Stoke Gabriel Community Land Trust (SGCLT)
1. Who we are:
Stoke Gabriel Community Land Trust (SGCLT) are committed to protecting and respecting your privacy. In this Privacy Notice, whenever you see the words ‘we’, ‘us’, ‘our’ or ‘SGCLT,’ it refers to Stoke Gabriel CLT; a Community Benefit Society registered with the FCA under company number 7667.
2. This Privacy Notice explains:
What information we hold about you, the legal basis for the processing, the duration for which we keep your information and (if applicable) who your information will be shared with and where those recipients are based. It applies to you, if you’re a Member of SGCLT, have completed our initial questionnaire to register your need for affordable housing, are a volunteer, investor, visit our website, email, call or write to us.
3. Why we collect personal data:
We use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation (GDPR)/UK Data Protection Act and Privacy of Electronic Communication Regulation.
SGCLT collect and process information upon the legal basis of ‘Legitimate Interest’, as per GDPR. In accordance with data protection law, we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information in this way and are satisfied that we are justified in doing so:
· In certain circumstances, the processing is necessary for us to comply with our legal or regulatory obligations. In all other cases, the processing is necessary for achieving our legitimate interests of developing affordable housing for local people in Stoke Gabriel, South Devon, as documented under our Rules as a Community Benefit Society.
· Your personal data is collected and used to help us deliver our activities, help us raise funds, process your request for membership, profile local housing need, maintain accurate internal records for administrative purposes, respond to your enquiry for information, whether submitted through our website, email, over the telephone, in person or otherwise; or sending you marketing information about our products and services (including, where applicable, on the basis of the soft opt-in under the Privacy and Marketing Communications Regulations).
· You can unsubscribe from these communications at any time by following the instructions contained in this notice or by contacting us using the details set out below, and in accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information and are satisfied that we are justified in processing your information for this purposes; and we are otherwise processing your data on the basis of your consent. This will typically be the case where you have opted into receiving marketing communications from us.
4. Fairness and transparency.
Personal data provided to us will be used for the purpose or purposes outlined in a fair and transparent manner at the time of collection, in accordance with any preferences you express.
If asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may need to provide your personal data to them.
5. What Personal Data Do We Collect? - Information you give us:
We collect different types and amounts of personal data about you depending on the specific activities you engage in with us, such as registering your need for an affordable home, becoming a CLT member, volunteering or donating or subscribing to a community share offer.
You may have given us your personal data by filling in a questionnaire, share registration form on our website, by corresponding with us by phone, email or letter or by signing up in person at one of our open days.
Below are the main uses of your data which depend on the nature of our relationship with you and how you interact with our website and activities.
5.1 Personal Data held in respect of Members of SGCLT:
· When you apply to become a member of SGCLT and buy a minimum of one share, you will be asked for your name, email, postal address and telephone number.
· We use the personal data you provide as a member to maintain our membership register as required by law and our Rules, and to service your membership e.g. such as sending news updates via email (subject to your contact preferences) and notices of our Annual General Meetings.
· We will hold this information on our membership register for as long as you remain a member under the Rules of SGCLT. It will be deleted in the event of SGCLT ceasing to exist as a Community Benefit Society.
· As a member you will have invested a minimum of £1.00, we will hold the following additional details about you: your name, the amount of your investment and the date on which it was made.
If you tell us you wish to cease being a member of SGCLT, or on the termination of your membership for any other reason under our Rules, we will delete your contact details and all other information we hold about you, apart from your name, the date you became a member and the date you ceased to be a member.
5.2 Personal Data Provided by Applicants registering in housing need:
· In order to fulfil SGCLT’s objectives of building affordable homes, we collect and process data, including sensitive personal data, from applicants registering their need for an affordable home.
· People who are interested in registering their need for an affordable home are asked to complete a questionnaire, with personal details, including profession, household composition, related skills and housing need. If you have completed a questionnaire, we will hold your questionnaire for 6 years, from when it was completed. We will then destroy your questionnaire but may keep a record of your name and details.
· Data from the questionnaire is only disclosed on a “need to know” basis to those involved on the management board of SGCLT, all of whom already have duties of confidentiality as Board members of SGCLT.
· Discussions of issues relating to individual’s registration at Board meetings are anonymised as far as is possible, and the applicant’s consent is obtained before any aspect of their data is shared or discussed with external bodies such as the local authority.
· In order to receive financial support via grant funding applications, SGCLT will anonymise personal data to provide statistics to evidence local housing need.
5.3 Personal data held in respect of financial Donors:
· If you donate or make an investment, we’ll use any personal information you give us to record the nature and amount of your gift, claim gift aid where you’ve told us you’re eligible and thank you for your gift. If you interact or have a conversation with us, we’ll note anything relevant and store this securely on our systems.
· If you tell us you want to fundraise to support our cause, we’ll use the personal information you give us to record your plans and contact you to support your fundraising efforts.
· If you’ve told us that you’re planning to, or thinking about, leaving us a gift in your will, we’ll use the information you give us to keep a record of this – including the purpose of your gift, if you let us know this.
5.4 Major Donors/Investors data:
· Our regulatory rules require us to know the source of any funds we receive, and any conditions attached to them. We follow a due diligence process which involves researching the financial soundness, credibility, reputation and ethical principles of donors and investors who have made, or are about to make, a significant donation to or investment in SGCLT. As part of this process we’ll carry out research using publicly available information and professional resources. If this applies to you, we’ll give you a bespoke privacy notice with further details of how we look after your data.
5.5 Personal data if you volunteer for SGCLT:
· If you become a volunteer, then we may collect extra information about you (e.g. references, criminal records checks, details of emergency contacts, medical conditions etc.). This information will be retained for legal or contractual reasons for a period of 6 years after you stop volunteering with us, to protect us (including in the event of an insurance or legal claim) and for safeguarding purposes.
· If you volunteer with us, we will need to use your personal data to manage your volunteering, from the moment you enquire to the time you decide to stop volunteering with us. This could include: contacting you about a role, expense claims you’ve made, and to recognise your contribution.
· If you make any general complaint to or about us, we will keep full details of your name and your complaint for 6 years from the last communication we receive in respect of your complaint.
5.6 Personal Data Held About SGCLT Board Members:
· In order to comply with our Rules and statutory and regulatory obligations and responsibilities, we collect personal data, including ‘sensitive’ personal data, from our Board members.
· Such data can include, but isn’t limited to:
- Name, address and full date of birth
- Current employer and job title.
- Your current and intended involvement in other organisations and activities and any directorships or controlling interests in other businesses and organisations.
- Your skills and experience and contribution to the Board.
- Evidence of bank account for expenses payments and records of expenses claims.
- Your opinions and attitudes about SGCLT, activities and interests, and your experiences of SGCLT.
- Information relating to health, racial or ethnic origin, and criminal conviction.
· These data will be held by us for the period of your membership of the Board and for 6 years after your resignation or removal from the Board. A record of your name and period of Board membership will be kept indefinitely.
5.7 Use of Photographs
· By attending our events, you are assumed to be consenting to us using your image in any group or crowd photos or videos taken at those events. We may use the photos or videos on our website or in printed or electronic newsletters, reports or publicity materials.
· Please let us know at the event if you do not wish to be included in any photos or videos. We will not use photos or videos that feature you by yourself, nor will we name you in any captions, unless you have given us general or specific written consent to do so.
5.8 Children’s Personal Data
· We sometimes take photographs of children for publicity purposes. We will always give children, their parents and guardians the opportunity to opt out of having their photographs taken and / or published and we will not publish pictures of those under 13 without the consent of the parent, guardian, school or youth organisation.
· If you have registered your need for an affordable home and completed the SGCLT questionnaire we will hold a record of the children in your household (their names, gender and ages).
· These details will not be copied to any other of our databases or shared with our external advisers except for a specific purpose and with your prior written or e-mailed consent.
· We won’t send emails, letters or make calls to people under the age of 13.
6. What Personal data do we collect? - Information we collect about you.
When you visit our website we will automatically collect the following information:
· Technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform; and
· Information about your visit, including the full Uniform Resource Locators (URL), through and from our site (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device's hard drive.
We use the following cookies:
· Strictly necessary cookies.
These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
· Analytical/performance cookies.
These allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
· Functionality cookies.
These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and organisation and remember your preferences (for example, your choice of language or region).
· Targeting cookies.
These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site more relevant to your interests. We may also share this information with third parties for this purpose. Except for essential cookies, all cookies will expire after 30 [thirty days].
· Third party cookies
· Blocking cookies.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that if you use your browser settings to block all cookies (including essential cookies) then you may not be able to access all or parts of our site.
7. What Personal data do we collect? - Information we receive from other sources.
We do not currently collect data about you from any other sources.
8. Duration and further processing.
We only keep your information for so long as it is reasonably necessary.
Generally speaking, we keep personal data detailed in sections 5.0, 6.0 and 7.0 for 6 years from the collection of this data.
9. Who is your information shared with?
We’ll never sell your personal data and will only share it with our external advisers, accountant, solicitor and trusted organisations we work with when it’s necessary and when the privacy and security of your data is assured, or when we are required by law to share it with our regulatory body (currently the FCA), the police or other official bodies.
To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes, then we will let you know.
10. How we safeguard Financial and Sensitive Data
Basic membership information from community share offer participants is kept on our database, accessible only to members of our board of Directors and co-opted Directors and password protected.
SGCLT questionnaires of housing need are kept securely in a locked filing cabinet accessible only by SGCLT Directors.
11. How can I change my contact preferences?
We’d love to stay in touch, but we don’t want to out-stay our welcome. If you wish to be removed from our email mailing list, please get in touch by notifying us at firstname.lastname@example.org
We’ll always act upon your choice of how you want to receive communications (for example, by email, post or phone). However, there are some communications that we need to send. These are essential to fulfil our promises to you as a member, volunteer, investor or applicant registered in need of affordable housing. Examples are: confirmation of your membership applications, membership-related mailings such as notice of our Annual General Meetings.
12. Your Rights and access to your information.
You have the following rights to have information; deleted, have inaccuracies corrected, the right to access information about you - free of charge - within 1 month, the right not to receive any unsolicited marketing, the right to determine how information about you is processed and the right to complain if you are unhappy about any of the above by contacting the Information Commissioners Office here: https://ico.org.uk/concerns/, although we trust that you will try to discuss this with us in the first instance.
13. Our assigned representative.
For the purpose of General Data Protection Regulation 2018, is Marie Howard, who can be contacted via email@example.com.
Our registered address is: The Secretary, Old Mill Hill Cottage, Stoke Gabriel, Totnes, TQ9 6RD.
14. Changes to our Privacy Notice.
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this policy.