Privacy Policy

Published 04/08/2021   |   Last Updated 16/09/2021   |   Reading Time minutes

The statement below provides an overview of how we will treat the information you provide to us.

Who we are

We are the Independent Remuneration Board of the Senedd.  We are the data controller of the information you provide and will ensure it is protected and used in line with data protection legislation.

Our contact details

We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice.  If you have any further questions about the way in which we process personal data, or how to exercise your rights, please contact our Data Protection Officer:

Why we are collecting this information

We use personal data to fulfil our functions and activities.  These include:

  • making decisions on the pay and allowances available to Members of the Senedd under our Determination;
  • considering applications from Members of the Senedd for exceptional expenses;
  • consulting with Members of the Senedd, their support staff, trade unions and others on the decisions we take;
  • engaging with stakeholders;
  • information and record keeping; and
  • administration connected with our activities.

Information may be gathered from a range of individuals including: Members of the Senedd and their support staff, Group support staff, Senedd Commission officials, trade union representatives, members of the public, and other stakeholders.

Information will be gathered in a variety of ways which include: consultations; surveys; correspondence including emails; representation or other engagement sessions with Members of the Senedd and support staff; and meetings with stakeholders.

Through the course of our activities, we may hold the contact details and other personal data of individuals at other organisations with whom we have a relationship, including our contractors and consultants.

We use social media channels as a key part of our public engagement work.  As well as using these channels to put out information for awareness raising purposes, we encourage interactions.  Content includes, but is not restricted to, images, videos, infographics and animations.  The channel we are currently active on is Twitter.

Our legal bases for collecting, holding and using your personal information

Data protection law sets out various legal bases (or ‘conditions’) which allow us to collect, hold and use your personal information.  For the purpose of processing the personal data you provide, we rely on the following legal bases:

The processing is necessary for the performance of a task carried out in the public interest

The task is to facilitate the work of an independent body to carry out its activities connected with determining the pay and allowances for Members of the Senedd.  The scope of our activities is set out under sections 20, 22, 24, 53 and 54 of the Government of Wales Act 2006 and the National Assembly for Wales (Remuneration) Measure 2010 and relates to making decisions on pay and allowances for Members of the Senedd.  We must act in an open and transparent manner.  We must consult those who are likely to be affected by our decisions, including Members of the Senedd, staff employed by Members of the Senedd (or by groups of Members of the Senedd), relevant trade unions, and such other persons as we consider appropriate.

The performance of a contract

We may enter into contracts to assist with our activities and decision making.

Special category personal data

We may process special category personal data as part of our information gathering. Special category personal data is defined as including data revealing racial or ethnic origin, religious or philosophical beliefs, sexual orientation and data about health. We may process any relevant special category data about you and anyone else you mention in your response.

Special category data will be processed on the basis that it is necessary for reasons of substantial public interest (as provided for by Article 9(2)(g) of the GDPR, read in conjunction with paragraph 6 of Schedule 1 to the Data Protection Act 2018).

What we will do with your information

We must generally act in an open and transparent manner, and publish such information as will enable the public to be kept informed as to our activities.

Information you provide will be seen in full by the Board members and the secretariat to the Board (employees of the Senedd Commission) who are involved in the relevant activity.

Some information may be shared with employees of the Senedd Commission in order to obtain views and advice in considering any changes to the pay and allowances available under the Determination and how any changes should be administered.

Where we are considering an application for exceptional expenses, we may need to share information with employees of the Senedd Commission in order to give proper consideration to the claim.

If you add a comment or tag us in a tweet, we may store the data.  This would include your user name, and any other personal information you have shared with us.  Depending on what views and experiences you have decided to share, the content of your tweet may be considered as special category data.

Most of the time we will not be processing any information provided to us via social media, and our interactions remain on the channels themselves.  These are covered by the terms and conditions and privacy notices of Twitter. We do not use any data that people have not already agreed to make public on the channels themselves.  Twitter’s privacy notice is available here: https://twitter.com/en/privacy.

Where we will store your information

Your information will be stored on the Senedd Commission’s ICT network (which includes third party cloud services provided by Microsoft).  Any transfer of data by Microsoft outside of the United Kingdom, other than transfers to the EEA, is covered by contractual clauses under which Microsoft ensures that personal data is treated in line with European legislation. Details about how Microsoft will use your data are available on their website: https://privacy.microsoft.com/en-gb/privacystatement

Information may also be retained in the Senedd’s business management system provided by Mod.Gov.

Publication of personal data

We may publish some or all of your information provided to us in a submission to a consultation, a survey response, correspondence or during meetings.  Such publication will be on our website.  We may also publish extracts of your information within documents produced in relation to our activities and published on our website.  Any information that is published on our website will remain in the public domain.

If we publish information you have provided on behalf of an organisation or political group within the Senedd, we will include your name, job title and the name of your organisation or political group with your information.  If we publish information you have provided on your own behalf, we will only publish your name if you have asked us to do so.

We are required to lay before the Senedd an annual report on our activities, including our use of resources, during a financial year.  Our report may include information we obtain through our activities.

Please let us know if you would prefer that your information, or extracts from it, are not published.

We will also publish the titles of any research for which the Policy, Research and Communication Fund has been used, along with the cost and the name of the service provider.

How long your information will be retained

Your information will be retained until we have completed the relevant piece of work and for a period of no longer than six months after. After the six month period, we will retain anonymised information.  Anonymised information will be retained for the duration of the Sixth Senedd, being the period during which the Determination is in force.  The anonymised responses are retained to help inform the Board’s annual reviews of the Determination.

We will keep information in relation to exceptional expenses until six months after the end of the last financial year in which the expenses are paid.  This information is required for the purpose of preparing our annual report.  Claims which relate to ongoing expenses are used for the purpose of annual reviews in deciding whether the expenses are still required.

Any information which has been published into the public domain, will remain there.

 

Website

Cookies are pieces of data that are often created when you visit a website and are stored in the cookie directory of your own computer.  Cookies policy

Log files allow us to record visitors’ use of the site.  Log files do not contain any personal information or information about which other sites you have visited.

What happens when I link to another site?

Other websites linked from this site are not covered by this privacy policy. Our website, hosted on the Welsh Parliament website, contains links to other websites, both those of government departments and of other organisations.  You should always be aware when you are moving to another site and we would encourage you to read the privacy policies of the other websites that you visit.

 

Contacting you

We may use the contact details you provide to contact you in relation to the matter for which you have provided information, and any additional work undertaken as part of our consideration of the matter.  Please inform us, when you contact us, if you would like us to retain your contact details and contact you for these purposes.  If you decide to opt into further contact, you may opt out of further contact at any point by letting us know.

Requests for information made to the Remuneration Board

In the event of a request for information being made under access to information legislation, it may be necessary to disclose all or part of the information that you provide. This may include information which has previously been removed by us for publication purposes. We will only do this if it is required to do so by law.

Your rights

As a data subject, you have a number of rights. The rights which apply depend on the legal bases we are relying on to use your personal information. Those rights will not apply in all instances, and we will confirm whether or not that is the case when you make a request.

The rights include the right to request access to your own personal information, sometimes called a ‘subject access request’.

Additionally, you have the right to request from us:

  • that any inaccurate information we hold about you is corrected (please note that you are required to keep us up to date with any changes to your personal information);
  • that information about you is deleted (in certain circumstances);
  • that we stop using your personal information for certain purposes or in certain circumstances; and
  • that your information is provided to you or a third party in a portable format (again, in certain circumstances).

If you would like to engage any of the rights that you have under data protection legislation, ask a question or make a complaint about how your information is used; please contact our Data Protection Officer.

How to make a complaint

You can complain to our Data Protection Officer at the contact details above if you are unhappy with how we have used your data.

If, following a complaint, you remain dissatisfied with our response, you can also complain to the ICO.  The ICO’s address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF