Who are we and what we do
We are ‘Publica’ Group (Support) Limited and are a council owned employment company which delivers shared services between Cotswold, West Oxfordshire and Forest of Dean District Councils and Cheltenham Borough Council (hereon known as “Clients”). Publica additionally provides services to the Cheltenham Trust, Cheltenham Borough Homes and UBICO (an environmental services local authority company) (hereon known as “Clients”).
Publica is a data controller under the Data Protection Legislation as we collect and process personal information about you in order to provide these services and meet our statutory and regulatory obligations. Publica is also a data processor under the Data Protection Legislation as we collect and process personal information on behalf of our Clients when delivering shared services.
We recognise that your personal information is important to you and we take our responsibilities for ensuring that we collect and manage it proportionately, correctly and safely very seriously.
Any questions regarding our privacy practices should be sent to:
Data Protection Officer (DPO)
Publica Group (Support) Limited
Trinity Road, Cirencester GL7 1PX
Email: data.protection@publicagroup.uk
Tel: 01993 861194
Why Publica needs your information and how we use it
The Public Sector Equality Duty 2011 was created under the Equality Act 2010; we must exercise our functions with due regard to the need to:
- Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act.
- Advance equality of opportunity between people who share a protected characteristic and those who do not.
- Foster good relations between people who share a protected characteristic and those who do not.
We collect personal data and special category personal data to monitor and improve our service delivery to assist in the removal of barriers and the advancement of opportunities.
We do not sell your personal information to anyone else.
What is the legal process for collecting and processing this data
Under the UK General Data Protection Regulation (GDPR) and Data Protection Act 2018, the lawful bases we rely on for processing this information are:
- GDPR Article 6 (1) (c) Legal Obligation – we collect and lawfully process your personal data under the Equalities Act 2010 and the subsequent Public Sector Equality Duty 2011.
- GDPR Article 6 (1) (e) Public Task – we collect and lawfully process your personal data as it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us or our Clients.
We process special category personal data under:
- GDPR Article 9 (2) (a) Explicit Consent – we collect and lawfully process your personal data as explicit consent has been given for the processing.
What type of information is collected from you
Personal details, which may include:
- Name
- Address
- Other contact details that you provide to us e.g. email address, telephone number
Special categories of personal data
We may collect any special category data with your explicit consent, examples would be race or ethnic origin, sexual orientation, health or religious beliefs.
Who your information may be shared with (internally and externally)
Equality data (anonymised data on numbers or percentages relating to protected characteristic) is captured corporately for publication on our, or our Clients’, website, in order to comply with our legal obligations under the Equality Act 2010 and Public Sector Equality Duty 2011. There are no personal identifiers contained within the published data.
Equality Impact Assessments may be carried out in partnership with other public bodies. This would be made clear in any surveys / consultations that are part of an assessment process. We may disclose your information to others, but only where this is necessary to either comply with our legal obligation or as permitted by Data Protection legislation.
Apart from where previously stated, we do not pass your details to third parties without your consent or unless we are lawfully required do so.
How long Publica keeps your information (retention period)
We will only retain your personal information for as long as we are required to do so by law and the purpose we collected it for. In the case of equality data, which forms part of an equality impact assessment, the retention period is 6 years.
Once your data is no longer needed it will be securely and confidentially destroyed or disposed of in line with retention schedules.
How Publica protects your Information
Your data is stored securely on our systems and accessed only by authorised officers using their own username and password created in line with pre-defined user credentials. Personal data is also held in electronic files on our network drives. These are only accessible through personal logon credentials and access privileges to specific drives. Access to our sites require a personal electronic pass to access staff only areas. Publica has strict procedures for the way this is done. Any and all information about you is treated as confidential and with respect. There are also clear rules and guidance about storing, recording and sharing information which staff receive training on.
Publica will not transfer your personal data outside the EU without your consent.
Publica have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
Publica will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
Your rights
You have the following rights under the Data Protection Legislations:
- To access your personal data
- To be provided with information about how your personal data is processed
- To have your personal data corrected
- To have your personal data erased in certain circumstances
- To object to or restrict how your personal data is processed
- To have your personal data transferred to yourself or to another business in certain circumstances
- To be told if Publica have made a mistake whilst processing your data and Publica will self-report breaches to the Commissioner.
How you can access, update or correct your information
The Data Protection law gives you the right to apply for a copy of information about yourself. This is called a ‘Subject Access Request'.
If you wish to see a copy of your records you should contact the Data Protection Officer. You are entitled to receive a copy of your records free of charge, within a month.
In certain circumstances access to your records may be limited, for example, if the records you have asked for contain information relating to another person.
The accuracy of your information is important to us to be able to provide relevant services more quickly. Publica is working to make our record keeping more efficient. In the meantime, if you change your address or email address, or if any of your circumstances change or any of the other information we hold is inaccurate or out of date, please email us or write to us at:
Publica Group (Support) Limited
Trinity Road, Cirencester GL7 1PX
Email: data.protection@publicagroup.uk
Tel: 01993 861194
Further information
If you would like to know more about how Publica uses your information, or if for any reason you do not wish to have your information used in any of the ways described in this privacy notice, please contact the Data Protection Officer at data.protection@publicagroup.uk
For more information about data protection please visit: https://www.publicagroup.uk/privacy-notice/data-protection-act-overview/
If you are concerned about the way we are handling your personal information you can contact the Information Commissioner (ICO): https://ico.org.uk/make-a-complaint/
Publica reserves the right to update this privacy notice from time to time by publishing a new version on our the website.