MyTown Media Ltd is an on-line publisher.

This policy sets out the practices for My Town Media Ltd which is the single trading name for MyWelshpool and MyNewtown on-line only publications.

Our website is www.mytownmedia.co.uk and the publication website addresses are www.mywelshpool.co.uk and www.mynewtown.co.uk 

MyTown Media Ltd is committed to conducting its business in accordance with the General Data Protection Regulation (GDPR) 2018.
The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Compliance

This policy applies to all MyTown Media staff. Any breach of this policy or of the Regulation itself will be considered an offence and the company’s disciplinary procedure may be invoked.

As a matter of best practice, other agencies and individuals working with MyTown Media Ltd and who have access to personal information, will be expected to read and comply with this policy. 

General Data Protection Regulation (GDPR)

This piece of legislation came into force on the 25^th, May 2018. The GDPR regulates the processing of personal data and protects the rights and privacy of all living individuals (including children), for example by giving all individuals who are the subject of personal data a general right of access to the personal data which relates to them.

Individuals can exercise the right to gain access to their information by means of a ‘subject access request’. Personal data is information relating to an individual and may be in hard or soft copy (paper/manual files; electronic records; photographs; CCTV images) and may include facts or opinions about a person.

Responsibilities under the GDPR

MyTown Media Ltd will be the ‘data controller’ under the terms of the legislation – this means it is ultimately responsible for controlling the use and processing of the personal data

Individuals who provide personal data to MyTown Media Ltd are responsible for ensuring that the information is accurate and up-to date.

Individuals Rights

The main rights for individuals under the GDPR will be: 

• Subject access 
• To have inaccuracies corrected 
• To have information erased 
• To prevent direct marketing 
• To prevent automated decision making and profiling 
• Data portability 

Data Protection Principles

The legislation places a responsibility on every data controller to process any personal data in accordance with the eight principles. More detailed guidance on how to comply with these principles can be found in the DPCoP at www.ico.gov.uk

In order to comply with its obligations, MyTown Media Ltd undertakes to adhere to the eight principles:

1) Process personal data fairly and lawfully.

MyTown Media Ltd will make all reasonable efforts to ensure that individuals who are the focus of the personal data (data subjects) are informed of the identity of the responsible person, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant.

2) Process the data for the specific and lawful purpose for which it collected that data and not further process the data in a manner incompatible with this purpose.

MyTown Media Ltd will ensure that the reason for which it collected the data originally is the only reason for which it processes that data, unless the individual is informed of any additional processing before it takes place.

3) Ensure that the data is adequate, relevant and not excessive in relation to the purpose for which it is processed.

MyTown Media Ltd will not seek to collect any personal data which is not strictly necessary for the purpose for which it was obtained.

4) Keep personal data accurate and, where necessary, up to date. 

MyTown Media Ltd will review and update all data on a regular basis. It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify the company, for example, a change in circumstances mean that the data needs to be updated.

5) Only keep personal data for as long as is necessary. 

MyTown Media Ltd undertakes not to retain personal data for longer than is necessary to ensure compliance with the legislation, and any other statutory requirements.

6) Process personal data in accordance with the rights of the data subject under the legislation. 

Individuals have various rights under the legislation including a right to:

• be told the nature of the information the MyTown Media holds and any parties to whom this may be disclosed.
• prevent processing likely to cause damage or distress.
• prevent processing for purposes of direct marketing.
• be informed about the mechanics of any automated decision-making process that will significantly affect them.
• not have significant decisions that will affect them taken solely by automated process.
• sue for compensation if they suffer damage by any contravention of the legislation.
• take action to rectify, block, erase or destroy inaccurate data.
• request that the Office of the Information Commissioner assess whether any provision of the Act has been contravened.

MyTown Media Ltd will only process personal data in accordance with individuals’ rights.

7)Put appropriate technical and organisational measures in place against unauthorised or unlawful processing of personal data, and against accidental loss or destruction of data. 

Members of staff are responsible for ensuring that any personal data which they hold is kept securely and not disclosed to any unauthorised third parties. MyTown Media Ltd will ensure that all personal data is accessible only to those who have a valid reason for using it.

8) Ensure that no personal data is transferred to a country or a territory outside the European Economic Area (EEA) unless that country or territory ensures adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. 

MyTown Media Ltd will not transfer data to such territories without the explicit consent of the individual.

Lawful, Fair and Transparent Processing

Under GDPR MyTown Media Ltd will obtain personal data by lawful and fair means and, where appropriate with the knowledge and consent of the individual concerned. Where a need exists to request and receive the consent of an individual prior to the collection, use or disclosure of their personal data, MyTown Media is committed to seeking such consent. 

Subject Access Rights (SARs)

Data subjects may make access request (SARs) at any time to find out more about their personal data which the company holds about them., what it is doing with that personal data, and why. 

Employees wishing to make a SAR should send their request to the Company’s Data Protection Officer, ads@mytownmedia.co.uk Responses to SARs shall normally be made within one month of receipt.

Data Protection Impact Assessments

MyTown Media Ltd shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.

Data Breach Notification

All personal data breaches must be reported immediately. Where any risk of breaches is identified the Information Commissioner’s Office will be informed.