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Guildford Borough Council

Privacy Notice

Guildford Borough Council online consultation system “Inovem”


The Council uses “Inovem”, a web-based consultation system, to manage planning policy consultations (see the consultation portal at This privacy notice sets out information regarding the data that is held within Inovem and how it is processed in order to demonstrate compliance with the General Data Protection Regulation 2018 (GDPR).

What personal data does the Council collect?

Profile data

Inovem includes a stakeholder database consisting of profiles of people who have made representations (comments) during planning policy consultations and/or have asked to be kept informed about planning policy consultations, and people or bodies that the Council has a statutory obligation to contact during planning policy consultations. These people are referred to hereafter as “stakeholders”.

Each profile includes the following data fields:

As a minimum, the Council requires stakeholders to provide their name and either an email address or a postal address. Online users must provide an email address and a password.

Representation data

Inovem includes a database of representations made by stakeholders who have responded to planning policy consultations. Representations are linked to the profile of the relevant stakeholder. Administrative information about the representation, such as the date it was submitted, is also collected.

Why does the Council consult and why does it collect personal data?

The GDPR allows the collection of personal data where “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority”.

Where the Council consults on a planning policy proposal because it is required to do so by legislation, it is exercising its official authority. The following table sets out the relevant legislation:

Document / proposal


Regulation / section

Local Plan
The Town and Country Planning (Local Planning) (England) Regulations 2012
18 &19
Supplementary Planning Document
The Town and Country Planning (Local Planning) (England) Regulations 2012
12 & 13
Neighbourhood Area
The Neighbourhood Planning (General) Regulations 2012
Neighbourhood Plan
The Neighbourhood Planning (General) Regulations 2012
Neighbourhood Forum
The Neighbourhood Planning (General) Regulations 2012
Habitats Regulations Assessment
The Conservation of Habitats and Species Regulations 2017
Strategic Environmental Assessment
The Environmental Assessment of Plans and Programmes Regulations 2004

The Council may also elect to consult on planning policy proposals where there is no legal requirement to do so because there is a general expectation of consultation from the public or other groups, or because it is important to gather information about proposals. These consultations are held in the public interest.

The Council or others (notably local plan inspectors and neighbourhood plan examiners) may need to follow up with stakeholders where their representation includes information that needs to be explored further. Therefore, the Council requires a name and either an email address or a postal address to be submitted with a representation as this is the minimum amount of data that is needed to contact a stakeholder. Other profile data is collected in order to make planning policy consultations more effective, in the public interest.

How will data be used?

Representation data

Representation data is collected for the purpose of receiving feedback on planning policy proposals and meeting our obligation to involve others in the development of those proposals.

Profile data

The data held in stakeholder profiles is used to contact stakeholders to ask them about their representations and/or, if they have asked us to do so, keep them informed about planning policy consultations.

Profile data may be used to analyse the response to consultations e.g. by mapping out the spatial patterns of respondents or providing statistics about the types of stakeholder who have responded. This information can help inform planning policy proposals and ensure that consultations are inclusive.

Is any data published?

Representations are typically published after a consultation closes. The name of the stakeholder who made the representation and/or the organisation they are representing (if relevant) may also be published where this is deemed necessary for transparency. The Council does not publish any other information held in stakeholder profiles (e.g. email or postal addresses). The Council advises stakeholders in advance if it intends to publish the names of respondents.

How long will data be held?

Where data has been collected because the stakeholder has responded to a planning policy consultation, profile and representation data will typically be held until the process for the proposal to which it relates is completed. This is the minimum period of time The Council needs to hold data in order to fulfil its legal duties in relation to the development of planning policy proposals.

Where profile data has been collected because a stakeholder has asked to be notified about planning policy consultations, it will be held until the stakeholder  advises they no longer wish to receive notifications (whether explicitly or implied).

Data may be archived in the public interest but will be anonymised wherever possible before doing so.

When data is no longer needed, it is destroyed securely. This is undertaken by Inovem’s support team at the Council’s request.

Rights and responsibilities

How is data kept secure?

The Council takes data accuracy and security seriously. With the exception of data that has been published, profile and representation data are held securely within Inovem and protected by a password system. Inovem has ISO27001 UKAS and Cyber Essentials+ certifications, and the company’s infrastructure is checked to CESG check standards annually.

Council staff are granted access to the database only where there is a valid business reason. Staff members who have been granted access operate under an internal process for the handling of the data and are given appropriate training at the outset.

Data may be shared with people who have a planning and development reason to see it. This includes:

When data is shared, anonymised and bulk data is used wherever possible.

Personal data is never passed to third parties for purposes unrelated to planning and development.

How is data kept accurate and up-to-date?

The Council will contact stakeholders at appropriate intervals to ensure that the data contained within stakeholder profiles remains accurate.

Stakeholders can access and modify their own personal information by logging in and visiting the “My Profile” page. Online stakeholders are always sent an email confirming their response to consultations to show that their response has been submitted correctly. Online stakeholders can also see their own responses online by using the “My Responses” link on each consultation home page. Stakeholders who do not/cannot log on to the system directly can request to see all the data about them by contacting the planning policy team (see “Further Information” for contact details).

Stakeholders can amend the data held in their profile in the following ways:

The data held in representations cannot be amended once the consultation to which it relates has closed except in exceptional circumstances.

Can stakeholders ask to have their data deleted?

Representation data cannot be deleted until the process for the planning policy proposal to which it relates has been completed. This is because the data is required in order to meet the duty placed upon the Council to take representations into account when developing planning policy proposals.

Additionally, stakeholder profiles cannot be deleted where their representation data is currently being used to develop planning policy proposals because the Council or others may need to contact stakeholders to follow up on the information provided in their representations.

However, representations and profiles will be deleted once they are no longer needed in accordance with the procedure set out in this notice.

Where a stakeholder does not have any representations that are still being used, but the profile remains because they have asked to be notified about planning policy consultations, and the stakeholder advises the Council they no longer wish to be notified, the stakeholder profile will be deleted.

Further information

Details about your rights and the Council’s commitments and responsibilities are available on our website at

You can contact the planning policy team at Planning Policy, Guildford Borough Council, Millmead, Guildford, GU2 4BB, email:

If you believe we are not processing your data lawfully you can contact the Information Rights Officer, Guildford Borough Council, Millmead, Guildford, GU2 4BB, email:

Alternatively, you can complain to the Information Commissioner’s Office at