Polegate Town Council  – General Privacy Notice

Last Updated: October 2025

Next Review: October 2026

1. Purpose of this Notice

This Privacy Notice explains how Polegate Town Council (“the Council”, “we”, “us”) collects, uses, and protects personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We are committed to processing personal data lawfully, fairly, and transparently.

2. Data Controller and Contact Details

Data Controller: Polegate Town Council
Address: Council Offices, 49 High Street, Polegate, East Sussex, BN26 6AL
Telephone: 01323 488114
Email: admin@polegatetowncouncil.gov.uk
Website: https://polegatetowncouncil.gov.uk
Data Protection Officer (DPO): GDPR-Info Ltd (contactable via the Council Offices)

3. What Personal Data We Collect

Depending on your interaction with the Council, we may collect:

  • Name, address, contact details (email, phone number)
  • Photographs and CCTV footage
  • Correspondence with the Council
  • Payment and banking details
  • Information relating to use of Council services
  • Employment and recruitment data
  • Health or other special category data
  • Social media contact (e.g., Facebook and Twitter)

We may also process:

  • Gender, age, marital status, nationality
  • Education/work history, qualifications
  • Family composition and dependants
  • Criminal convictions, racial or ethnic origin, political beliefs, trade union affiliation, genetic and biometric data, sexual orientation

4. How We Use Your Information

We process personal data to carry out our statutory and administrative functions, provide local services, and engage with residents and stakeholders.

Purpose and Legal Basis for Processing Personal Data

  • Statutory Services
    We process personal data to deliver statutory services such as allotments, planning consultations, and civic functions.
    Lawful Basis: Public task
    Legal Reference: Article 6(1)(e)
  • Legal Obligations
    Data is processed to meet legal obligations including Freedom of Information, audits, and health and safety compliance.
    Lawful Basis: Legal obligation
    Legal Reference: Article 6(1)(c)
  • Contracts
    Personal data is used to manage contracts, such as hall hire agreements or allotment tenancies.
    Lawful Basis: Contract
    Legal Reference: Article 6(1)(b)
  • Communication
    We may contact individuals for engagement purposes, such as newsletters or surveys.
    Lawful Basis: Public task or consent
    Legal Reference: Article 6(1)(e) and/or Article 6(1)(a)
  • Employment
    Data is processed for employment-related purposes including payroll and recruitment.
    Lawful Basis: Legal obligation and/or contract
    Legal Reference: Article 6(1)(b) and 6(1)(c)
  • Publicity Materials
    Event photos and other promotional content may be used with consent.
    Lawful Basis: Consent
    Legal Reference: Article 6(1)(a)
  • CCTV
    CCTV footage is used for crime prevention and site security.
    Lawful Basis: Legitimate interests or public task
    Legal Reference: Article 6(1)(f) and/or Article 6(1)(e)
  • Special Category Data
    Sensitive data such as health information is processed for accessibility or safety reasons.
    Lawful Basis: Explicit consent or substantial public interest
    Legal Reference: Article 9(2)(a) or (g), and Data Protection Act 2018 Schedule 1 Part 2

5. Sharing Your Information

We only share personal data when necessary and lawful. Recipients may include:

  • Other public authorities or councils
  • Government departments or regulators
  • Contractors and service providers
  • Insurers, auditors, advisers
  • Law enforcement

We may also work with:

  • Community groups, charities, not-for-profit entities
  • Credit reference agencies

Where data is processed jointly, we may act as joint data controllers. Where processed independently, each party is responsible for its own compliance.

6. International Transfers

We store data within the UK wherever possible. If transferred outside the UK or EEA (e.g., via cloud services), we ensure appropriate safeguards are in place.

7. Retention of Your Data

We retain personal data only as long as necessary. Examples:

  • Council minutes – permanently
  • Financial records – 7 years
  • Routine correspondence – 2 years
  • CCTV footage – typically 30 days

We may retain data for legal claims (e.g., 3 years for personal injury, 6 years for contracts). For a full breakdown of Retention please follow the follow link to our Data Retention Policy: https://polegatetowncouncil.gov.uk/wp-content/uploads/13-Document-Retention-Policy-2025.pdf

8. Your Rights

You have the right to:

  • Access your data
  • Rectify inaccurate data
  • Erase data (“right to be forgotten”)
  • Restrict processing
  • Data portability
  • Object to processing
  • Withdraw consent at any time

To exercise these rights, contact the Town Council. We may require proof of identity.

You can also withdraw consent via: https://gdpr-info.com/data-protection-contact-form/

9. Further Processing

If we wish to use your data for a new purpose not covered by this notice, we will issue a new notice and seek your consent where necessary.

10. Children’s Data

We do not knowingly collect personal data from children under 13 without parental consent. Where data is collected for youth services or events, appropriate safeguards are applied.

11. Automated Decision-Making

We do not carry out automated decision-making or profiling with legal or significant effects.

12. How We Protect Your Information

We use appropriate technical and organisational measures including:

  • Password protection
  • Access controls
  • Encryption
  • Staff training

All staff and councillors are bound by confidentiality obligations.

13. Data Breach Protocol

In the event of a data breach, we will follow our internal reporting procedures and notify affected individuals and the ICO where required.

14. Website Cookies

Our website may use cookies to improve user experience and gather anonymous usage statistics. You can manage cookie preferences via your browser settings.

15. Accessibility

This Privacy Notice is available in alternative formats upon request. Please contact the Town Clerk for assistance.

16. Complaints and Contact

If you have concerns, contact:

Polegate Town Council, 49 High Street, Polegate, BN26 6AL
Email: admin@polegatetowncouncil.gov.uk

Or contact the Information Commissioner’s Office (ICO):
https://ico.org.uk

Tel: 0303 123 1113

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