South West Lakes Trust Privacy Notice

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Introduction

This privacy notice tells you what to expect us to do with your personal information.

Contact details

Email

[email protected]

What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery:

  • Names and contact details
  • Addresses
  • Date of birth
  • Purchase or account history
  • Payment details (including card or bank information for transfers and direct debits)
  • Credit reference information
  • Health information (including dietary requirements, allergies and health conditions)
  • Health and safety information
  • Account information
  • Information relating to loyalty programmes
  • Website user information (including user journeys and cookie tracking)
  • Photographs or video recordings
  • Identification documents
  • Information relating to compliments or complaints
  • Information relating to sponsorship

We collect or use the following information for the operation of customer accounts and guarantees:

  • Names and contact details
  • Addresses
  • Payment details (including card or bank information for transfers and direct debits)
  • Purchase history
  • Account information, including registration details
  • Information used for security purposes
  • Marketing preferences

We also collect or use the following special category information for the operation of customer accounts and guarantees. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following information for service updates or marketing purposes:

  • Names and contact details
  • Addresses
  • Marketing preferences
  • Location data
  • Recorded images, such as photos or videos
  • Purchase or viewing history
  • Website and app user journey information
  • Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

  • Name
  • Contact information
  • Criminal offence data (including Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
  • Health and safety information

We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details
  • Address
  • Video recordings of public areas
  • Audio recordings of public areas
  • Video recordings of private or staff only areas
  • Witness statements and contact details
  • Relevant information from previous investigations
  • Customer or client accounts and records
  • Financial transaction information
  • Information relating to health and safety
  • Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for legal requirements are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Where we get personal information from

  • Directly from you
  • CCTV footage or other recordings
  • Schools, colleges, universities or other education organisations
  • Credit reference agencies

How long we keep information

The Trust will review all personal data held on its databases annually to ensure it should be retained. The categories of data listed below have to be retained under the following specific criteria:

  • Personal data of donors associated with finance data must be retained for at least six years.
  • Personal data associated with records of transactions/purchases needs to be kept for at least six years.
  • Personal data of employees needs to be retained for six years with reference to payroll and ten years with reference to pension information.
  • Personal data of volunteers and trustees needs to be retained for at least six years if it is associated with financial transactions.

Only CCTV and/or BWC footage relevant to the safety and security of staff, visitors and property is retained. Standard retention:

  • CCTV: 30 days
  • BWV: 30 days

Footage required for investigations or legal proceedings may be retained longer, subject to review.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Data processors

IRIS Payroll Solutions UK

This data processor does the following activities for us: They process our payroll information

CF Systems LTD UK

This data processor does the following activities for us: They provide IT support services

Checkfront Bookings, INC

This data processor does the following activities for us: They provide our online booking services

Breathe HR, UK

This data processor does the following activities for us: They provide our HR software.

Others we share personal information with

  • Insurance companies
  • Professional or legal advisors
  • Financial or fraud investigation authorities
  • External auditors or inspectors
  • Emergency services

Sharing information outside the UK

Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Checkfront Bookings, INC

Category of recipient: Online Booking Services

Country the personal information is sent to: Hosting Facilities in Canada and Europe

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:          

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

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