@wolverhampton.gov.uk
Telephone: 01902 554498

Post:
City of Wolverhampton Council
Information Governance Team
Civic Centre
St. Peter's Square
Wolverhampton
WV1 1SH

Amendments

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