SONI's Online Consultation Portal is a free service provided to enable participation in public consultations. The portal publishes consultations to which you can make submissions, receive messages about consultations, read and interact with published submissions, make applications to our services.
SONI fully respects your right to privacy. We will not collect any personal information about you on its public consultation portal without your clear permission. Any information, which you submit via SONI's websites will be treated with the highest possible standards of security and confidentiality, strictly in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. This privacy statement sets out how SONI (Data Controller) and CiviQ (the Data Processor and the company that runs the online consultation portal service) processes your personal data, secures this personal data, and the various policies that adheres to General Data Protection Regulation.
SONI reserves the right to amend the scope of the privacy statement at any time which may include or exclude other sites or platforms
Identity and the contact details of the controller:
The Data Controller is Data Protection Officer, SONI Limited, 12 Manse Rd, Belfast BT6 9RT
Contact details of the data protection officer:
- - Data Protection Officer email: DataProtection@soni.ltd.uk
Identity and the contact details of the processor:
The Data Processor is CiviQ, Business Barn, Kellystown Lane, Leixlip, Co. Kildare.
-- Email: email@example.com
-- Phone: (01) 2548006
How we collect your information
SONI and the data processor, CiviQ, collects personal information from you on our behalf, via the Online Consultation Platform, known as the "platform", to facilitate your responses to public consultations and engagement with other respondents. Your data is collected in the following ways:
- Directly from your written input to the platform via the registration form, submission forms, survey forms and comment boxes;
- Automatically through the platform’s technologies including tracking online, such as by web cookies (which are small text files created by websites that are stored on your computer)
The information you provide
We collect the following information about you from your use of the platform:
- Contact details, including your name, email address, postal address, website and telephone number;
- Organisational affiliation if you are registering an organisation or a company;
- Gender and age (optional);
- Usernames and passwords;
- Website security roles to allow you to securely perform some limited functions within the CiviQ platform;
- Tracking codes, such as cookies;
- Submissions, comments, emails, feedback about the platform, indicators of support to other users, and other content you provide via the platform;
- Consent to receive emails from subscriptions, notifications and messages including date and time of consent;
- Anonymised Internet Protocol (IP) addresses used to connect your computer to the Internet;
- Account creation and last log-in date and time;
- Audit of moderation tasks on your submission
If you make a submission to some types of consultation, there is or may be a requirement to provide your name and address. The platform therefore requests these details at log in to facilitate your participation in all types of consultation, in an efficient and effective manner.
Some types of communications from the platform require your consent. These include messages and notifications. You may choose to receive notifications about consultations; system messages and notifications or withdraw consent to the same.
What we need and why we need it
We may use information we hold about you in the following ways:
Information you give us.
We will use this information:
- to carry out our obligations to process your responses to public consultations;
- to provide you with information;
- to notify you of confirmation that we have received your response to a consultation;
- to notify you about changes to any of our services;
- to ensure that content from the platform is presented in the most effective manner for you and for your computer;
Information collected about you by the platform.
This information is used:
- to administer the platform and for internal operations, including troubleshooting and testing.
- to improve the platform to ensure that content is presented in the most effective manner for you and for your computer or mobile device;
- to keep the platform safe and secure; and
- to help improve the reach and inclusiveness of public consultations using third party services such as Google Analytics.
Our legal basis for using your information
The main legal basis for processing your personal data is that such processing is:
- necessary for us to carry out our tasks in the public interest and/or in the exercise of official authority vested in SONI.
We will ask for your consent with regard to certain types of communications and notifications.
How long we hold your data
We will retain your data until such time as required by legislation or, where there is no legislative requirement, until you remove your consent. You can manage your consent settings for communications, notifications and messages via the Manage Consent page on the platform –https://consult.soni.ltd.uk/user/consent.
Storage of your information, international data transfers and security
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
The transmission 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 platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
Transfers of data will be within the European Union and therefore covered by GDPR.
Disclosure of Your Information
We will not share your information with third parties. Some third parties may occasionally have access to areas of the platform where your data is stored for the purposes of providing the platform service, development, testing and fixing of the platform. In these cases, the third parties will also be bound by data protection agreements that comply with the GDPR.
Your personal data is not used for any automated decision-making.
You have certain rights in relation to your personal information that is processed by us. These rights are listed below. These rights are not absolute and apply subject to certain conditions. For example, your rights may include:
- the right to access personal data held by us about you;
- the right to require us to rectify any inaccurate personal data held by us about you;
- in certain circumstances, the right to require us to erase personal data held by us about you;
- in certain circumstances, the right to restrict our processing of personal data held by us about you;
- in certain circumstances, a right to receive personal data which you have provided to us in a structured, commonly used and machine readable format. You may also have the right to require us to transfer this personal data to another organisation where feasible, at your request;
- the right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you); and
- the right to withdraw your consent, where we are relying on it to use your personal data
Some rights you can exercise directly on the platform via your Personal Account page; My Submissions Page; Manage Consent page; and by checking certain boxes on the consent forms we use when collecting your personal information. These facilitate you keeping your personal details up to date and prevent certain types of processing.
With regard to communications, if at any point you wish to review or change your preferences, you can use the ‘opt-out’ or 'unsubscribe' mechanism or other means provided within the communications that you receive from us. Note that you may still receive transactional communications regarding your submissions.
To inquire about or exercise other rights please email the data controller. CiviQ will action any instructions from SONI, the data controller, with respect to your request.
Obligation to provide personal data
In order to provide certain services to you, SONI requires your personal data, and cannot provide the services without this data. Where we require these data it will be made clear to you on application for these services, what personal data will be required to be held and processed.
Changes to this policy
Concerns or complaints
If you have any concerns or complaints about the processing of your personal data or SONI's responses to regarding your personal data, you have the right to lodge a complaint to the The Information Commissioner’s Office – Northern Ireland, 3rd Floor, 14 Cromac Place, Belfast, BT7 2JB
-- email: firstname.lastname@example.org
For further information please visit the Data Protection section of SONI's website.
For further assistance on Data Protection contact: Data Protection Officer, SONI Limited, 12 Manse Rd, Belfast BT6 9RT FW28.
-- E-Mail: DataProtection@soni.ltd.uk
12th February 2021