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Privacy Policy

Privacy Policy

This is the privacy policy of Go Vocal.

Go Vocal are the provider of this digital engagement platform ("the platform) to Brighton & Hove City Council. View the council's primary privacy notice.

The council is the data controller for purposes of the Data Protection Act (2018) and The General Data Protection Regulation (EU) 2016/679 ("GDPR") and is registered as a data controller with the Information Commissioner’s Office (ICO)

Brighton & Hove City Council are committed to protecting your personal information. As a data controller we have a responsibility to make sure you know why and how your personal information is being collected in accordance with relevant data protection law.

The primary laws that govern how Brighton & Hove City Council collects and uses personal information (known as Data) about you are: General Data Protection Regulation (GDPR)Data Protection Act (DPA) (2018)

For the remainder of this policy Brighton and Hove City Council, the controller of your personal data, will be referred to as "the organisation".

For the remainder of this policy Go Vocal, the processor of your personal data, will be referred to as "Citizenlab".

Processor on behalf of the Organization, and controller for the processing activities mentioned under 3.3 (hereafter: “CitizenLab”):

  • Name and legal form: Go Vocal NV
  • Belgian enterprise number: 0638.901.287
  • Registered office address: Pachecolaan 34 (6th floor), 1000 Brussels, Belgium
  • Contact e-mail address: support@govocal.com

Hereafter jointly referred to as “the Platform”.

The Platform respects your privacy and strives to always treat your personal data with the necessary care and confidentiality. The Platform commits itself to comply with the General Data Protection Regulation (“GDPR”) and any other applicable regulations.

Please find all relevant details below. Via the mentioned contact details, you can always reach the Platform for further questions or comments regarding the processing of your Personal Data.

1. Scope

This Privacy Policy applies to the processing of your Personal Data through the Platform.

What is the legal process for collecting and processing this data

Under the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018, the lawful base we rely on for processing this information is:

The legal basis under Article 6 of the UK GDPR for processing personal data is: (e) – Public task: the processing is necessary to perform a task in the public interest or for official functions

Local Government Act 1972 Section 141

The legal basis under Article 9 of the UK GDPR for processing special category data is:(g) – Substantial public interest: the processing is necessary to perform a task in the public interest or for official functions

2. What is personal data?

In this Privacy Policy, Personal Data refers to information that makes it possible to identify you. An identifiable person is someone who can be identified, either directly or indirectly, in particular from an identification number or one or more factors that are linked to physical, physiological, mental, economic, cultural or social identity. A typical example of Personal Data is your name and email address.

3. What personal data do we collect

The Platform may collect your Personal Data from the following three sources:

3.1.Personal Data that you provide when registering on the Platform, some of which are optional.

The Personal Data that the Platform collects from you are:

  • First/given name and last/family name
  • E-mail address

The Organisation may also request additional Personal Data during the registration process.

3.2. Personal Data that you provide when participating on the Platform.

Every action that you take on the Platform (e.g., voting, posting an idea, writing a comment, answering a poll, etc.) constitutes Personal Data and is registered and stored. Such Personal Data is also linked to your registration data (3.1), implying that the Organization can link your profile data to this participation data.

3.3. Personal Data that Go Vocal collects when you visit the Platform.

If you provide permission by accepting cookies on the Platform, Go Vocal (and third party processors acting on our behalf) collect information about the usage of the Platform to assess its proper functioning and security. To this end, Go Vocal may collect technical information about you such as your IP address and browser details. Go Vocal may also gather usage data to improve its services. You can opt out of this collection at all times in your Cookie Settings.

The processing activities mentioned above are based on the legitimate interests of Go Vocal.

4. How do we use personal data

The Platform uses your Personal Data for the following purposes:

  • First and foremost, to communicate your input and its relevant context to the Organization and to provide aggregated reports of all the data collected on this Platform to assist with their decision-making.
  • To create and maintain your user profile on the Platform.
  • To manage the identification and authentication of users.
  • To provide information about your community and/or alert you when activities on the Platform may interest you. You can opt-out of email notifications from your user profile at any time.
  • To improve the Platform and to monitor its functionalities.

The Personal Data is only stored and processed for the period required for the purpose of the processing. After that, the Personal Data will be deleted or anonymized.

5. Who and where we share personal data with

Your data is shared internally only with the appropriate staff where it is necessary for the performance of their roles, such as the project manager of the engagement and consultation.

We will not normally share your information with organisations without your consent, where single engagement projects share data with other organisations - this will be details in the relevant privacy notice shared.

Your information will not be disclosed to any other organisations, except where the council is required and allowed to by law, to safeguard public safety and in risk of harm or emergency situations.

The council will not share your information with third parties for marketing purposes.

Go Vocal shares your Personal Data with the Organization on behalf of which Go Vocal processes such Personal Data.

Where necessary, the Platform engages external service providers who process Personal Data on its behalf, i.e. (sub-)processors. The Platform will only share your Personal Data with these external service providers to the extent necessary for the relevant purpose. The Personal Data may not be used for any other purpose by these third parties. In addition, these service providers are contractually bound to ensure the confidentiality of your Personal Data by means of a so-called “data processing agreement” concluded with these parties.

The Platform will never sell or rent your Personal Data to other service providers, nor will it share your Personal Data with any service provider that is not compliant with the GDPR.

Should the Platform, for limited and specific processing activities, rely on service providers that operate from outside of the EEA, data transfers will only occur to countries that the European Commission has confirmed guarantee an adequate level of protection for your Personal Data, or where other measures have been taken to ensure the lawful processing of your Personal Data.

6. What are your rights

6.1. Right of access

You have the right to view your Personal Data at any time as well as the right to be informed of the use that the Platform makes of your Personal Data. You may also request a copy of the Personal Data that is being processed.

6.2. Right to rectification

You have the right to rectify inaccurate Personal Data that concerns you.

6.3. Right to erasure

You have the right to ask the Platform to delete your Personal Data. It is however possible that some Personal Data will still need to be processed. When the Platform deletes your Personal Data, a limited amount of Personal Data may still need to be retained to ensure the Platform can fulfil its obligations under the GDPR.

If you choose to remove your account entirely from the Platform, your Personal Data will be removed from our servers. Some Personal Data about you may remain in the logging data the Platform keeps for security and legal reasons for up to 30 days.

You acknowledge that a request to delete your Personal Data means that certain services may no longer be delivered.

6.4. Right to object

You have the right to object to the processing of your Personal Data for serious and legitimate reasons. In addition, you always have the right to object to the use of your Personal Data for direct marketing purposes.

6.5. Right to restrict the processing of your data

You can exercise your right to restrict the processing of your data, if you believe that we are processing your Personal Data unlawfully. You can also request us to restrict the processing if you believe we are processing inaccurate Personal Data about you, for the period needed to verify the accuracy of your Personal Data. The same applies when you exercise your right to object to the processing of your Personal Data. In this case you can restrict the processing for the time needed to verify our legitimate grounds to process your data.

6.6. Right to data portability

You have the right to obtain the Personal Data you have provided to the Platform in a structured, typical and machine-readable form and/or have such Data transferred to different controllers.

6.7. Right to withdraw consent

Insofar as the processing is based on your prior consent, you have the right to withdraw your approval.

6.8. Automated decision-making and profiling

The processing of your Personal Data does not include profiling and shall also not be subjected by Go Vocal to automated decision-making.

6.9. Right to lodge a complaint

You also have the right to lodge a complaint with a competent supervisory authority in the field of data protection. Hereunder we refer to the contact details of the Belgian Data Protection Authority. If you are within the EEA, you can also lodge a complaint with the national supervisory authority of the EEA state where you have your habitual residence or place of work, or where the potential infringement occurred. You also have the option to file a legal claim against the Organization or against Go Vocal with the competent court in the EEA state where you have your habitual residence. For further information and the contact details of the supervisory authority of each EEA state, we refer to this web page of the European Data Protection Board.

Belgian Data Protection Authority: Drukpersstraat 35, 1000 Brussels, Belgium, +32 (0)2 274 48 00, contact@apd-gba.be, Website DPA - file a complaint

7. How to exercise your rights

You can exercise your rights by contacting:

Data Protection Officer

If you're concerned about how we collect or use your personal data you can contact the council’s Data Protection Officer.

How to make a complaint

We aim to resolve all complaints about how we handle personal information. You also have the right to make a complaint about data protection to the Information Commissioner's Office.

Contact them by post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or phone 0303 1231 113.

You can also make a complaint or find out more information on the Commissioner's Office website.

Or Go Vocal, by e-mail to support@govocal.com, or by post to Pachecolaan 34 (6th floor), 1000 Brussels, Belgium, provided you enclose a copy of the front of your identity card.

When you submit a request to exercise your rights, we will verify your identity if we have reasonable doubts in this regard. We do so to prevent your Personal Data from falling into the wrong hands. If we have doubts about your identity, we will request you to provide us with documents that enable you to identify yourself without a reasonable doubt, such as a copy of your identity card. In this case we urge you to cross out the non-relevant information for the verification of your identity, such as your national citizen number and photo.

Exercising your rights is in principle free of charge. However, if your request appears to be manifestly unfounded or excessive (in particular because of its repetitive character), we may charge you a reasonable fee to cover our own administrative costs. In such cases, we may also simply opt to reject your request. In this event, you will be notified of the reasons for such a decision.

8. Additional information on data collection and processing

8.1. Legal procedures

Go Vocal and the Organization for whom we process your Personal Data may use the Personal Data for legal purposes, for the court or legal proceedings preceding phases in the event of unlawful use of this Application or the related services. You are aware that Go Vocal and the Organization it works with may be obliged to disclose the Personal Data at the request of competent government institutions for the processing of the Personal Data. The legal basis for this processing is the acceptance of the terms and conditions (contractual basis) and the necessity to fulfil a legal obligation.

8.2. Security Measures

The Platform has developed appropriate technological and organizational measures to prevent the destruction, loss, falsification, modification, prohibited access or the erroneous disclosure to third parties of Personal Data as well as any other prohibited processing of this Personal Data. Under no circumstances can the Platform be held liable for any direct or indirect loss resulting from the incorrect or unlawful use of your Personal Data by a third party. You must at all times comply with the security instructions, including by preventing all prohibited access to your login details and password. You are solely responsible for the use made of the Platform on your computer, IP-address and your identification details, as well as for the confidentiality of such.

8.3. Changes to this privacy policy

The Platform reserves the right to change this privacy policy at any time. When the policy changes in a material way we will notify the users on this page. We encourage you to check this page for possible changes. The date of the last change is indicated at the bottom of the page. If you object to any change in the policy, you must cease to use the Platform. Unless otherwise indicated, the valid Privacy Policy applicable at that time applies to all Personal Data that the Platform processes.

Last updated: 26 Feb 2024