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Privacy Policy

 

Updated March 2019

 

West Itchen Community Trust Ltd is committed to protecting the privacy and security of your information under the General Data Protection Regulation (GDPR) which came into force on 25 May 2018. We will use your personal data legitimately and responsibly in line with applicable privacy laws and regulations.

 

In this Privacy Statement, we describe who we are, how and for which purposes we process your personal data within West Itchen Community Trust Ltd, how you can exercise your privacy rights, and all other information that may be relevant to you. If you have any questions about our use of your personal data after reading this Privacy Statement, you can contact us through the contact details provided at the end of this document.

 

We are continually developing and improving at West Itchen Community Trust Ltd. If this brings about any changes in the way we process personal data, this will be reflected in this Privacy Statement. We therefore recommend that you regularly take notice of the Privacy Statement for any modifications.

 

Who we are

 

West Itchen Community Trust Ltd is the data controller for West Itchen Community Trust Ltd activities. Our contact details are: West Itchen Community Trust Ltd, Ropewalk Centre, 53 Derby Rd, Southampton SO14 0DJ. If you want to contact West Itchen Community Trust Ltd, please use the contact details provided at the bottom of this Privacy Statement.

 

For which purposes do we collect your personal data?

 

West Itchen Community Trust Ltd processes your personal data for the following purposes:

  • Membership – We process your personal data to register your membership and communicate with you under the terms of our membership agreement.
  • Fulfilment of a contract – We process your personal data to prepare, receive and carry out the service, licence or room hire agreement(s) as outlined in the Terms and Conditions of your service agreement.
  • Grants applications & funding – We process your personal data as part of the application and assessment of our Small Grants Programme.
  • Office activities – We process your personal data for administrative and financial business activities, such as reporting and the managing and processing of invoices and collections.
  • Communication, marketing purposes – We process your personal data for the purposes of community networking, customer service and support, to manage our relationship with you, to carry out marketing activities and/or to provide and share information about our events or those in our area of operation.
  • Legal purposes – We process your personal data for identification purposes, to counter fraud, to perform audits, to initiate legal action, to secure safety within the company and to comply with legal obligations.

 

What personal information do we collect about you:

 

We collect several categories of personal data:

  • Contact details (name, address, place of residence, e-mail, telephone number, fax number, etc.)
  • Company details (address, Chamber of Commerce number, VAT number, references etc.)
  • Membership details (Member ID, affiliation with other groups etc.);
  • Marketing & communication details (whether you have opted out for direct marketing, creation of mailing lists, social media details, geographic details, promotional offerings, etc.)
  • Bank details: for the processing of payments, grants and purchase of goods and services
  • Participation details (whether you participate in events, groups, activities)
  • Sensitive Data: We may collect sensitive personal data on diversity – including age, disability, sexual orientation, race and gender during recruitment, in the follow ups to events, or when you use one of our services. This data anonymised and analysed so we can plan to reach as diverse an audience as possible in order to achieve our charitable objectives and/or fulfil our Equal Opportunities Policy and as such, will not be stored with your personal data.
  • Web details (cookies, etc.)

 

How and why do we use your personal data?

 

  • We use your personal data in order to achieve our aims as a charity – our key charitable objects are to work as an independent Trust to continue with the regeneration in Southampton, to champion inner-city needs and to assist the aspirations of the people living and working there.
  • We use your personal data to inform you of ways in which you can get involved, and ways in which you can support us.
  • We use your personal data to process payments to us.
  • We use anonymised personal data to measure the impact of content on our website, mailings, and service, to learn how we can more effectively communicate digitally.
  • We use anonymised personal data to detect trends in the demographics and interests of those who support us.
  • If you have applied for a paid or volunteer role, we will use the information provided to us to assess your suitability for the role. The data privacy law allows this as part of our legitimate interest in maintaining our operations to work towards achieving our charitable objectives.
  • You are free to opt out of communications with us at any time – please email info@wict.co.uk

 

How long do we keep your information?

  • If you are an occupier or supplier, we will keep your information up to 7 years after the license or contact ends.
  • If you are on our mailing list, we will keep your information for 12 months after your last engagement with one of our mailings.
  • If you have emailed us, we will keep your information for 3 years after your last engagement with a member of our staff.
  • If you have applied for a paid or volunteer role, we will keep your information for a maximum of 12 months.
  • If you use one of our community services, we will keep your information for 2 years after you last engaged with the service.
  • If you are a volunteer, we will keep your information for up to 7 years after your placement ends.
  • At the end of the period, your data will be deleted or anonymised.
  • Any paper records will be securely shredded and disposed of.
  • There are instances where certain elements of your personal data are stored for a longer period of time due to certain legal obligations set out by public institutions. We may also store elements of your personal data for our own legitimate interest, such as detecting fraud, handling potential disputes, or facilitating our contractual arrangements with third parties.

 

How do we store your data?

  • We store your data in a password protected, in-house server which only staff have access to.
  • We store any sensitive data on paper securely in our locked office.
  • We store all email communications on Microsoft Office 365, protected by their own robust security.

 

Security

 

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.

 

Who do we share your personal data with?

We only share your data when necessary to perform the task you expect us to perform. We will only share your data with trusted third parties who take data protection seriously. Depending on why you have provided your data to us, we may share this with:

  • our bank (Handelsbanken)
  • our financial auditors (Xebra Accounting Ltd)
  • a delivery service (e.g. Royal Mail or other courier service)
  • our IT company (Peach Technologies Ltd)Authorities: We may provide your personal data to supervisory authorities such as Tax and Customs Administration, the police and other statutory bodies. We provide your personal data: To comply with a statutory obligation or court order; or If this is necessary to prevent, trace or prosecute criminal acts; or If this is necessary to enforce our policies, or to protect the rights and freedoms of others.
  • Event venues
  • Web analytics software (Google Analytics)
  • Occasionally we will ask for your consent to share your contact details with someone else who engages with our charity. For example, if you are interested in collaborating in your local area, we may ask if we can share your contact details with other activists in your local area.

 

We never share data with third parties for their own purposes.

 

 

On which legal grounds do we base the processing of your personal data?

 

To be lawful, each processing of personal data has to be based on a so called ‘legal ground’ as listed in the EU General Data Protection Regulation (GDPR). We process personal data associated with West Itchen Community Trust Ltd based on four legal grounds;

(1) for the performance of a (service) contract with you; or (3) for compliance with a legal obligation; or (4) for legitimate interests pursued by us; or (4) your consent.

 

Performance of a contract

We use your personal data for processing necessary for performance of the service contract with you. Without these data, we would not be able to fulfil our side of the contract. The processing of orders and service requests falls under this legal ground.

 

Legal obligation

We are legally obliged to process your personal data in order to comply with fiscal and other legal obligations.

 

Legitimate interest

We use your personal data for our legitimate interests.

  • to be able to maintain a lasting relationship with you as a member/customer and to offer you products and services (e.g. direct marketing).
  • to be able to detect fraud and security incidents on our website.
  • to defend ourselves in legal proceedings.
  • to improve the effectiveness of our service through statistical analysisConsentNote that you can always withdraw your given consent. Contact us on 023 8038 8580 or at info@wict.co.uk
  • In those cases where the previous three legal grounds do not apply, we process data with your unambiguous consent.
  • We may use personal data in a personal, pseudonymous form to understand how we can develop and improve the service, as well as for reporting purposes, general statistical and analytical purposes. When circumstances make this necessary we may process personal data for fraud investigation or to fulfil legal obligations. Processing personal data for these purposes serves a legitimate business interest of ours.

 

How we use cookies?

 

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

 

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

 

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

 

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

 

To block cookies from being used on this website, please change your cookie settings.

 

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

 

How can you exercise your privacy rights (data subject rights)?

 

At any desired moment, you can request to access, rectify or erase your personal data or you can object to direct marketing and profiling. In addition to this, you may also have the right of restriction of processing concerning your personal data, the right to object to processing as well as the right to data portability. These rights are known as your ‘data subject rights’.

 

To invoke your data subject rights, please contact us by using the contact details at the bottom of this Privacy Statement.   Please keep in mind that we may ask for additional information to verify your identity.

 

If you no longer want to receive direct marketing communication, please contact us by using the contact details at the bottom of this Privacy Statement.

 

Can you withdraw your consent?

Once given, you may always withdraw your consent. Please keep in mind that withdrawal does not have retrospective effect.

If you want to withdraw your consent, please contact us by using the contact details at the bottom of this Privacy Statement.

 

Can you lodge a complaint?

You can lodge a complaint with us via the contact details at the bottom of this Privacy Statement. Furthermore, you can lodge a complaint via the UK Data Protection Authority ‘Information Commissioner’s Office (ICO)’, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, UK.

 

How can I contact West Itchen Community Trust Ltd?

If you have any questions about the way we process your personal data that are not answered by this privacy statement, please contact:

 

Data Protection Officer

West Itchen Community Trust

53 Derby Road

Southampton

SO14 0DJ

info@wict.co.uk

 

If you believe that any personal information we are holding is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

 

This Privacy Statement was reviewed and the last modifications to this Privacy Statement were made on 1 April 2019. 

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