Privacy notice - Local Transport Plan
Overview
This privacy notice covers the preparation, development, publication and any promotion or activities relating to our Local Transport Plan (LTP). LTPs assess an area's transport needs and challenges and sets out different ways in which these challenges will be addressed.
This Plan will set out how we will identify, develop, and deliver transport improvements in East Sussex. We will be consulting with key stakeholders including internal Teams, external authorities and bodies, businesses, organisations, user groups, local communities etc on how they want to shape the future of transport, connecting people and places.
In order to reach our target audience in consulting on the proposed Local Transport Plan we will need to store contact details of the relevant individuals and organisations. We will also need to obtain permissions - where relevant - for the use of photographs and videography to promote the LTP.
East Sussex County Council takes data protection seriously. Please be assured that your information will be used appropriately in line with data protection legislation, will be stored securely and will not be processed unless the requirements for fair and lawful processing can be met.
What information is being used?
In order to provide the service we will collect:
- name
- address
- location based data and
- special category data which includes race or ethnic origin, and physical health.
How will your information be used?
The data will be used to enable delivery of a statutory duty, which is the development of a Local Transport Plan (LTP). The end result will help to connect people and places, and improve transport systems (walking, cycling, scooting, bus, rail, road) within/outside and around the county.
We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never sold for direct marketing purposes.
Our staff are trained to handle your information correctly and protect your confidentiality and privacy.
Your information is processed in the UK or in a country with an adequacy agreement with the UK.
What is the legal basis for processing your information?
The legal basis for processing the information of personal data is consent of the data subject for one or more specific purposes.
Consent of the data subject is required to enable the County Council (or the contracted consultant who will be commissioned to prepare and develop the LTP) to collate and retain information and data to enable consultation of the LTP at the preliminary and subsequent stages, and to contact the individual, group or organisation where appropriate where there is a valid reason to do so (e.g. responding to a specific question or query).
Consent of the data subject is also required for permission to take photos and videos where appropriate for the use of photographs and/or videography in the promotion and publication of LTP4 - both in hard copies and online.
Consent will be collected by the County Council, or via a contracted Provider, and will be shared and/or stored where appropriate on secure and encrypted software. If consent is sought to be withdrawn, we will be able to delete data from our system. At no time will personal data be shared publicly.
Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
As per Article 6(1)(f) of the GDPR processing of data for interested individuals meets the three-part test set out by the GDPR regarding purpose, necessity and balance.
The processing is not required by law but is of a clear benefit both East Sussex County Council Infrastructure Planning and Policy Team and its stakeholders, there is a limited privacy impact on the individual, the individual should reasonably expect us to use their data in that way; and it is disproportionate to bother them with disruptive consent requests when they are unlikely to object to the processing.
There is a direct and appropriate relationship where this legal basis is applied, and individuals can opt out as required.
How long will your information be kept for?
The information, images and video will be stored by the County Council (and contracted Provider) for a period of 2 years.
Where express permission has been granted by the stakeholder, a contact e-mail will be retained on a secure spreadsheet which provides the names and contact e-mails of those who are considered to be key stakeholders. This information will be retained for a period of 5 years, and individuals will only be contacted where they are considered to be a key stakeholder with an interest in engaging on any future East Sussex County Council transport consultation. This information will be deleted after a period of 5 years, unless (either) the information is requested to be deleted, or permission has been re-granted for the retention of the information when the 5 year period expires.
Sharing your information
Any sharing of personal data is always done:
- on case-by-case basis
- using the minimum personal data necessary
- with the appropriate security controls in place
- in line with legislation.
Information is only shared with those agencies and bodies who have a "need to know" or where you have consented to the sharing of your personal data to such persons.
We may use the information we hold about you to assist in the detection and prevention of crime or fraud. We may also share this information with other bodies that inspect and manage public funds.
Use of third party organisations
East Sussex County Council may share your information with trusted external organisations to process your data on our behalf.
The County Council will be entering into a contract with a consultant to deliver many elements of the development of the Local Transport Plan (LTP).
This will include liaising with the key stakeholders that the County Council have identified who are instrumental in the consultation stages and the successful development and progression of the LTP.
Any organisation commissioned by the Council will be under contractual obligation to comply with data protection legislation.
Your rights
Under data protection legislation, you have the right:
- to be informed why, where and how we use your information
- to ask for access to your information
- to ask for your information to be corrected if it is inaccurate or incomplete
- to ask for your information to be deleted or removed where there is no need for us to continue processing it
- to ask us to restrict the use of your information
- to ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information
- to object to how your information is used
- to challenge any decisions made without human intervention (automated decision making)
Please visit data subject rights for further details.
How to find out more or complain
Should you have any further queries on the uses of your information, please speak directly to our service:
Infrastructure, Planning and Place team
Email: Infrastructure, Planning and Place team
To complain about the use of your information, please contact our Customer Services Team or our Data Protection Officer.
Further information on making a complaint.
You can also contact the Information Commissioner's Office (ICO) for further information or to make a complaint:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Phone: 0303 123 1113 (local rate)