We at Connect Public Affairs Ltd, trading as Connect, registered address: Grove House, 1 Grove Place, Bedford, Bedfordshire MK40 3JJ, company number: 03449749 (“we” or “our” or “us”) want to make sure all the personal information we have collected about you through this website (“Site”)  is safe and secure. 

This Policy set outs our commitments to you, in compliance with, and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.

PRIVACY NOTICES

Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us or in providing services to our clients or just managing our relationship with you.

When we hold or use your personal information as a data controller (see below for a description of what this is) we will provide you with a privacy notice which sets out in detail what information we hold about you (such as your contact details, address, email address, phone number etc), how your personal information may be used and the reasons for these uses, together with details of your rights. 

Where we collect personal information from you directly, we will provide this privacy notice at the time we collect the personal information from you. Where we receive your personal information indirectly, we will provide this privacy notice when we first contact you, first pass the data to someone else or within a month, whichever is earlier.

We will only provide this privacy notice to you once, generally at the start of our relationship with you. However, if the applicable privacy notice is updated substantially, then we may provide you with details of the updated version. You are encouraged to check back regularly for updates.

A copy of our current privacy notice can be found at https://rafhaltonconsultation.co.uk/privacy-policy/

THE DIFFERENCE BETWEEN DATA CONTROLLERS AND DATA PROCESSORS

A data controller is a person who controls how personal information is processed and used.  A data processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller.

This distinction is important. You have certain rights in relation to your personal information, for example, the right to be provided with the personal information held about you and details of its use and the right to have certain personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below on what rights you have).  These rights can generally only be exercised against a data controller of your information. 

In most cases we will be a data controller of your personal information. In any case where we are not a data controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the data controller (i.e. the person who controls how we process the personal information). In these cases we will endeavour to inform you who is the data controller of your personal information so that you can direct any such requests to them.

Moreover, it is only a data controller that will provide you with a privacy notice about your personal information, so where we process your personal information as a data controller we will provide you with a privacy notice. Where we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We may process information that you provide to us. This data may include the following:

  • Your Name;
  • Your address;
  • Your telephone number;
  • Your email address;
  • Your employer or any group on whose behalf you are authorised to respond;
  • Your feedback in response to the RAF Halton Consultation;
  • Your IP address (online only);

IP addresses are collected automatically if you contact us online. Apart from that, we only collect the information you choose to give us.

We will use your personal data for the following purposes:

  • To record accurately and analyse any questions you raise during the Consultation or feedback you have provided in response to the Consultation.
  • To report on our consultation, detailing what issues have been raised and how we have responded to that feedback (please note that the information contained in the consultation report will be aggregated and will not identify specific individuals).
  • To personalise communications with individuals we are required to contact as part of future consultation or communications.

The legal basis for processing this data is that it is necessary for our legitimate interest, namely for the purpose of ensuring the consultation process, analysis and reporting are accurate and comprehensive.

In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We may provide your personal data to the following recipients:

  • Defence Infrastructure Organisation (DIO) on whose behalf we are collecting your feedback in order to analyse and report on the responses received.
  • Third party service providers and professional advisors who provide services to DIO in connection with the Consultation
  • The Planning Inspectorate (or any successor body), the examination Inspector, the Government and/or any relevant local planning authority or council.
  • Our insurers/professional advisers. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance cover, managing risks, obtaining professional advice and managing legal disputes.

In such circumstances, we will put in place arrangements to protect your personal information. 

Outside of that we do not disclose your personal information unless we are required to do so by law. 

We do not sell, trade or rent your personal information to others.

HOW LONG DO WE HOLD YOUR PERSONAL INFORMATION FOR?

Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose.

Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will delete your personal data as soon as practicable following the outcome of the planning application relating to the Consultation or any appeal of such decision.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject.

WHAT ARE YOUR RIGHTS?

Full details of your rights are set out in the relevant privacy notice provided to you, but you are entitled by law to ask for a copy of your personal information at any time. You are also entitled to ask us to correct, delete or update your personal information, to send your personal information to you or another organisation and to object to automated decision making. Where you have given us your consent to use your personal information in a particular manner, you also have the right to withdraw this consent at any time. 

To exercise any of your rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contact” section below.

You should note that some of your rights may not apply as they have specific requirements and exemptions which apply to them and they may not also apply to personal information recorded and stored by us.  However your right to withdraw consent or object to processing for direct marketing are absolute rights.

If you are unhappy with the way we are using your personal information you can complain to the UK Information Commissioner’s Office or your local data protection regulator. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

However, we are here to help and would encourage you to contact us to resolve your complaint first.

LINKING WITH THIRD PARTY SITES

Our Site may contain links to and from other websites which may be of relevance to this project.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.

In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

SECURITY

We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information. 

COOKIES

Certain parts of our Site use “cookies” to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store on your computer’s hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited. The only personal information a cookie contains is information that you have personally supplied.

Please note that providers of third party content may also use cookies over which we have no control.

We use cookies on this Site to:

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not and to provide a seamless experience when you are booking one of our services through the Site. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

LOG FILES

In common with most websites, our Site logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.

We may use this information to analyse trends, administer the Site, track your movement around the Site and gather broad demographic information.

CHANGES TO THIS POLICY

Any changes we may make to this Policy in the future will be posted on our Site and, where appropriate, notified to you by email. When we change this Policy in a material way, we will update the version date at the bottom of this page. Please check back frequently to see any updates or changes to this Policy and should you object to any alteration, please contact us as set out in the “Contact” section below.

CONTACT

In the event of any query or complaint in connection with the information we hold about you, please email gdpr@connectpa.co.uk or write to us at: Data Protection Compliance Manager, Connect, 3rd floor, Millbank Tower, London SW1P 4QP.

Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

Version Date: 29 April 2019