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Consultation and Platform Data Privacy Notice

Controller of the processing of your personal data (hereafter: “the Council”):

  • Name and legal form: Reading Borough Council
  • Registered office address: Reading Borough Council, Civic Offices, Bridge Street, Reading, RG1 2LU
  • Contact details of the Data Protection Officer: Nayana George, IGTeam@reading.gov.uk

Processor on behalf of the Council, and controller for the processing activities mentioned under 3.3 (hereafter: “Go Vocal”):

  • Name and legal form: Go Vocal
  • Belgian enterprise number: 0638.901.287
  • Registered office address: Pachecolaan 34 (6th floor), 1000 Brussels, Belgium
  • Contact e-mail address: support@govocal.com

RBC and Go Vocal commit to respect your privacy and strive to always treat your personal data with the necessary care and confidentiality, to comply with the UKGeneral Data Protection Regulation (“UK GDPR”) and any other applicable regulations.

For further questions or comments regarding the processing of your Personal Data please contact us via the details above.

1. SCOPE OF APPLICATION

This Privacy Notice applies to the processing of your Personal Data as part of the Council’s consultation function, including through the Platform.

2. WHAT IS PERSONAL DATA?

In this Privacy Notice, Personal Data refers to information that makes it possible to identify a living individual. An identifiable person is someone who can be identified, either directly or indirectly, in particular from an identification number or one or more factors that are linked to physical, physiological, mental, economic, cultural or social identity. A typical example of Personal Data is your name and email address.

3. WHAT PERSONAL DATA DO WE COLLECT?

We may collect your Personal Data from the following three sources:

3.1. Personal Data that you provide when registering on the Platform, some of which are optional.

The Personal Data that the Platform collects from you are:

  • First and last name
  • E-mail address
  • Preferred language

Additional data (not mandatory) collected by the Council as part of the registration flow are:

  • Location (Council Ward)
  • Age
  • Sex
  • Gender identity
  • Ethnicity
  • Disability

We may also ask you for the following, where this is relevant to the consultation:

  • Employment status
  • Highest level of qualification
  • Housing tenure
  • Religion

If you choose to sign in via a third party authentication provider such as Google or Facebook, they may provide us with your name, email address and profile photo. The same applies if you choose to verify your identity with a third party identity provider such as COW, NemID, FranceConnect or CSAM.

We may also ask for this data as part of consultations that are carried out outside of the platform.

3.2. Personal Data that you provide when participating on the Platform.

Every action that you take on the Platform (e.g., voting, posting an idea, writing a comment, answering a poll, etc.) constitutes Personal Data and is registered and stored. Such Personal Data is also linked to your registration data (3.1), implying that the Organization can link your profile data to this participation data.

3.3. Personal Data that Go Vocal collects when you visit the Platform.

If you provide permission by accepting cookies on the Platform, Go Vocal (and third party processors acting on our behalf) collect information about the usage of the Platform to assess its proper functioning and security. To this end, Go Vocal may collect technical information about you such as your IP address and browser details. Go Vocal may also gather usage data to improve its services. You can opt out of this collection at all times in your Cookie Settings.

The processing activities mentioned above are based on the legitimate interests of Go Vocal.

4. HOW DO WE USE PERSONAL DATA?

Go Vocal uses your Personal Data for the following purposes:

  • First and foremost, to communicate your input and its relevant context to the Council and to provide aggregated reports of all the data collected on this Platform to assist with their decision-making. This includes understanding who responds to consultations to help ensure the Council is reaching a diverse range of residents.
  • To create and maintain your user profile on the Platform.
  • To manage the identification and authentication of users.
  • To provide information about your community and/or alert you when activities on the Platform may interest you. You can opt-out of email notifications from your user profile at any time.
  • To improve the Platform and to monitor its functionalities.

The Council uses your Personal Data for the following purposes:

·      To provide feedback to you about the survey or where you have agreed to it to keep you informed of other Council activities.

·      To help us see if there are differences between the views of different residents. and to help us understand whether our consultations are reaching a diverse range of residents.

Personal Data is stored as part of a respondent's account for as long as it is active, or for up to 3 years after it has become inactive, at which point it will be deleted.

5. WITH WHOM AND WHERE DO WE SHARE YOUR PERSONAL DATA?

Go Vocal shares your Personal Data with the Council on behalf of which Go Vocal processes such Personal Data. 

Where necessary, the Platform engages external service providers who process Personal Data on its behalf, i.e. (sub-)processors. The Platform will only share your Personal Data with these external service providers to the extent necessary for the relevant purpose. The Personal Data may not be used for any other purpose by these third parties. In addition, these service providers are contractually bound to ensure the confidentiality of your Personal Data by means of a so-called “data processing agreement” concluded with these parties.

Go Vocal will never sell or rent your Personal Data to other service providers, nor will it share your Personal Data with any service provider that is not compliant with the GDPR.

Should the Platform, for limited and specific processing activities, rely on service providers that operate from outside of the EEA, data transfers will only occur to countries that the European Commission has confirmed guarantee an adequate level of protection for your Personal Data, or where other measures have been taken to ensure the lawful processing of your Personal Data.

The Council will not pass personal details on to any other organisation. Personal details may be shared internally within the Council in order to effectively deal with your response. 

Reports of consultations will not identify individuals. Information such as postcodes will rounded up to at least ward level before data is shared. 

Under the Data Protection Act 1998 we have a legal duty to pass information to third party organisations such as the Police, The Department of Work and Pensions and anti-fraud agencies for the purposes of preventing and detecting crime, or for anti-fraud purposes. 

6. HOW WILL THE DATA BE STORED?

Your data is stored on the Go Vocal consultation platform, a secure data system.

Any personal information downloaded from the platform is stored on the Council’s password protected, secure network, with access limited to those processing the data. The computer equipment is only used in line with Reading Borough Council’s ICT security policies and all Council staff are trained in information governance procedures.

7. WHAT IS THE LAWFUL BASIS FOR THE COLLECTION, USE AND STORAGE OF THE DATA?

The lawful bases for processing data are set out in Article 6 of the UK GDPR. We rely on the following as the basis for collecting and using your personal data:

Public task: the processing is necessary to perform a task in the public interest or for your official functions; in particular, the Equality Duty requires public authorities, in the exercise of their functions, to have due regard to the need to advance equality of opportunity between people who share and people who do not share a relevant protected characteristic.

Special category data is personal data that needs more protection because it is sensitive, i.e. personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); health; concerning a person’s sex life; and concerning a person’s sexual orientation.

Special Category Data will be processed under UK GDPR Article 9 and the appropriate condition below:

(a) Explicit consent

(b) Employment, social security and social protection law

(c) Vital interests

(d) Not-for-profit bodies

(e) Made public by the data subject

(f) Legal claims and judicial acts

(g) Substantial public interest conditions

(h) Health or social care

(i) Public health

(j) Archiving, research and statistics

8. WHAT ARE YOUR RIGHTS?

8.1. Right of access

You have the right to view your Personal Data at any time as well as the right to be informed of the use that the Platform makes of your Personal Data. You may also request a copy of the Personal Data that is being processed.

8.2. Right to rectification 

You have the right to rectify inaccurate Personal Data that concerns you. 

8.3. Right to erasure

You have the right to ask the Platform to delete your Personal Data. It is however possible that some Personal Data will still need to be processed. When the Platform deletes your Personal Data, a limited amount of Personal Data may still need to be retained to ensure the Platform can fulfill its obligations under the GDPR. 

If you choose to remove your account entirely from the Platform, your Personal Data will be removed from our servers. Some Personal Data about you may remain in the logging data the Platform keeps for security and legal reasons for up to 30 days.

You acknowledge that a request to delete your Personal Data means that certain services may no longer be delivered. 

8.4. Right to object

You have the right to object to the processing of your Personal Data for serious and legitimate reasons. In addition, you always have the right to object to the use of your Personal Data for direct marketing purposes.

8.5. Right to restrict the processing of your data

You can exercise your right to restrict the processing of your data, if you believe that we are processing your Personal Data unlawfully. You can also request us to restrict the processing if you believe we are processing inaccurate Personal Data about you, for the period needed to verify the accuracy of your Personal Data. The same applies when you exercise your right to object to the processing of your Personal Data. In this case you can restrict the processing for the time needed to verify our legitimate grounds to process your data.

8.6. Right to data portability

You have the right to obtain the Personal Data you have provided to the Platform in a structured, typical and machine-readable form and/or have such Data transferred to different controllers.

8.7. Right to withdraw consent

Insofar as the processing is based on your prior consent, you have the right to withdraw your approval.

8.8. Automated decision-making and profiling

The processing of your Personal Data does not include profiling and shall also not be subjected by Go Vocal to automated decision-making.

8.9. Right to lodge a complaint

You have a right to complain to the Information Commissioner’s Office (ICO) if you are unhappy with how your personal information has been handled by RBC. They can be contacted at:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk

9. HOW TO EXERCISE YOUR RIGHTS

You can exercise your rights by contacting:

  • Either the Council, by submitting a Subject Access Request which can be made by following the link: www.reading.gov.uk/dataprotection;
  • Or Go Vocal, by e-mail to support@govocal.com, or by post to Pachecolaan 34 (6th floor), 1000 Brussels, Belgium, provided you enclose a copy of the front of a proof of identity.

When you submit a request to exercise your rights, we will verify your identity if we have reasonable doubts in this regard. We do so to prevent your Personal Data from falling into the wrong hands. If we have doubts about your identity, we will request you to provide us with documents that enable you to identify yourself without a reasonable doubt, such as a copy of a proof of identity. In this case we urge you to cross out the non-relevant information for the verification of your identity.

Exercising your rights is in principle free of charge. However, if your request appears to be manifestly unfounded or excessive (in particular because of its repetitive character), we may charge you a reasonable fee to cover our own administrative costs. In such cases, we may also simply opt to reject your request. In this event, you will be notified of the reasons for such a decision. 

10. ADDITIONAL INFORMATION ON DATA COLLECTION AND PROCESSING

10.1. Legal procedures

Go Vocal and the Council for whom we process your Personal Data may use the Personal Data for legal purposes, for the court or legal proceedings preceding phases in the event of unlawful use of this Application or the related services. You are aware that Go Vocal and the Council it works with may be obliged to disclose the Personal Data at the request of competent government institutions for the processing of the Personal Data. The legal basis for this processing is the acceptance of the terms and conditions (contractual basis) and the necessity to fulfil a legal obligation.

10.2. Security Measures

The Platform has developed appropriate technological and organizational measures to prevent the destruction, loss, falsification, modification, prohibited access or the erroneous disclosure to third parties of Personal Data as well as any other prohibited processing of this Personal Data. Under no circumstances can the Platform be held liable for any direct or indirect loss resulting from the incorrect or unlawful use of your Personal Data by a third party. You must at all times comply with the security instructions, including by preventing all prohibited access to your login details and password. You are solely responsible for the use made of the Platform on your computer, IP-address and your identification details, as well as for the confidentiality of such.

10.3. Changes to this privacy Notice

The Council and Go Vocal reserve the right to change this privacy notice at any time. When the notice changes in a material way we will notify the users on this page. We encourage you to check this page for possible changes. The date of the last change is indicated at the bottom of the page. If you object to any change in the notice, you must cease to use the Platform. Unless otherwise indicated, the valid Privacy Notice applicable at that time applies to all Personal Data that the Platform processes.

Last updated: Oct 2024