Privacy
Peabody Complaints Archive is an independent website. It is not affiliated with, endorsed by, or operated by Peabody Trust.
Who is responsible for your personal information?
The data controller for this website is:
David Wood
Editor, Peabody Complaints Archive
Email: PBCAEditor@gmail.com
The data controller decides how and why personal information received through this website is used.
What information may be collected?
The website does not require visitors to create an account or provide personal information in order to read its content.
Personal information may, however, be received when someone contacts the editor, submits documents or information, requests a correction or right of reply, or otherwise corresponds with the site.
This may include:
- names and contact details;
- email correspondence;
- documents relating to complaints, service charges, housing management, repairs, legal proceedings or other matters covered by the site;
- information about residents, employees, contractors, public officials or other individuals contained within submitted material; and
- information necessary to verify claims or prepare articles.
Submitted documents may sometimes contain sensitive personal information. Such information will only be retained, used or published where there is a legitimate editorial reason and a lawful basis for doing so. Unnecessary personal information will normally be disregarded or redacted.
Please avoid sending personal information that is not relevant to the matter you are contacting the site about.
Why is personal information used?
Personal information may be used to:
- respond to correspondence;
- review information or documents submitted to the site;
- verify facts;
- investigate matters that may be of legitimate public or resident interest;
- prepare, fact-check and publish articles;
- consider requests for corrections, clarification or rights of reply;
- maintain appropriate editorial records; and
- establish, exercise or defend legal rights where necessary.
Information supplied for editorial purposes will not ordinarily be used for unrelated purposes.
Lawful basis
For most processing, the lawful basis relied upon is legitimate interests under Article 6(1)(f) of the UK GDPR.
Those legitimate interests include operating an independent publication, investigating and reporting matters affecting residents and leaseholders, verifying information, maintaining accurate editorial records, responding to correspondence, and enabling individuals and organisations referred to on the site to provide corrections or responses.
Where processing is necessary to comply with a legal obligation, Article 6(1)(c) may apply.
Some processing undertaken for journalistic purposes may also fall within the provisions and exemptions applying to journalism under the Data Protection Act 2018.
Where particularly sensitive information, including special category data or information concerning criminal allegations or proceedings, is involved, it will only be processed where an additional lawful condition or applicable journalistic provision permits this.
Information supplied about other people
Documents and correspondence submitted to the site may contain information about people other than the person making the submission.
Such information may be used where it is relevant to legitimate editorial work, verification or publication. The site seeks to distinguish between information that is genuinely relevant and personal information that does not need to be retained or published.
Personal details may be redacted or omitted where identification is unnecessary.
Where appropriate, people referred to in published material may be contacted for comment or offered a right of reply.
Publication and anonymity
Providing information to the site does not automatically mean that it will be published.
Where documents or information are published, personal information may be redacted where appropriate.
Residents and other sources may request anonymity. The site will normally respect such requests, although there may be circumstances in which information cannot responsibly be used without identifying its source. Where this arises, it will normally be discussed with the source before publication.
The identity of a confidential source will not ordinarily be disclosed merely because another person or organisation requests it.
Who may receive personal information?
Personal information is not sold.
Information may be processed using service providers necessary to operate and communicate through the site, including:
- email providers;
- website hosting and infrastructure providers; and
- privacy-focused website analytics services.
Information may also be disclosed where required by law, where necessary in connection with legal proceedings, or where the person concerned has authorised disclosure.
Information intended for publication may, of course, become publicly available once published.
Correspondence sent to PBCAEditor@gmail.com is processed using Google's email services.
Email should not be regarded as a completely secure method of communication. If material is particularly sensitive, consider whether unnecessary personal information can be removed before sending it.
Website analytics
The site uses GoatCounter to obtain basic statistics about visits to the website, such as which pages are viewed and general information about browsers and devices.
GoatCounter does not use tracking cookies, advertising identifiers or persistent browser identifiers for this purpose and does not store visitors' IP addresses in its analytics database.
The information is used to understand how the site is being used and to help maintain and improve it.
Website hosting and technical data
Like most websites, the infrastructure used to deliver the site may necessarily process technical information such as IP addresses, browser information and request logs in order to provide, secure and maintain the service.
Such processing may be carried out by the site's hosting or infrastructure providers under their own privacy and security arrangements.
International processing
Some service providers used by the site may process information outside the United Kingdom.
Where UK data-protection law requires safeguards for an international transfer, the relevant service provider is expected to use an applicable lawful transfer mechanism or other recognised safeguard.
How long is personal information kept?
Personal information is kept only for as long as it remains reasonably necessary for the purpose for which it was received or for a related legitimate editorial, evidential or legal purpose.
In practice:
- routine correspondence that no longer has any continuing relevance may be deleted;
- unsuccessful or irrelevant submissions may be deleted once they are no longer required;
- material relied upon for a published article may be retained for longer so that the accuracy of the article can be demonstrated or challenged;
- records relating to disputes, complaints or legal proceedings may be retained while those matters remain relevant; and
- published material may remain available indefinitely as part of the site's public archive unless there is a reason to amend or remove it.
Retention decisions take account of the nature of the information, its continuing editorial or evidential value, privacy risks, and any legal obligations.
Your rights
Depending on the circumstances and the lawful basis being relied upon, data-protection law may give you rights including:
- the right to ask whether personal information about you is being processed and to request access to it;
- the right to ask for inaccurate information to be corrected;
- the right to request deletion of personal information in some circumstances;
- the right to request restriction of processing in some circumstances; and
- the right to object to certain processing.
These rights are not absolute. In particular, data-protection law contains provisions and exemptions relating to journalism, freedom of expression, legal claims and the rights of other people. A request will therefore be considered according to the circumstances in which the information is held and used.
Requests can be sent to PBCAEditor@gmail.com.
Your right to object
Where personal information is processed on the basis of legitimate interests, you have the right to object to that processing.
An objection will be considered in light of your circumstances and the reasons for which the information is being processed. There may be circumstances in which processing can lawfully continue despite an objection, including where there are compelling legitimate grounds or where information is required for legal or journalistic purposes.
Complaints
If you have concerns about how personal information relating to you has been handled, please contact PBCAEditor@gmail.com.
The aim will normally be to resolve concerns directly where possible.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.
Information about making a complaint is available at ico.org.uk.
Automated decision-making
The site does not use personal information to make automated decisions about individuals and does not carry out profiling for this purpose.
Changes to this notice
This privacy notice may be updated as the website or its methods of operation change.
The current version will always be published on this page, together with the date it was last updated.