ROMSEY MILL TRUST PRIVACY POLICY

 

1) Introduction

Romsey Mill (Romsey Mill Trust, UK registered charity number 1069905) is committed to safeguarding your personal information. Our Privacy Policy explains how we hold and use personal information and your rights and options in relation to it, so please take a moment to read it carefully.

This Policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

Romsey Mill Trust is registered as a Data Controller with the Information Commissioner’s Office (ref: Z714228X).

In this policy, "we", "us" and "our" refer to Romsey Mill Trust.  [ For more information about us, see Section 17.]

 

2) Credit

Parts of this document were created using a template from Docular: https://seqlegal.com/free-legal-documents/privacy-policy).

 

3) Changes to this Privacy Notice

This Privacy Notice may change from time to time so it's a good idea to come back and read through it again regularly. Where necessary, for example if there are significant changes, we may also notify you of the changes to this Privacy Policy by email where possible.

This Privacy Policy was last updated in March 2022.

 

4) Third Party websites

Our website contains hyperlinks to websites controlled by third parties. This Privacy Policy does not cover those websites and we are not responsible for their privacy practices or content - they will have their own privacy policies and we urge you to review them if you choose to follow those hyperlinks.

 

5) How is my personal information collected?

We collect personal information in the following ways:

  • Directly from you:

For example, by filling in forms on our websites (such as to sign up to our newsletter or register an account, or making a donation) or offline (including taking part in our events), or communicating with us by phone, email or letter or completing a survey or when you meet with us.

  • Indirectly, via third parties:

 

For example, we may receive information from analytics providers (such as Google), contact, financial and transaction information from technical, payment and delivery services.

Depending on your settings and the relevant policies and terms of service, you might give us permission to access information about you from social media such as Facebook and Twitter.

We also collect cookies – see Sections 12-15 for more information.

 

6) What personal information will Romsey Mill Trust collect about me?

In this section, we have set out the general categories of personal data that we process; and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

  • We may collect, process and store data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you.
  • We may collect, process and store information relating to transactions, including donations and purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include [your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider. Please see section 8 for details of our payment services providers.
  • We may collect, process and store information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
  • We may collect, process and store recruitment and HR records about our employees, volunteers and contractors to fulfil our record keeping obligations as employers and contractors.
  • We may process data about your use of our website ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website use. The source of the usage data is our analytics tracking system.

 

7) How does Romsey Mill keep your information safe?

We take the security of your personal information extremely seriously.

Data storage - We keep your information safe in these ways:

  • Personal data collected through forms on our website is channelled straight into our Customer Relationship Management system which has limited access for appropriate staff only.
  • Paper files are kept locked on all premises.
  • Some partner companies have access to our systems (for example our IT consultants) who comply with the Data Protection Act 2018, including the GDPR.

8) How and why will Romsey Mill use my personal information?

In this Section, we have set out the purposes for which we may process personal data and the legal bases of the processing.

  • Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of donations, and other payment-related documentation. The legal basis for this processing is our legitimate interests, namely contract between you and us and/or taking steps, at your request, to enter into such a contract (e.g., payments or donations)
  • Relationships and communications - We may process contact data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
  • Direct marketing - We may process contact data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
  • Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website, as well as researching and analysing other interactions with us. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
  • Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally including recruitment and HR records. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
  • Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
  • Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks].
  • Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources.

Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply

  • Your data will be made available to our website provider
  • The data that may be available to them include any of the data we collect as described in this privacy policy.
  • Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
  • They will store your data for a maximum of 7 years.
  • This processing does not affect your rights as detailed in this privacy policy.

9) Providing your personal data to others

  • We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
  • Your personal data held in our website database will be securely stored on the servers of our hosting services providers identified at HostAMG.com; or on our customer relationship management database, identified at www.donorfy.com
  • Financial transactions relating to our website are handled by our payment services providers, GoCardless and Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of [processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds]. You can find information about the payment services providers' privacy policies and practices at gocardless.com and www.stripe.com
  • In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

10) Retaining and deleting personal data

This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will hold your personal information only for as long as is necessary for the purpose(s) for which it is being held, and to satisfy any legal, accounting or reporting requirements. This length of time may vary depending on those purposes, and if you would like further information, please contact us (see details in Section 16, below).

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

It is Romsey Mill’s responsibility under our Data Protection Policy (last reviewed September 2020) to ensure all personal data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

 

11) Your rights

In this Section, we have listed the rights that you have under data protection law.

Your principal rights under data protection law are:

  • the right to access - you can ask for copies of your personal data;
  • the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
  • the right to erasure - you can ask us to erase your personal data;
  • the right to restrict processing - you can ask us to restrict the processing of your personal data;
  • the right to object to processing - you can object to the processing of your personal data;
  • the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
  • the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
  • the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

These rights are subject to certain limitations and exceptions.  You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

You can learn more about the rights of data subjects by visiting:

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You may exercise any of your rights in relation to your personal data, by written notice to us, using the contact details set out in Section 17 below.

 

12) About Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

You can find out more about cookies at www.allaboutcookies.org

13) The types of cookies that we use

Information supplied by cookies helps us build a picture of how people interact with the website, and how we can improve it.

Types of cookies we use include: 

  • Essential / strictly necessary cookies- some cookies are essential so you can move around the website(s) and use its features, including for example account login and saving incomplete webforms. These cookies don't gather information about you that could be used for marketing or remember where you've been on the internet.
  • Functionality cookies- these remember choices you make to improve your online experience, such as recently viewed pages, and enabling social media components, like Facebook and Twitter.
  • Performance cookies (for analytics)- these cookies collect anonymous information on the pages visited. They keep track of what pages and links are popular and are performing well so we can make improvements and measure the effectiveness of our marketing communications. As a charity, we need to make sure our charitable funds are spent in the most efficient and therefore effective way possible.
  • Third party cookies– we also use some tools on our pages from social networks, such as Twitter and Facebook, and third parties such as YouTube. They also set cookies on our website(s) on its behalf in order to deliver the services that they are providing. These cookies are placed on our website, and may collect information about your online behavior, such as your IP address, the website you arrived from, and what you may have previously purchased from us. If you would like more information about the cookies used by these suppliers, as well as information on how to opt-out, please see their individual privacy policies.

14) The cookies that we use

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy

 

Here is more information about the cookies we use and why:

  • _ga -  Google analytics tag
  • _gat_UA-5853814-1 - Google analytics tag
  • _gid - Google analytics tag
  • fr - Facebook due to social sharing plugin
  • has_js - Checking if user has javascript
  • webform-512[1527241654] - Webform submission time

 

15) Managing cookies

By clicking accept when you first visit the website you consent to our use of cookies as updated from time to time. In particular, you consented to cookies being stored on your computer and/or mobile device (unless rejected or disabled by your browser).

Most browsers allow you to refuse to accept cookies and to delete cookies.

The methods for doing so vary from browser to browser, and from version to version.

You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

 

16) Amendments

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy. If we plan to use previously collected personal data for a new purpose, we will update our privacy information and communicate the changes to individuals before starting any new processing.

17) Our details

This website is owned and operated by Romsey Mill Trust.

We are registered in England and Wales under charity registration number 1069905, and our registered office is at:

Romsey Mill Centre, Hemingford Road, Cambridge. CB1 3BZ

You can contact us:

  • by post, to the postal address given above;
  • using our website contact form;
  • by telephone, on 01223 213162; or
  • by email, using: [email protected]

Our Data Protection Officer's contact details are:

Diane Hicks, Operations and Resources Manager,

Romsey Mill Centre, Hemingford Road, Cambridge. CB1 3BZ

Telephone, on 01223 213162

Email: [email protected]

 

You are entitled to make a complaint at any time to the Information Commissioner’s Office, the UK regulator for data privacy: www.ico.org.uk/global/contact-us. We are always grateful for the opportunity to resolve your concerns before you feel the need to speak to the ICO.