Lichfield Community Media C.I.C. privacy policy
This Privacy Policy (“the Policy”) explains the approach Lichfield Community Media C.I.C. (“LCM”, “we”, “us”) takes to personal information collected via the Lichfield Live website (lichfieldlive.co.uk) (“LL”) and other means. The Policy explains the information we collect, how it is stored and what it is used for.
LCM reserves the right to alter, without notice, this policy if either required to by law or to improve the services offered to users.
LCM is registered with the Information Commissioner’s Office (“ICO”) with registration number ZB659775.
Our contact details
We can be contacted via email to yournews@lichfieldlive.co.uk or via post to 29 Bore Street, Lichfield, WS13 6LZ.
The type of personal information we collect
We may collect, use and store the following categories of personal data about you:
- Identity data such as names, titles, usernames, pseudonyms (if used) etc;
- Contact data such as emails, addresses, telephone numbers etc;
- Political party membership where an individual is an elected official and that information is legitimately required for journalistic purposes (see below);
- Financial data such as card details where payments are made;
- Transactional data such as payments made, subscriptions etc;
- Technical data such as IP address, browser type, time zone, location, etc; and
- Usage data such as the number of visits, the time spent on the site, etc.
We do not collect, use or store special category about our website users. Special category data includes:
- Personal data revealing racial or ethnic origin;
- Personal data revealing political opinions (except where an individual is an elected official and that information is legitimately required for journalistic purposes - see below);
- Personal data revealing religious or philosophical beliefs;
- Personal data revealing trade union membership;
- Genetic data;
- Biometric data (where used for identification purposes);
- Data concerning health;
- Data concerning a person’s sex life; and
- Data concerning a person’s sexual orientation.
We do not collect personal data about criminal allegations, proceedings or convictions in respect of our website users.
We may collect, use and store special category data and/or data about criminal allegations, proceedings or convictions where such personal information is legitimately required for journalistic purposes (see below).
How we get the personal information and why we have it
Most of the personal information we process is readily available in the public domain or is provided to us directly by you for one of the following reasons:
- You have accessed the LL website;
- You have commented on an article via the LL website;
- You have emailed, written to or otherwise contacted us;
- You have contributed to surveys;
- You have subscribed to our newsletters or other service; or
- You have made a donation or subscribed to membership via the LL website or through direct payments.
We use the information that you have given us to:
- Identify unauthorised attempts to upload or change information, or otherwise cause damage to our site;
- Undertake statistical analysis of LL usage;
- Record the originator of any comments on the LL website;
- Reply to any correspondence, however received;
- Deliver subscription services such as newsletters;
- Maintain financial records; or
- Produce journalistic content, including contacting those who leave comments on stories.
Where data is aggregated for statistical purposes, this aggregated data is not considered personal data where it cannot directly or indirectly identify you. We may use aggregated data for any purpose.
We may also receive personal information indirectly from a variety of sources, including publicly available sources, when producing journalistic content.
We do not share personal information with any other organisation or individual except for the purposes of storage (see below), where it forms part of legitimate journalistic content or where legally required to do so (for example as required by a court injunction).
Under the UK General Data Protection Regulation (“UK GDPR”), the lawful bases we rely on for processing personal information are:
- Your consent. You are able to remove your consent at any time, You can do this via email to yournews@lichfieldlive.co.uk or via post to 29 Bore Street, Lichfield, WS13 6LZ;
- We have a legal obligation, including maintaining financial records;
- We need it to perform a public task;
- We have a legitimate interest; or
- We are relying on the “Special Purposes” exemption contained in the Data Protection Act 2018 (see below).
How we store your personal information
Your information is securely stored.
- Email addresses and other contact information is stored in Capsule (see https://capsulecrm.com/privacy/)
- Financial transactions are recorded on FreeAgent (see https://www.freeagent.com/website/privacy/) and Stripe (see https://stripe.com/gb/privacy)
- Documents and other information are stored on Google drive (see https://policies.google.com/privacy?hl=en-US#europeanrequirements)
- LL is hosted using Ghost (see https://ghost.org/privacy/) which stores user account details, including email addresses.
Access to all systems is strictly controlled.
Where we share our content via social media (e.g. Facebook, X etc) any comments, “likes” etc you leave are governed by the social media providers’ privacy policies.
We retain personal information only for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting and reporting requirements.
Personal data associated with comments made on the Lichfield Live website (e.g. email addresses, names, pseudonyms, etc) is retained indefinitely for archive purposes in the public interest. Similarly we may retain usage records (both individual and in aggregate) for statistical usage purposes only.
Cookies
Cookies are small text files stored on your device by your browser when you visit a website. We use cookies for the following purposes:
- Functional cookies: these cookies are needed to make the site function correctly and to store your preferences with respect to other cookies;
- Analytics cookies: these cookies are optional and are used for statistical analysis of, for example, site traffic, and to improve your user experience; and
- Advertising cookies: these cookies are optional and are used to help monitor the performance of advertisements.
Non-essential cookies are deployed only after you give your consent. You can adjust your preferences at any time by clearing the cookie cache in your web browser.
Your data protection rights
Under data protection law, you have rights including:
- Your right of access: You have the right to ask us for copies of your personal information;
- Your right to rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to restrict the processing of your personal information is certain circumstances;
- Your right to erasure: You have the right to ask us to erase your personal data is certain circumstances;
- Your right to restriction of processing: You have the right to ask us to restrict the processing or your personal information in certain circumstances;
- Your right to object to processing: You have the right to object to the processing of your personal information in certain circumstances; and
- Your right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
The ICO and UK GDPR recognises that a free and independent press is important in a healthy democracy and media organisations must therefore be able to process personal data when producing journalistic content, where there is a public interest is doing so.
The Data Protection Act 2018 contains an exemption from many of the rights and obligations in data protection law when your personal data is used for “Special Purposes”, including for the purposes of journalism.
The exemption aims to balance freedom of expression with privacy, which are both fundamental rights. It means that where LCM is using your personal data for the purposes of journalism, some of your rights may be restricted. These rights include:
- Your right to obtain a copy of your personal data;
- Your rights to object to the use of your personal data or have your personal data deleted; or
- Your right to be informed that your personal data is being used, and what it is being used for.
However, LCM still needs to comply with data protection law and will only rely on the exemption if:
- We are using your personal data for journalism, with a view to publishing journalistic material;
- We can justify that we reasonably believe the publication of the material would be in the public interest; and
- We can show that complying with the relevant parts of the GDPR would be incompatible with journalism in the specific circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us via email to yournews@lichfieldlive.co.uk or via post to 29 Bore Street, Lichfield, WS13 6LZ.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
