What are cookies?
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work more efficiently as well as to provide information to the owners of the site.
Some examples of cookie usage are:
Storing information to personalise the website to your requirements
A website that sells things may use a cookie to record items you have in a shopping basket
Cookies can be used to record users behaviour on a website, for example to record the pages they have viewed
There are two different types of cookie that can be placed in your browser by a website:
Session cookies are only used for the period you use the website, and are deleted when you close your web browser. A new cookie would then be placed in your web browser if you were to visit the same website again in the future.
Persistent cookies remain in your browser once you have left the site and closed your web browser. The next time you visit the site the information in the cookie will be used to ensure the website works as set up at the previous visit, for example to display certain things on the homepage. Persistent cookies will expire if the website that set them is not visited again within a certain time.
Cookies on this website
We use a Google Analytics cookie on our website to record website usage. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone, we do not make any attempt to find out the identities of those visiting our website, and we do not share this information with anyone.
Managing cookies on your computer
Most web browsers allow some control of cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage or delete them, visit the About Cookies website (opens in new window).
You can choose to block the cookies that are set by the HCEB website, however you must be aware that doing so may mean that parts of the site will not work correctly.
The law that controls how cookies are used on websites has changed. There is more information on the Information Commissioners website (opens in new window).
Information Governance Policy
Heathrow Community Engagement Board Limited, a registered company limited by guarantee.
means the General Data Protection Regulation.
Means the Data Controller
Register of Systems
means a register of all systems or contexts in which personal data is processed by HCEB Ltd.
1. Data protection principles
HCEB Ltd is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
a. This policy applies to all personal data processed by HCEB Ltd.
b. The Responsible Person shall take responsibility for HCEB Ltd’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. HCEB Ltd shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, HCEB Ltd shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to HCEB Ltd shall be dealt with in a timely manner.
4. Lawful purposes
a. All data processed by HCEB Ltd must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
b. HCEB Ltd shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in HCEB Ltd’s systems.
5. Data minimisation
a. HCEB Ltd shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
a. HCEB Ltd shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, HCEB Ltd shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
a. HCEB Ltd shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, HCEB Ltd shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).