The Head of Planning advised that minor changes were proposed to the Council’s adopted Statement of Community Involvement that were driven by GDPR requirements.  It was proposed that a public consultation took place early in the new year.

The proposed amendments would take place to paragraph 4.15, and existing links would be updated, mean that the council would accept representations using a standardised electronic form in place of email.  This would mean that email addresses, names and addresses would be separated from submissions from the outset significantly reducing the risk of GDPR issues.

To enable more lengthy representations the form would accept an attachment. Images and other such information would need to be included in this attachment. The Head of Planning confirmed that the Council’s Digital Services were aware of the need to provide a generous file size allowance for the attachment.  Clear warnings would be put in place to advise correspondents not to include personal data in the attachment, and whilst this would not completely eliminate the risk, or remove the need for manual checking it should significantly reduce risk and also make members of the public more mindful about personal data and take some responsibility for what is included in the attachment.

A Member was grateful that representations would still be accepted by letter for those who did not have internet or computer access. 

Some local authorities had decided to not publish comments completely as there was no statutory duty to do so, however the committee were in agreement with officers’ views that residents and members wanted to be aware of the local feeling around applications, therefore representations would continue to be published with personal data separated at an early stage.

The Head of Planning confirmed that a recent update in notification letters and on the website had provided additional background guidance around what residents can respond to and the planning reasons around it. The Council’s website had also been updated to provide this information at the first point of contact and improve the comments landing page and put it in a more prominent position on the website. A member suggested using QR codes in the future, this may well occur in the future, though this was not a matter for this SCI review.

It was confirmed that the response of statutory consultees would remain labelled and on the website.

There was a debate about the potential redaction of residents’ groups, with some residents keen to know that a group had submitted a representation but others having the potential to fear retribution meaning they would prefer to stay anonymous. 

The Head of Planning confirmed there would be a mechanism to keep personal details separate whilst still having the option to specify who the representation had been made on behalf of. This could be achieved by the attachment or the body or body of the text clearly stating it was on behalf of the group, whilst not including the authors name in the attachment or body of the text (that would only be included in the non-published fields).

Members were supportive of this proposal and the need to comply with GDPR and as a result the proposal was unanimously supported.

Resolved that –

Committee agreed that the proposed amendments to the Statement of Community Involvement could be published for public consultation for a period of 4 weeks between 3 January and 31 January 2024.