Introduction

This privacy policy explains how London Resort Company Holdings Limited (referred to as LRCH, we, us, or our) collects and processes your personal data, in connection with LRCH’s application for a Development Consent Order to develop The London Resort theme park (the DCO) and in connection with LRCH’s other reporting and consultation obligations in relation to the proposed development of The London Resort.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

About London Resort Company Holdings Limited

London Resort Company Holdings Limited is the data controller responsible for your personal data. Our company number is 07625574 and our registered office is C/o Armila Capital, 20 Berkeley Square, London, W1J 6EQ.

If you have any questions about this privacy policy or how we use your personal data please contact our Data Privacy Officer using the following details:

Post: FREEPOST, London Resort Consultation

Email: info@londonresortcompany.co.uk

 

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Some personal data is known as ‘special category data’. This includes data about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, a person’s sex life or their sexual orientation, and biometric data. We would not normally expect to process special category data.

We may collect your personal data in various contexts before, during and after the DCO application process and when you use our website. These contexts are listed below:

 

1. Public Consultations


2. Land Referencing


3. Examination Process


4. Correspondence


5. Negotiations


6. Mailing list


7. Data we collect about you when you use our website

 

1          Public Consultations

1.1       We have carried out public consultations about our proposals for The London Resort, and it is possible that we may carry out further consultations in the future.

1.2       We will collect your data in the course of a consultation if you submit a consultation response, or if someone else submits a consultation response that includes information about you.

What data we collect

1.3       The data we collect through consultations is any data included in the responses. Usually this will include your name, address, and contact details as well as views on the questions asked in the consultation.

Purpose and legal basis for processing

1.4       We use consultation data to analyse the views of people who respond to the consultation, to develop changes to our proposals where appropriate, to inform our submissions to the Planning Inspectorate, and to inform our communications strategy. In some instances we will be under a statutory obligation to consult certain stakeholders and in that case we will use consultation data to help us fulfil those statutory obligations as well. Our consultation documents will make clear if the consultation is a statutory consultation.

1.5       The legal basis we rely on to process the consultation data is Article 6(1)(f) of the GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to further the development of The London Resort project by gathering and understanding the views of stakeholders.

1.6       In the case of a statutory consultation the legal basis we will rely on to process the consultation data is Article 6(1)(c) of the GDPR, which allows us to process personal data where this is necessary for the purposes of complying with our legal obligations.

1.7       We do not expect that consultation responses will include any special category data. If your response does include special category data the condition we rely on to process it under Article 9 of the GDPR is that by including it in your submission you have explicitly consented to us processing it for those purposes.

Who we share the data with

1.8       We share the consultation data with our professional advisors so that they can assist us in administering and analysing the consultation and provide advice to us concerning the consultation and the development of The London Resort.

1.9       We may also share the consultation data with the Planning Inspectorate so that the Planning Inspectorate can take it into account when considering our DCO application.

1.10     Our use of the data may include publishing analyses of the consultation responses.

 

 

2          Land Referencing

2.1       When preparing the DCO application and at various stages during and after the application process we will have to complete a process called land referencing. This means that we will have to gather information about people who have an interest in land that is affected by the development proposed in the DCO application.

2.2       We will collect land referencing information from publicly accessible sources, such as HM Land Registry records, and by circulating questionnaires. We may collect your data from your responses to a land referencing questionnaire or from a response provided by somebody else. For example, if you are a tenant your landlord’s questionnaire response might include information about your tenancy.

What data we collect

2.3       The personal data that we may collect for land referencing includes your name, address, and other contact details and information about the nature and value of your interests in the relevant land. For instance, we may collect data about whether you are a freeholder or leaseholder of the relevant land, and the duration of your interest in the land. We may also collect data about how your interest in the relevant land could be affected by the proposed development, for example if your access to the land might be interrupted.

Purpose and legal basis for processing

2.4       We will use the land referencing data to prepare the Book of Reference, and to keep it up-to-date. The Book of Reference is a document we will be required to submit to the Planning Inspectorate and keep up-to-date as part of the DCO application process. The Book of Reference will include information about people whose interests in land are likely to be affected by the proposed development.

2.5       We will also use the land referencing data to identify people who we are under a statutory obligation to consult and to notify of developments in the DCO application process. We will use the contact details in the land referencing data to issue consultation documents and notices to those people.

2.6       We will use the land referencing data to inform our proposals and designs for The London Resort development and for the purpose of our submissions to the Planning Inspectorate.

2.7       We will use the land referencing data for the purposes of negotiations with people whose interests in land are affected by the proposed development, and for the purpose of exercising compulsory acquisition powers or temporary possession powers as appropriate if the DCO is granted. We will also use it to respond to legal challenges and claims.

2.8       The legal basis we rely on to process the data is Article 6(1)(f) of the GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to promote the development of The London Resort.

2.9       In the case of land referencing data that the law requires us to collect and use, the legal basis we rely on is Article 6(1)(c), which allows us to process personal data where this is necessary for the purposes of complying with our legal obligations

Who we share the data with

2.10     We share the land referencing data with our professional advisors so that they can assist us in preparing our DCO application, the Book of Reference and in issuing consultation documents and notices, and so that they can provide advice to us concerning the development of The London Resort, the DCO application process, exercising powers under the DCO (if it is granted), and responding to legal challenges and claims.

2.11     We may also share the land referencing data with the Planning Inspectorate so that the Planning Inspectorate can take it into account when considering our DCO application.

2.12     Where we use the land referencing data to send notices about the DCO application, we will share it with contractors involved in printing and delivering those notices, so that they can produce the notices and deliver them to the correct recipients.

2.13     We are required to publish the Book of Reference.

 

 

3          Examination Process

3.1       The DCO application will be considered in a public process known as the examination. The examination is carried out by the Planning Inspectorate. Before and during the examination people are able to make submissions to the Planning Inspectorate either in person, at examination hearings or in writing. Submissions made in writing are published by the Planning Inspectorate on its website.

3.2       We collect submissions published on the Planning Inspectorate website. Those submissions may include what are known as ‘relevant representations’, ‘written representations’, ‘statements of common ground’, and answers to written questions posed by the Planning Inspectorate. We also take notes of submissions made at examination hearings.

What data we collect

3.3       We collect all of the personal data that is included in submissions published on the Planning Inspectorate website or made at examination hearings. The nature of this personal data will vary depending on the nature of the submission, but is likely to include names, information about interests in land and views about the proposed London Resort development and its impacts.

Purpose and legal basis for processing

3.4       We will use data collected for the examination in order to inform our own submissions to the Planning Inspectorate, to answer questions raised in those submissions or by the Planning Inspectorate, for the purpose of negotiating with stakeholders, for the purpose of responding to legal challenges or claims, and for the purpose of meeting our legal obligations in relation to the DCO application process.

3.5       The legal basis we rely on to process the examination data is Article 6(1)(f) of the GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to promote The London Resort development effectively during and after the examination.

3.6       In the case of examination data that the law requires us to collect and use the legal basis we rely on is Article 6(1)(c), which allows us to process personal data where this is necessary for the purposes of complying with our legal obligations.

3.7       We do not expect that the examination data will include special category data, but if it does the condition we rely on to process it under Article 9 of the GDPR is that by including the data in submissions that you knew would be published on the Planning Inspectorate website or at a public examination hearing you have manifestly made the data public.

Who we share the data with

3.8       We may share examination data with our professional advisors so that they can assist and advise us in connection with the above purposes.

 

 

4          Correspondence

4.1       We may engage in correspondence with you before, during, or after the DCO application process for example if you contact us to request copies of DCO documents.

What data we collect

4.2       We collect any personal data that you include in your correspondence with us. The nature of that data depends on what you choose to disclose to us, but will generally include contact details such as your name and address so that we can respond to you.

Purpose and legal basis for processing

4.3       We will use the data collected from your correspondence to answer your enquiries. For example, if you request copies of DCO documents that you are entitled to receive we will use your data to provide those documents to you. We may also use your data to respond to legal challenges or claims that you make.

4.4       The legal basis we rely on to process the consultation data is Article 6(1)(f) of the GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to promote The London Resort development effectively before, during and after the consultation.

4.5       We do not expect that you will provide us with special category data, but if you do the conditions we rely on to process it under Article 9 of the GDPR is that by providing it to us you have explicitly consented to us processing it for the purpose of responding you your enquiry, or that our processing is necessary for the establishment, exercise, or defence of legal claims.

Who we share the data with

4.6       We share the data you provide to us with our professional advisors so that they can assist and advise us in connection with your correspondence.

4.7       If we use contractors to respond to your requests we may share your data with those contractors so that they can provide the response. For example, if you request copies of documents we may use a courier service to deliver the documents to you and will share your delivery address details with them so that they can do so.

 

 

5          Negotiations

5.1       We may engage in negotiations with people affected by the proposed London Resort development, for instance to acquire land from them or to agree common approaches to aspects of the development that impact them.

What data we collect

5.2       If we are negotiating with you we will collect any personal data that you or your representatives provide to us in the course of those negotiations. This personal data is likely to include information about the nature and value of your interests in land, information about the financial effects on you of the proposed development, and information about your business (if the development affects your business).

Purpose and legal basis for processing

5.3       We will use the data for the purpose of conducting our negotiations with you. We may also use the information to respond to legal challenges or claims that you make, to inform any negotiations that we are conducting with other people, and to inform our submissions to the Planning Inspectorate.

5.4       The legal basis we rely on to process negotiation data is Article 6(1)(f) of the GDPR, which allows us to process personal data when this is necessary for the purposes of our legitimate interests, except where those interests are overridden by the interests of the individuals whose data we are using. Our legitimate interest is to further the development of The London Resort project.

Who we share the data with

5.5       We will share the information with our professional advisors so that they can assist and advise us in connection with the above purposes.

5.6       We will not share the information with the Planning Inspectorate or other interested parties if the information is explicitly provided on a confidential or ‘without prejudice’ basis. If the information is not explicitly provided on that basis we may share it with the Planning Inspectorate or other interested third parties.

 

 

6          Mailing list

6.1       We may publish a newsletter and issue other updates about the project, such as employment and supply chain opportunities, which you will receive if you have signed-up to our mailing list.

What data we collect

6.2       If you have signed-up to receive updates we will collect your first name, last name, email address and the date that you subscribe. If you have signed-up previously, we may have also collected your postal address, and details about your age group, if you chose to provide this information to us. If you later unsubscribe we will keep a note that you have unsubscribed and the date that you unsubscribed.

Purpose and legal basis for processing

6.3       We will use this data for the purpose of sending you updates if you subscribe to it and to ensure we do not send you updates if you unsubscribe.

6.4       When processing the data in this way we rely on Article 6(1)(a) of the GDPR, which allows us to process your personal data where you have given your consent for us to process it for a particular purpose. By subscribing for updates you consent to us processing your data for the purposes of sending updates to you. You can withdraw your consent at any time.

Who we share the data with

6.5       We share this data with the contractors who deliver our newsletter and other updates for us.

 

 

7          Data we collect about you when you use our website

7.1       We use Google Analytics to collect information about how people use this site. We do this to make sure the site is meeting users’ needs and to understand how we could do it better.

7.2       Google Analytics stores information about what pages you visit, how long you’re on the site, how you got here and what you click on. We do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are. We do not allow Google to use or share our analytics data.

7.3       To find out more, go to ‘how Google uses information from sites or apps that use our services’ at https://policies.google.com/technologies/partner-sites.

7.4       You can opt out of Google Analytics - https://tools.google.com/dlpage/gaoptout.

7.5       With the exception of Google Analytics, we do not use our website to collect data using cookies and similar technologies.

International transfers

 

We may sometimes transfer your personal data to countries outside the United Kingdom or the European Union, for example if we store it with a cloud storage provider based outside the UK or EU. Whenever we do this we will make sure that we put in place the safeguards required by data protection laws.

 

At the moment we do not transfer data outside the UK.

 

Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

All of our professional advisors and contractors are bound by legal obligations to keep the personal data confidential, so it remains confidential when we share it with them.

 

Data retention

 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

To determine the appropriate retention period for personal data, we consider: the amount, nature and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal data and whether we can achieve those purposes through other means; and the applicable legal, regulatory, tax, accounting or other requirements.

 

In most instances we will need to retain data until the DCO application has been decided and the challenge period has passed. If the DCO is granted we may need to keep information relevant to the implementation of the DCO during the construction period for the authorised works and for as long as there is any prospect of claims for compensation.

 

Third party links from this website

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave this website, we encourage you to read the privacy policy of every website you visit.

 

Changes to this policy

 

We keep our privacy policy under regular review. This version was last updated on 06/02/2020.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Complaints

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Your rights

 

You have the right to:

 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

 

If you want us to establish the data’s accuracy.

 

Where our use of the data is unlawful but you do not want us to erase it.

 

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

 

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.