Privacy Policy

Who we are

Moray Council, Council Office, High Street, Elgin, Moray, IV30 1BX, www.moray.gov.uk 01343 543451, is a Local Authority established under the Local Government etc. (Scotland) Act 1994. We are the Data Controller of the personal data being collected.  

Why we are collecting your personal data

You can choose to get involved with Moray Engage, the Council’s Community Engagement Platform https://engage.moray.gov.uk without providing any personal data. Publicly accessible sections of Moray Engage can be browsed completely anonymously and you can get take part in the majority of projects anonymously, without registering.

Personal data will only be collected from you in the following instances: 

Registration - Profile Information

Some projects require you to register to take part. The registration form will ask for your email address, year of birth, part of your postcode, and your gender identity (you can select ‘prefer not to say’ if you wish).

We may use this data to contact you to let you know the outcome of the project(s) you have taken part in, and, to analyse contributions to any engagement activity that you choose to take part in. If you choose to register an interest in being part of a citizens panel, then we will use the email address on your registration form to contact you regarding this.

The registration form will also ask you if you would like to provide equalities information, including health information, and whether you look after, help or support another person for health reasons or problems related to old age. You do not need to provide this information. Moray Council has a legal duty under the Equality Act 2010 to consider the impact of all its strategic, policy, procedural and operational decisions. If you choose to provide this information, we will use it to inform our assessments on the impacts our decisions may have on protected groups, to help make sure we deliver fair and inclusive services. 

Some Moray Engage hubs may offer newsletters, if you wish to subscribe to these your email address and username will be provided to the relevant service. Details on how to unsubscribe will be provided on each hub/newsletter.

Engagement Information

The content you create as part of your interactions with the Moray Engage website will be collected. This includes responses to surveys, comments on discussion forums, or any of the other engagement opportunities. We collect this information to help inform the creation of better services and policies. The information provided will be anonymised when used for analysis and reporting purposes.

Private Hub/Protected Spaces

If you choose to participate in engagement activities within a Private Hub or a Protected Space, then further personal data beyond the registration data may be required. In these instances (such as for a Citizen Panel’s User Group or focus group) this is to ensure users are eligible to take part in these engagement activities. If users wish to use these spaces, they should be aware of dedicated Privacy Notices, and Forum Etiquette and Moderation requirements.

The information collected will be used to:

• analyse and interpret data to help meet the Council’s objectives and in some cases, our statutory and legal obligations
• respond to enquiries and otherwise engage with all stakeholders (including Moray residents, visitors to Moray, organisations and all with any connection to Moray)
• to inform service development and delivery, to ensure that our Services and processes are fit for purpose, efficient and effective
• plan, design and improve the services we offer
• evidence positive outcomes from accessing Council Services.

When you have requested to be informed about the outcome of engagement exercises and/or engagement opportunities, events and other initiatives, we will use the contact details you provide to communicate with you regarding these.

On occasion, additional personal data may be collected by Council Services via Moray Engage, for example when completing a Tenant Participation Survey. In these instances, a separate Service specific Privacy Notice will be made available prior to the collection of your personal data, to explain why it’s needed, how it will be used, shared and your data rights. For further information, please see our central Privacy Notice webpage: www.moray.gov.uk/PrivacyNotices

Usage Information

Information about your usage of the site, including the pages you visit and documents you download will also be collected.

Personal data you give us about other people 

If you have provided, or have been asked to provide, someone else’s personal data for a specific purpose; if reasonable to do so then please make sure that you have told them that you have given their personal data to us for this purpose. 

Our legal basis

Whenever the Council processes personal data we need to make sure we have a legal basis for doing so. We understand the Council’s legal basis in data protection law to be Article 6(1)(e) of the United Kingdom General Data Protection Regulation (UK GDPR), because your personal data is necessary for the performance of a task carried out in the public interest, under legislation including the Local Government in Scotland Act 2003 and the Community Empowerment (Scotland) Act 2015. 

When you choose to subscribe to a newsletter, have asked to be kept informed about the outcome of a project, or, to be contacted about further engagement exercises or future engagement opportunities, we understand our legal basis to typically be Article 6(1)(a) of the UK GDPR because you have given consent to your personal data being used for these purposes.

Engagement that involves the collection of special category data, such as health information, and/or criminal offence data would have a separate dedicated Privacy Notice linked from that engagement page or activity, and available on the Council’s dedicated Privacy Notice webpage: www.moray.gov.uk/PrivacyNotices 

Who we share this personal data with

The personal data you provide when using Moray Engage will be shared with a third party - Granicus LLC, our Community Engagement platform provider. Granicus LLC provide the software platform that the Moray Engage website runs on and associated technology operations. We make sure that they process your personal data appropriately through our contractual arrangements with them. For more information on how Granicus LLC process personal data, please see their Privacy Policy available on their website here: https://granicus.com/uk/trust-center/privacy-policy/  

Your personal data may be shared internally with authorised officers of the Council if having access to personal data is a necessary part of their roles to ensure records are accurate and up to date. It may also be shared with other relevant Council departments where applicable.

The Council may share your personal data with other relevant Council departments and third parties, where we are under a legal obligation to do so. For example, this may be with Police, Social Security Scotland, UK Border Agency, or other Registered Professional Bodies.

The Council is required by law to protect public funds against fraud. It may share personal data with other relevant Council departments and third parties responsible for auditing and administering public funds, or who otherwise have responsibility for preventing and detecting fraud.  

How long the personal data is held for 

Your personal data will be securely stored by Moray Council for a pre-determined length of time. Information is only kept for the minimum amount of time necessary. We maintain a record retention schedule which sets out how long we retain different types of personal data. This is available on our website: www.moray.gov.uk/RetentionSchedules

Your rights

Moray Council is the Data Controller for this personal data. You have legal rights about the way the Council handles and uses your personal data. These include the right to ask for a copy of it, to ask us to correct it and to ask us to stop doing something with your personal data. 

You have the right to withdraw your consent to being contacted about engagement opportunities, events and other initiatives at any time by contacting: engage@moray.gov.uk

As so far as the legislation permits, you also have the right to request the deletion of your data, and to object to the processing.

For more information about these rights, please see the Information Management pages on the Council’s website here: www.moray.gov.uk/InformationRights.

Alternatively, email the Council’s Data Protection Officer at: IG@moray.gov.uk

You also have the right to make a complaint to the Information Commissioner’s Office. They are the body responsible for making sure organisations like the Council handle your personal data lawfully.

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113          Website: https://ico.org.uk/ 

External links

Please note that the Moray Engage website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of linked websites, and we suggest you review the privacy policies of those websites before using them.