Privacy Notice for Promotional Photographs and Video

Data Controller: Mole Valley District Council

Mole Valley District Council (“MVDC”) is the body exercising control over the purpose for which and the manner in which your personal data is processed.

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

The legal basis for and the purposes of the processing:

MVDC’s Communications team is responsible for taking and using promotional imagery for the purposes of publicising council services, campaigns and events in order to provide information, public awareness campaigns or to supplement the publicity of a single moment or action both internally and externally. The team do this by way of taking photographs and video footage, which can often include interviews. In doing so, on occasion, images or video of one or more people is taken, no just landscapes or non-identifiable crowd shots.

The legal basis for carrying out this processing, which is intended to help MVDC improve its services and maintain or enhance its reputation, is under Public Interest (UK General Data Protection Regulation (UK GDPR), Article 6e).

The source of the personal data:

Should you choose to actively participate in either a photograph or video for publicity purposes for MVDC, you are the source of providing the personal data. Where you are the main or joint subject of the promotional photograph or video, you will be asked to give your explicit consent by being given a consent form to read and sign, or indeed sign as a parent or guardian on behalf of a child you are responsible for. You may at any time opt-out of the photograph or video being used in the future. To do so, please email communications@molevalley.gov.uk, indicating which photograph or video you want your personal data to be deleted from. MVDC has no control over the usage of a photograph or video once it has been shared using various channels, and potentially reproduced by third parties.

Recipients and categories of recipients of the personal data:

MVDC’s Communications team will lead on taking publicity photographs and videos for use by the Council. On most occasions, editing both photographs and videos will be carried internally, using in-house software to do so. Videos are saved on password protected devices and photographs are kept in a central location in a folder which requires access to be granted.

There will be times where photographs and videos will be forwarded to third party designers, as required. Photographs and videos will be used either primarily as, or to accompany, promotional material via various channels, including social media, and sent to numerous third parties for publicity purposes, with a view to being shared. Third parties include, but not are limited to, local and national press contacts, publications, partner organisations, parish councils and resident associations.

Further information on onward transfers:

MVDC will not transfer the personal data you have provided outside of the UK or European Union unless this is permitted in accordance with the Data Protection Act 2018.

How long the personal data will be kept for:

The personal data you have supplied will be destroyed in accordance with MVDC’s Data Retention Policy.

Statutory Obligations to provide the personal data:

There is no statutory obligation on you to provide any personal data about you.

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 processing of your personal data is restricted (this will only apply in certain situations, for example where its accuracy is contested, where the processing is unlawful and you oppose its proposed erasure by MVDC, or where MVDC no longer needs to process the personal data but it is required by you in connection with legal claims).
• be given a copy of your personal data in an accessible electronic format;
• 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);
• object to the processing where the processing is necessary for a task carried out in the public interest or in the exercise of official authority vested in the data controller (though MVDC will still be able to continue with the processing in certain circumstances, such as if there are compelling grounds for processing which overrides your interests);
• if you have provided consent to the processing of your personal data, you may withdraw your consent at any time by emailing communications@molevalley.gov.uk

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.

If you are dissatisfied with how your personal data is processed by MVDC 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.