1.
This site uses cookies. We only use cookies to ensure that we are encouraging input from the widest Moray community possible. We are interested in your demographic data. This information will never be passed on or sold.
2.
The information in the form you may opt to fill in is used by the project team to create a network of interested parties and communicate with you. We reserve the right to pass the mailing list on to Moray Council at the end of the project, and your submission of the form information expressly gives us the option to do this. The only reason that Moray Council may use the mailing list information going forward is to promote and prolong the network and relationships created during this project. You information will never be sold. It will never be made available to any third party beyond Moray Council.
3.
Any words or images you submit as part of this project will be considered public domain and free of copyright unless otherwise and expressly stated within your submission. Please say that you want to ‘keep copyright’.
Data Protection Policy
Moray’s Great Places
Last updated
20-9-18
Company
The Moray’s Great Places project is being operated by Bright White Ltd.
GDPR
means the General Data Protection Regulation.
Responsible Person
Chris Walker, Bright White Ltd
Register of Systems
means a register of all systems or contexts in which personal data is processed by the Company.
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
a. This policy applies to all personal data processed by the Company.
b. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner.
4. Lawful purposes
a. All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
b. The Company shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
5. Data minimisation
a. The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. Accuracy
a. The Company shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
8. Security
a. The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
9. Breach
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
10. Transfer
Moray Council shall be given the option of receiving an archive of the mailing list in order to further the mission of the council to improve the economy of Moray and for this reason alone. You may receive communications from Moray Council after the natural termination of this project.
END OF POLICY