Privacy Notice for e-newsletters

Data Controller:

Mole Valley District Council (“MVDC”).

Data Controller’s contact details:

MVDC Pippbrook, Dorking RH4 1SJ. Telephone: 01306 885 001.

Data Protection Officer:

Mr Tom Penlington (Solicitor): Telephone: 01306 879 354

Data Processor:

MVDC creates, sends and manages a number of e-newsletters using Granicus. MVDC is the body exercising control over the purpose and the manner in which your personal data is processed. This means that MVDC is your data controller. Granicus performs data processing functions on behalf of MVDC. Granicus’s data processing functions are carried out by it pursuant to the terms of a Data Processing Agreement. Further details of the Data Processing Agreement are available on request.

The legal basis for and the purposes of the processing

When you subscribe to an e-newsletter produced by one or more of MVDC’s Services, you are giving explicit consent to the processing of your data for one or more specific purposes. Under the Local Government Act 1972 and Communications Act 2003, MVDC can distribute information by way of an electronic communications service relating to the MVDC functions, and those of other authorities or partners. Whichever e-newsletter you are subscribing to, the purpose of that e-newsletter is to provide you news that you have confirmed would be of interest, or of benefit, relating to that Service area.

The source of the personal data:

Your personal data, your email address, is captured when you give your consent to receive future editions of the relevant e-newsletter. You will continue to receive the e-newsletter until such a time you wish to unsubscribe. You have the option to unsubscribe at any time from receiving future editions of the e-newsletter by following the ‘unsubscribe’ link found at the bottom of each edition.

Recipients and categories of recipients of the personal data:

MVDC creates, sends and manages several e-newsletters using the online platform Granicus provides. Your personal data, in this case your email address, is held by Granicus in accordance with the company’s Privacy Policy. MVDC, and more specifically the relevant MVDC Service areas:

Communications; Regeneration & Investment; Mole Valley Life teams

The above teams all have password protected access to Granicus accounts, and your personal data held in them, for the purpose of using their individual subscriber lists to send editions of their respective e-newsletters.

Further information on onward transfers:

Granicus stores its data in the US so when you subscribe to one of our MVDC’s e-newsletters, your personal data is transferred and held outside of the UK. Granicus complies with the UK Extension to the EU-U.S. Data Privacy Framework (DPF) to be able to provide adequate privacy protection and process personal data received from the UK. More information on the DPF and Granicus’s certification is available to view online.

How long the personal data will be kept for:

The personal data you have supplied will be destroyed upon you unsubscribing from the e-newsletter, which you can do at any time by following the ‘unsubscribe’ link found at the bottom of each edition. Granicus does not retain any private data after the termination of a client’s (MVDC) account. The data is permanently deleted in full.

Statutory Obligations to provide the personal data:

There is no statutory obligation on you to provide any personal data about you, however, if you do not you will not receive future editions of the respective e-newsletter.

Automated Decision Making:

The personal data provided by you will not be used for any automated decisions.

Data Subject Rights:

From 25 May 2018 you will have some specific rights in respect of your personal data. These may include some or all of the following rights to:

• see what personal data about you MVDC holds at any time (subject to certain caveats, for example where third parties are identified);
• have MVDC correct any errors (if any) in the personal data it holds about you, and to have incomplete personal data completed. In certain situations however, MVDC can retain the personal data in dispute. You will be informed whether this is the case when we respond to your request;
• request your personal data is erased (though this right will not apply where MVDC is processing your personal data because it is necessary to comply with a legal obligation);
• If you have provided consent to the processing of your personal data, you may withdraw your consent at any time by following the ‘unsubscribe’ button found at the bottom of each edition of MV e-news

Will the personal data be processed for a different purpose?

No. If MVDC needs to inform recipients about any action it has taken under the Data Protection Act then it will do so by placing a Notice on MVDC’s website informing the public of any relevant changes. For more information about how your data could be used by Granicus, please refer to the company’s Privacy Policy.

Data Processing

If you require further information about the processing of your personal data by Granicus outside of the UK, please contact them at support@granicus.com.

If you have additional questions or need to escalate an issue, contact the Data Protection Officer for Granicus, details below:

Full name of legal entity: Granicus, LLC and Firmstep, Ltd.

Email address: dpo@granicus.com

Postal address: 1152 15th Street NW, Suite 800, Washington, DC 20005, USA

Telephone number: 01 651 400 8730

Name of EU representative: DataRep

Email address: granicus@datarep.com

You can also contact DataRep using this online form: https://www.datarep.com/data-request

Postal address: The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland

Granicus’s Privacy Notice can be found here: Privacy Policy | Granicus

If you are dissatisfied with how your personal data is processed by MVDC or Granicus, then you have the right to complain to the Information Commissioner who can be contacted at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF

Google Analytics

MVDC uses Google Analytics software to collect information about how you use www.molevalley.gov.uk. MVDC does this to help make sure the site is meeting the needs of its users and to help us make improvements.

The cookies MVDC uses for this purpose are:

Universal Analytics

Google Analytics

How do I prevent being tracked by Google Analytics?

If you are uncomfortable with this tracking, you can take the following actions:

• Use a tracking-blocker, such as Privacy Badger
• Clear cookies after every browsing session

Install the Google Analytics opt-out extension.