The Society of Local Council Clerks (SLCC) is committed to protecting your privacy and security. This policy explains how and why we use your personal data, to ensure you remain informed and in control of your information.
From May 2018, SLCC will ask its contacts to “opt-in” for marketing communications. This is due to a change to the rules which govern how we can communicate with you and a new regulation on personal data (the General Data Protection Regulation) which came into force on the 25th May 2018. Therefore, we are introducing a new approach that relies on you giving us your consent about how we can contact you. This means you’ll have the choice as to whether you want to receive these messages.
You can decide not to receive communications at any time. If you wish to do so please email firstname.lastname@example.org or write to SLCC, 8 The Crescent, Taunton, Somerset TA1 4EA or call 01823 253646 (Lines open 9am – 5pm, Mon – Thurs, 9am – 4.30pm, Fri).
We will never sell your personal data and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed.
Questions? Any questions you have in relation to this policy or how we use your personal data should be sent to email@example.com or addressed to The Information Officer, 8 The Crescent, Taunton, Somerset TA1 4EA
2. ABOUT US
Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by the Society of Local Council Clerks and SLCC Enterprises Ltd (SLCC) a company limited by guarantee, registered in England and Wales with company registration number 10566132. Registered office: 8, The Crescent, Taunton, Somerset TA1 4EA.
3.WHAT INFORMATION WE COLLECT
Personal data you provide We collect data you provide to us. This includes information you give when registering on our website, joining as a member, booking a delegate place at an event, placing a book order or communicating with us. For example:
personal details (name, email, address, telephone, your council name, job title, salary etc.) when you register as a user of our website or join as a member
financial information (payment information such as credit/debit card or direct debit details. Please see section 8 for more information on payment security);
other information such as preferences and interests
Information created by your involvement with SLCC
Your activities and involvement with SLCC will result in personal data being created. This could include details of how you’ve helped us by volunteering or being involved with our branches, speaking at events or writing for The Clerk magazine.
If you decide to enter our charity raffle at National Conference or donate to us then we will keep records of when and how much you give to a particular cause.
Information we generate
We conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analysing your interests and involvement with our work we may be able to build a profile which helps us decide which of our communications are likely to interest you. Section 6 (Research and profiling) contains more information about how we use information for profiling and targeted advertising.
Information from third parties
We sometimes receive personal data about individuals from third parties. For example, if you have left your position at a council or taken over a new position, the Principal Authority may make us aware. Also, as explained in Section 11 (Cookies and links to other sites), we may use third parties to help us conduct research and analysis on personal data (and this can result in new personal data being created).
We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.
Occasionally, we may collect information about certain clerks (e.g. particularly well known or influential people) from public sources. This could include public websites, news or other media. We don’t do this to everyone, and it is the exception not the rule. Sensitive personal data We do collect and store sensitive personal data about our members in order to provide an SLCC advisory service and as part of our Service Level Agreement with the Association of Local Council Clerks (ALCC) the trade union. SLCC treats all personal information with the utmost confidentiality and with appropriate levels of security. By joining the SLCC and/or registering for related services you agree to our processing your personal information, including sensitive personal information, such as trade union membership.
Accidents or incidents
If an accident or incident occurs on our property, at one of our events or involving one of our staff (including volunteers) then we’ll keep a record of this (which may include personal data and sensitive personal data).
If you are a volunteer (whether for specifically SLCC, or if you are helping us for other reasons – for example you work for another organisation which is running an event with us) then we may collect extra information about you (e.g. references, details of emergency contacts, medical conditions etc.) This information will be retained for legal reasons, to protect us (including in the event of an insurance or legal claim) and for safeguarding purposes.
4. HOW WE USE INFORMATION
We only ever use your personal data with your consent, or where it is necessary in order to: enter into, or perform, a contract with you; comply with a legal duty; protect your vital interests; for our own (or a third party’s) lawful interests, provided your rights don’t override these. In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes):
We use personal data to communicate and promote the SLCC. If you are a member of the SLCC this will include your membership benefits such as sending you the News Bulletin, The Clerk magazine and information from your branch. However, members and non-members may choose whether they receive the promotional communications. For further information on this please see Section 5 (Promotional Communication).
We use personal data for administrative purposes. This includes: maintaining databases of our volunteers, members and contacts; performing our obligations under membership contracts; fulfilling orders for goods or services (whether placed online or in person); helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this). Internal research and analysis
We carry out research and analysis on our volunteers, members and contacts, to determine the success of events, qualifications, better understand the sector and member behaviour and identify patterns and trends. This helps inform our approach towards marketing and make SLCC a stronger and more effective organisation. Understanding our members, their interests and what they care about also helps us provide a better experience (e.g. through more relevant communications).
Supporter research and profiling
We evaluate, categorise and profile personal data in order to tailor materials, services and communications (including targeted advertising) and prevent unwanted material from filling up your inbox. This also helps us understand our supporters, improve our organisation and carry out research. Further information on profiling can be found in Section 6 (Research and profiling).
5. DISCLOSING AND SHARING DATA We will never sell your personal data but may share it with our sponsors or exhibitors if you have opted-in to doing so. We may share personal data with subcontractors or suppliers who provide us with services. For example: If you are a member of the SLCC, your name and address will be shared with our mailing house in order to deliver The Clerk magazine to you. If you are a member of the SLCC, your name, council name and email address will be shared with the International Institute of Municipal Clerks (IIMC), who we have a special Binding Corporate Rule agreement in place with. The IIMC are based in the United States of America. If you sign up for our ILCA course your name and address will be shared with our learning platform in order for you to undertake the online course. If you sign up for CiLCA your name and address will be shared with the provider of EMMA in order for your to undertake the online course. However, these activities will be carried out under a contract which imposes strict requirements on our supplier to keep your information confidential and secure. Occasionally, where we partner with other organisations, we may also share information with them (for example, if you register to attend an event being jointly organised by us and another membership organisation such as One Voice Wales). We’ll only share information when necessary and we’ll make sure to notify you first.
6. PROMOTIONAL COMMUNICATIONS
From May 2018, SLCC will ask its users to “opt-in” for most communications. This covers all our promotional communications (the term promotional is broadly defined and, for instance, covers offers and promotions covering membership, events, qualifications, bookshop, branches, SLCC Partners & Exhibitors and the Association of Local Council Clerks (ALCC)). This means you’ll have the choice as to whether you want to receive these messages. You can decide not to receive communications at any time. If you wish to do so please email firstname.lastname@example.org or write to SLCC, 8 The Crescent, Taunton, Somerset TA1 4EA or call 01823 253646 (Lines open 9am – 5pm, Mon – Thurs, 9am – 4.30pm, Fri). Newsletters and magazines Our bi-monthly membership magazine, The Clerk, is provided as a benefit to our members. We send this out to all our members and you can choose to unsubscribe from promotional communications (as above) without giving up your subscription to The Clerk. Part of your membership (excluding ‘The Clerk’ only membership) will mean you are affiliated to a local SLCC branch, as a member you are agreeing to receive communications regarding your local branch news, meetings and agendas. If you are not a member you may unsubscribe from this communication if you wish. Part of your membership (excluding The Clerk only membership) is that you will receive regular (bi-weekly) News Bulletin communications to update you on the latest SLCC and sector news, upcoming events and job opportunities. Part of signing up for membership is the agreement that, if you have not already used the website, a user account will be setup for you. We will generate your password which will be the same as your membership number and we ask that you regularly update your password (which can be done on the SLCC website) to keep your information secure. Also part of signing up for membership is the agreement that you will receive regular communications regarding the renewal of your membership towards your membership renewal date.
7. RESEARCH AND PROFILING
This section explains how and why we use personal data to build profiles which enable us to understand our members, improve our relationship with them, and provide a better member experience. Analysis and grouping We analyse our members to determine common characteristics and preferences. We do this by assessing various types of information including behaviour (e.g. previous responses) or demographic information (e.g. age or location). We also send membership surveys to our members to help us profile our membership and compare to results from previous years to asses how the profile of our membership is changing. From time to time we may also send surveys to members on behalf of our Community Governance students. This helps our students complete their research topic studies and are not compulsory. The surveys will occasionally ask for personal details in order for the students to invite members to further focus groups but again this is not compulsory. By grouping people together on the basis of common characteristics, we can ensure that a group is provided with communications, products, and information which is most important to them. This helps prevent your inbox from filling up, and also means we aren’t wasting resources on contacting people with information which isn’t relevant to them. Profiling to help us understand our members We profile members in terms of precept and membership level. For example, we send relevant event communications to clerks working for councils on a particular precept to ensure communications are relevant and timely. We will also obtain information about you from other sources, much of which is available on public databases and websites. We do this to enhance and fill-in any gaps so that we can understand our members better, send you the most relevant communications and target our resources effectively. Examples of information we’ll obtain are details of your councils’ precept. Anonymised data We may aggregate and anonymise personal data so that it can no longer be linked to any particular person. This information can be used for a variety of purposes, such as recruiting new members, or to identify trends or patterns within our existing member base. This information helps inform our actions and improve our campaigns, products/services and materials.
8. HOW WE PROTECT DATA
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to or use or disclosure of your personal information. Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data. Payment security All electronic SLCC forms that request financial data will use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers. If you use a credit card to donate, purchase a membership or purchase something online we will pass your credit card details securely to our payment provider (SagePay). Other payment methods (e.g. Bank Transfers) are handled in a similar manner. SLCC complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council and will never store card details. Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.
Where we store information The SLCC’s operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we’ll only allow them to do if your data is adequately protected. For example, some of our systems use Microsoft products. As a US company, it may be that using their products result in personal data being transferred to or accessible from the US. However, we’ll allow this as we are certain personal data will still be adequately protected (as Microsoft is certified under the USA’s Privacy Shield scheme). How long we store information We will only use and store information for so long as it is required for the purposes it was collected for, this is usually seven years (six years plus current). We continually review what information we hold and delete what is no longer required. We never store payment card information.
10. KEEPING YOU IN CONTROL
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows: the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as subject access request); the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason); the right to have inaccurate data rectified; the right to object to your data being used for marketing or profiling; and where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format. Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so. If you would like further information on your rights or wish to exercise them, please write to our Information Officer at SLCC, 8 The Crescent, Taunton, Somerset TA1 4EA or email email@example.com We can provide you with a template subject access form which includes guidance on how to make your request (and will help us respond more quickly). Please contact us for a copy of this. Complaints You can complain to the SLCC directly by contacting our Data Protection Officer using the details set out above. If wish to make a complaint which does not directly relate to your data protection and privacy rights, you can do so in accordance with our complaint policy. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk
11. COOKIES AND LINKS TO OTHER SITES
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