Westbourne Community Trust holds data about our members and other individuals for a variety of business purposes in pursuance of our objects.
This policy sets out how we seek to protect personal data and ensure that our members and supporters understand the rules governing our use of personal data.
Controllers of information
The Data Protection Officer at The Westbourne Community Trust is the Chairman, who can be contacted using the contact details below.
The Registered Office: Willow Barn, Mill Lane, Westbourne, PO10 8RA
We aim to process information about you fairly and in a transparent manner and the intention of this document is to provide you with sufficient information for you to be able to understand what we are doing with your data. If you are unsure how we are handling information about you or you think we could improve our privacy information please let us know. If we are unable to address any complaint you may have to your satisfaction you may contact the Information Commisioner, either via the website https://ico.org.uk/make-a-complaint/ or by phone 0303 123 1113
Westbourne Community Trust understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.westbournecommunitytrust.org (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Our website address is: https://www.westbournecommunitytrust.org.
Definitions and Interpretation
In this Policy, we use the following terms and meanings:
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in the Cookies section below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended from time to time;
“Westbourne Community Trust Newsletter” means the Newsletter containing general news and information about Westbourne Community Trust and other related news that you have expressed an interest in hearing about by signing up to our mailing list;
“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site or other contact and communication with Us. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Westbourne Community Trust Limited, a society registered in England under the Co-operative and Community Benefit Societies Act 2014 as a Community Benefit Society under number 7872, whose registered address is at Willow Barn, Mill Lane, Westbourne, Emsworth, West Sussex. PO10 8RA.
Information About Us
Our Site is owned and operated by Us and you can find out more about us by visiting the Westbourne Community Trust website www.westbournecommunitytrust.org.
We are a social enterprise working make Westbourne a more sustainable community through a variety projects that have environmental, social and economic sustainability at their core.
What Does This Policy Cover?
As a data subject under data protection law, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right of access to the personal data We hold about you (see the How Can You Access Your Data section below);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in the Contacting Us section below);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in the How Do We Use Your Data section below but if you would like Us to delete it sooner, please contact Us using the details in the Contacting Us section);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided below and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (the “ICO”).
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What personal data we collect and why we collect it
- contact information such as name, address, email address and telephone numbers;
- bank account details;
- geographical area;
- your preferences;
- project proposal;
- images and/or plans of house designs, building plots etc relating to your project;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
How We will collect your data?
We will collect this personal data by the following means:
- Membership application forms
- Sign-up sheets at meetings
- Website form
How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see the How and Where Do We Store Your Data section below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our delivery of a service to you, for our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by signing up to our mailing list), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Governing the WCT, for example inviting you to Annual General Meetings.
- Informing you of opportunities to engage with our work, for example, giving input into a housing survey, feeding into the design for a housing development
- Research, analysis and survey purposes
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by using the “unsubscribe” option in our emails, or by writing to us to inform Us that you wish to unsubscribe), to include:
- the Westbourne Community Trust Newsletter, containing information about community-led housing opportunities, policies and other related news;
- Project-specific email updates;
- information on specific products, services, events and opportunities that are related to the activities of Westbourne Community Trust Limited;
- Supplying products and/or services to you (your personal details are required in order for Us to enter into a contract with you);
- Invoicing you and processing payments for our products and services;
- Replying to emails and/or phone calls from you;
- Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You will always have the opportunity to opt-out.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it. Please note that this will probably mean that you will no longer be able to receive the service for which the personal information was collected.
How Long Will We Keep your Data?
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for periods determined on the following bases:
- where you have opted in to our Westbourne Community Trust Newsletter mailing list and/or other project-specific mailing lists, We will retain your personal data for as long as We are operating these services;
- where you have opted in to receiving information about our products or services, We will retain your personal data for as long as We are offering those products and services;
- in order to determine whether We are still able to retain your personal data under the paragraph above, we will review your personal data every 2 years or as recommended by ICO guidelines.
How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in the section How Do We Use Your Data, and/or for as long as We have your permission to keep it.
Your data will be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
Steps We take to secure and protect your data include:
- All emails containing personal data are marked “confidential”;
- Personal data is transmitted over secure networks only using password-protected access; transmission over unsecured networks is not used in any circumstances;
- Paper records are stored in secured premises
- All electronic copies of personal data are stored securely using passwords for access;
- When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it is securely deleted and disposed of.
Do We Share Your Data?
We will only share your data with third parties in the following circumstances and where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the law.
- We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities and marketing.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you.
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
How Can You Control Your Data?
When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information
You may access Our Site without providing any data at all. However, to receive emails via our mailing lists and to allow us to supply specific products and services to you, you will be required to submit or allow for the collection of certain data.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held) and this is known as a “subject access request”. Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. We will respond to your subject access request within one month of receiving it from you.
Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in the Contacting Us section below.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a prompt or pop-up box requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Our Site uses website analytics services. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the Help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
The links below provide instructions on how to control Cookies in all mainstream browsers:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
- Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
- Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
- Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB
- Safari (iOS): https://support.apple.com/en-gb/HT201265
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
- Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)