Get Commonplace

COMMONPLACE DIGITAL LTD are committed to protecting and respecting your privacy.

What we do

We want to be really clear about what we do, because it sets the scene for how and why we collect and process personal data.

Personal data means any information about a living individual from which that person can be identified (but not data where the identity has been removed, like anonymous data).

Commonplace.is (referred to as our site or a Commonplace in this document) is an online engagement platform, which helps developers, councils and city managers (our customers) engage with individuals in local communities – people just like you.

Our customers use our platform to gather information that may reveal issues and suggest solutions, as well as for statutory consultation and formal planning applications.

We also help communities use the platform to plan their neighbourhoods, co-design solutions and analyse the social impact of new developments.

We can’t make good community engagement happen without collecting, using and sharing personal data.

In this privacy policy, each individual engagement project is called a Commonplace. Each Commonplace is publicly available and you can see them on the Commonplace places page.

We explain all the details about how we collect, use and process personal data below. If you have any questions, please email privacy@commonplace.is.

 

Project teams

We make it clear to you who initiated the Commonplace. It could be a developer, council or city manager, or it could be an architect or agency working for them, or it could even be someone like you who wants to make something happen in their community.

That person or project team chooses the questions for each Commonplace and it’s up to them to decide what they would find helpful for engagement purposes. We are the platform that makes it happen, but it’s their project or community and they choose the questions.

As well as being transparent about who started a Commonplace, you will also be able to manage your communications preferences for each Commonplace. See Managing your contact preferences below. And by the way, all our communications are opt-in – we won’t spam you!

 

How we collect information

We collect data from you in a number of different ways, depending on how you interact with us.

You can interact with us directly, for example through one of our Commonplaces. Or you can interact with us via someone else, for example by filling in a paper or digital questionnaire in your local area (this data is then provided to us for use in the Commonplace).

If you interact with us directly, we may collect data from you:

  • Via a Commonplace
  • By email
  • Over the phone
  • In person

We may also be given data about you from third parties:

  • From our customers and their project partners (this will include people you interact with locally who may ask you for feedback and record it on a Commonplace.
  • From service providers who we engage on our behalf.
  • From publicly available sources.

We may also automatically collect some technical data about your equipment, browsing actions and patterns.

 

Information we collect

We may collect and process the data about you described below.

The specific data categories vary for each Commonplace and it’s up to the person starting the Commonplace each time to decide what they would find helpful for engagement purposes. The data might include:

  • Information that you provide by participating, for example your email address. (This is important, because we want to make sure our platform is used for feedback from real people – not lots of bots!)
  • Information that you provide by filling in the About you page as part of responding to a Commonplace (or if you update it later). Each Commonplace may be a mix of these and other things, depending on what the person or team originating the Commonplace will find helpful for engagement purposes.
    • Why ask for my postcode? For each Commonplace, it helps map which roads/estates have and haven’t responded.
    • Why ask for my age range? For each Commonplace, it helps identify how many residents have been reached in a particular age group.
    • Why ask for my gender? For each Commonplace, it helps ensure that it has reached a balanced group of people. It’s totally up to you if you share that information.
    • Why ask for my ethnicity? For each Commonplace, it helps identify how many residents have been reached in an ethnic group. It’s totally up to you if you share that information.
  • Generally, information that you provide by filling in questions on a Commonplace or a paper questionnaire that is recorded on a Commonplace.
    • Some of this information is mandatory (for example, we would like you to confirm that your feedback is genuine) and some may be requested to be provided on a voluntary basis – the screens will always make it clear which is which and why.
    • The questions that you fill in for each Commonplace is bespoke for the project, so there may also be project specific information requested.
  • Details of any materials, agreements and comments you put on a Commonplace.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of your visits to our Commonplaces including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access (see IP addresses and cookies below).

 

If you wish to remain publicly anonymous

If you do not want to be identified with material posted by you then you should not include your name or any identifying information in the material posted. We don’t review feedback before it’s published, so it’s important that you take responsibility for this yourself.

 

Managing your contact preferences

When you first contribute to a Commonplace, you are given the opportunity to subscribe to updates about that Commonplace and updates about other Commonplaces in your area. You don’t get any updates without asking for them, so be sure to say Yes please, if you do!

You can manage your preferences for a Commonplace at any time on your Commonplace profile. We only want you to be contacted when you want to be, so we will always get your consent to contact you or to pass your data to a customer or their project partners to contact you. You can withdraw your consent to receive communications by updating your preferences at any time on your Commonplace profile, or by contacting us at privacy@commonplace.is. You can also use the unsubscribe links on any email.

Generally, Commonplaces have the following options:

  • Direct contact – you can consent to be contacted by our customer or their project partners about specific issues raised by you in your feedback and responses.
  • Project news and updates – you can consent to be contacted by our customer or their project partners with news and updates about the project.
  • Newsletter – you can consent to be sent newsletters which may be relevant to your area.
  • New Commonplaces – you can consent to be told about new Commonplaces in your local area.

 

IP addresses

We may collect information about your computer, including where available: your IP address, operating system and browser type. This may be used for system administration and to report aggregate information to our customers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Cookies

Our Commonplaces use cookies to distinguish you from other users and help us to provide you with a good experience when you browse our sites and allows us to improve our sites. For detailed information on the cookies we use and the purposes for which we use them see our cookie policy.

 

Keeping personal data secure

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where you have chosen a password (for example if you are an administrator or surveyor) which enables you to access certain parts of a Commonplace, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the exchange of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

Where we store your personal data

Our servers where we store personal data gathered from people who participate in Commonplaces are located in Europe. If we ever need to transfer personal data outside of Europe, we will follow the rules which govern that.

 

How and why we use information

For each use of personal data, the law requires something that is called a ‘lawful basis for processing’. This defines what each use of personal data is for, which category it fits into and why that’s allowed.

We use information held about you in the following ways:

  • Where we need to perform a contract – that’s the way the law puts it, but it’s essentially using your personal data to carry out something we’ve made a contract with you to do (for example, publishing your comments on a Commonplace).
  • Where it’s necessary for our legitimate interests – this is where we or a third party have a legitimate interest in using your personal data and your interests or fundamental rights don’t override it (for example, including your identifiable comments in a Commonplace as part of a planning application).
  • Where we have your consent to do so – this is where you clearly say to us it’s OK to do something (for example, you ask us to send you news and updates in your preferences).
  • Where we need to comply with a legal or regulatory obligation – this one is probably self-explanatory, but if there’s a law that says we need to keep or hand over some personal data, or if someone in authority asks us to, we’ll follow the rules.

Those are generally the categories under the law which we rely on for it to be OK for us to process personal data. If you’d like to read more about these categories, please refer to the ICO website.

The table below is a bit more detail on the how and why, and then tells you the lawful basis.

 

The sort of data we might use

When we might ask you for it

How and why we might use it

The legal basis on which we use it

Your identity and contact data (email address and/or password)

 

When you contribute to, or log into a Commonplace site.

Your email address is our primary method to identify you, and the contributions and information that belong to you.

Perform a contract – we need to do this to provide our site to you.

 

Your identity, contact data (email address and/or password), technical data, profile, usage, marketing and communications and technical data.

When you use our services on the site.

To provide you with the services and functionality on our site.

Perform a contract – we need to do this to provide our site to you.

 

Your identity, contact data (email address and/or password), technical data, profile, usage, marketing and communications and technical data.

When you subscribe to news, newsletters or contact emails.

To provide you with information that you request from us (for example, to be kept up to date about your local Commonplaces).

Consent – where you have consented to communications.

 

Your identity, contact data (email address and/or password), technical data, profile, usage, marketing and communications and technical data.

When you subscribe to news, newsletters or contact emails.

To provide you with information which we feel, based on the options you have selected, may interest you (for example, to tell you about new Commonplaces or other initiatives which may be of interest to you).

Legitimate interests – it is in our legitimate interests to consider what may interest you.

 

Consent – where you have consented to communications

Your identity, contact data (email address and/or password), and technical data

 

 

When you contribute to, or log into a Commonplace site.

To ensure that content from our site is presented in the most effective manner for you and for your device.

Legitimate interests – it is in our legitimate interests to make sure our site is presented nicely

Your identity, contact data (email address and/or password), technical data, profile, usage, marketing and communications and technical data.

When you contribute to, or log into a Commonplace site.

To provide you with services that you request from us (for example, to participate in a Commonplace).

Perform a contract – we need to do this to provide out site to you.

 

Your identity, contact data (email address and/or password), technical data, profile data, usage, marketing and communications and technical data.

When you contribute to, or log into a Commonplace site.

To allow you to participate in interactive features of our service, when you choose to do so.

Legitimate interests – it is in our legitimate interests to offer features on our site which we consider will enhance our service.

 

 

Your identity, contact data (email address and/or password), and technical data

When you contribute to, or log into a Commonplace site.

To notify you about status and changes to our service.

Legitimate interests – it is in our legitimate interests to keep users of our site updated about the site.

Your identity, contact data (email address and/or password), technical data, profile data, usage, marketing and communications and technical data.

When you contribute to, or log into a Commonplace site.

To manage and improve our day-to-day operations.

Legitimate interests – it is in our legitimate interests to analyse how our site is being used and use that information to improve our business operations.

Your identity, contact data (email address and/or password), technical, and usage data

When you contribute to, or log into a Commonplace site.

To help to develop and improve our services, information technology systems and know-how.

Legitimate interests – it is in our legitimate interests to monitor our site is being used and use that information to improve our technology systems and know-how.

Your identity and contact data (email address and/or password)

When you contribute to, or log into a Commonplace site.

To contact you about a comment that you have made on a Commonplace site.

Consent - where you have consented to communications about feedback you have made.

Your identity, contact data (email address and/or password), technical, usage and profile data

When you contribute to, or log into a Commonplace site.

To deal with feedback and complaints about our site.

Legitimate interests – it is in our legitimate interests deal with feedback and complaints.

Your identity, contact data (email address and/or password), technical data, profile data, usage, marketing and communications and technical data.

When you contribute to, or log into a Commonplace site.

To respond to law enforcement or regulators about users of our site.

Legal or regulatory obligation – we need to do this so that we do not break the law.

 

Anonymised information

All Commonplaces are publicly available on the internet.

If you contribute to a Commonplace, your feedback and any agreements added by you, are collected on an anonymised basis and made available publicly to anyone who has an interest in the information. The words of your feedback and your agreements may be used for further analysis, but they won’t know your identity unless you shared something in your comment that reveals that (see section ‘If you wish to remain publicly anonymous’ above).

 

Sharing your information

Who is it shared with?

Why?

Our project partners (e.g. developers, councils, city managers).

Remember: if you don’t want us to share your personal data with project partners, or if you don’t want project partners to contact you, you can control this when you first contributed and by changing your account settings.

To enable the Commonplaces to be delivered as instructed by our customers; to enable project partners to respond directly to you, if you have consented to this.

For each Commonplace you participate in, you can see who your information is shared with by logging into the relevant Commonplace. The exact nature of the information that gets shared, and why, for each Commonplace depends on its settings and your preferences.  Our project partners may also incorporate information from a Commonplace into more formal processes, like planning applications.

If you do not want us to share your data with project partners, please edit your personal information.

Other users of the site.

It might be a bit obvious saying this, but hey: if it’s on the site, it’s public – so that’s like sharing it with the world.

Service providers (e.g. technology providers).

To enable us to run our business and provide the site.

For example, companies that we buy IT services from (storage, software and connectivity).

Where we engage a third party to process personal data on our behalf, we enter into a contract with them which contains standard clauses to ensure they process personal data in compliance with the law.

Our key service providers are below and you can learn more about the privacy of their services at each of their websites:

  • Amazon Web Services
  • Google Analytics
  • New Relic
  • Mixpanel
  • Sendgrid
  • Hotjar
  • MLab

HM Revenue & Customs, regulators and other authorities

Compliance and reporting

Professional advisers, including lawyers, bankers, auditors and insurers

They provide consultancy, banking, legal, insurance and accounting services to us

 

Third party links

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for these third parties.

Please check their privacy policies before you submit any personal data to these websites.

Advertising on websites invariably involves some form of tracking. We don’t place any of these trackers ourselves, but many third parties do. Learn more about this on the Your Online Choices Website.

 

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information to third parties, including:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Commonplace Digital Ltd, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Commonplace Digital Ltd, our customers, or others.

If we are asked to as part of them seeking to exercise of defend their legal rights (for example, as part of a planning application or a judicial review).

 

How long we keep your information

We will only keep your information for as long as necessary to carry out the purposes for which we collected it (which, generally, is your participation in a Commonplace). This will depend on the type of information and the types of legal and contractual obligations we must comply with.

We don’t want to keep personal data for longer than is necessary, so when we are deciding how long to keep each category of personal data, we think about the following things: how much data we have, whether it’s sensitive or not, what kind of harm there could be if there were an unauthorised disclosure.

These periods will vary by Commonplace, so if you have a question about how long personal information is kept for each Commonplace, please ask us. The person or team originating the Commonplace will have their own periods for which they keep personal data. As a rule of thumb, you should expect them to keep personal data for as long as any planning process or appeals may be ongoing.

 

Your rights

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Commonplace Digital Ltd, Cardinal House, 20 St Mary's Parsonage, Manchester M3 2LG.

The Act gives you the right to access information held about you. Your Commonplace profile shows you everything we store on you and lets you exercise a lot of your rights. Your right of access can be exercised in accordance with the Act. Any access request that requires manual work to access or modify data may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. For more information on how to make an access request see the ICO website for personal information.

We try to respond within 40 days, but if your request is complex or you’ve made a number of different requests, it may take us longer. If that’s the case, we’ll keep you updated.

If you’d like to exercise any of these relevant rights, please contact us at privacy@commonplace.is.

When you contact us to exercise your rights, we need to be sure it’s you. We may need to ask you to confirm your identity – this is an important security measure so that we don’t disclose personal data to any person who doesn’t have the right to receive it.

Right now, the laws which apply to how we may process personal data about you are changing.

From 25 May 2018, the Act will be replaced by the General Data Protection Regulation (the GDPR).

Under the GDPR you get wider rights than just the right of access under the Act. Under the GDPR your individual rights are:

  • The right to be informed – that’s us telling you what we do with your personal data (which we do in our screens and forms and via this privacy policy).
  • The right of access – it’s the same right as under the Act, but from 25 May 2018 you don’t have to pay the £10 fee.
  • The right of rectification – that’s an obligation on us in certain circumstances to correct your personal data if it’s inaccurate or incomplete.
  • The right to erasure – that’s an obligation on us in certain circumstances to delete or remove your personal data where there is no compelling reason for its continued processing (some people also call this right ‘the right to be forgotten’).
  • The right to restrict processing – that’s an obligation on us in certain circumstances to stop actively processing your personal data.
  • The right to data portability – that’s an obligation on us in certain circumstances to allow you to transfer your personal data from us to a third party.
  • The right to object – that’s an obligation on us in certain circumstances to allow you to object to us processing your personal data where we do not have an overriding reason.

Not all of these rights will be relevant to your use of Commonplace, just because of the nature of our site, but they are important rights and we want to make sure you know about them. If you’d like to read more about them, you can get more information on the ICO website.

(The ICO, who enforces the Act and will enforce the GDPR, hasn’t published a page on these rights for the public yet – but as soon as it’s available, we’ll update this link.)

If you wish to make a complaint about our use of your personal data please read the ICO guidelines for raising concerns. We’d appreciate the chance to deal with your concerns before you raise a formal complaint though. Thank you!

 

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

 

Contact

Got any questions? Please contact us by email: privacy@commonplace.is.