Full Privacy Notice
Welcome to the privacy notice of the Box Moor Trust (referred to as “the Trust“, “we”, “us” or “our” in this notice)
The Trust respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data through your relationship with the Trust and when you visit our website (regardless of where you visit it from), and will tell you about your privacy rights and how the law protects you.
This privacy notice is issued in compliance with the EU General Data Protection Regulation (GDPR) 2016 and the Data Protection Act 2018.
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how the Trust collects and processes your personal data through your relationship with the Trust and use of its website. This includes any data that you may provide to the Trust by being an employee, volunteer, Friend, visitor, or their partner or by purchasing something from the Trust’s online shop. This data is collected to help us to administer the Trust and organise its activities.
The Trust’s website is not intended for children and we do not knowingly collect data relating to children via our website.
It is important that you read this privacy notice together with any other notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
The Box Moor Trust is the controller and responsible for your personal data. We have appointed a Data Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Manager using the details set out below.
Full name of organisation: The Box Moor Trust
Name and title of Data Manager: Jessica Box, Senior Administration Officer
Email address: [email protected]
Postal address: The Box Moor Trust Centre, London Road, Hemel Hempstead, HP1 2RE
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this privacy notice and your duty to inform us of changes
This version was last updated in December 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Trust’s website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, title.
Contact Data includes address, email address and telephone number.
Financial Data includes bank account and payment card details.
Transaction Data includes details about your transactions in our online shop.
Technical Data includes internet protocol (IP) address and the login data you use to access this website.
Profile Data includes your name and email address and purchases or orders made by you.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you through the Trust’s website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Purchase something from the shop;
- Join as a Friend of the Box Moor Trust;
- Request information to be sent to you;
- Enter a competition;
- Complete a form;
- Give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers; and
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
4. How we use your personal data
We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into, or have entered into, with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing [email protected].
Purposes for which we will use your personal data
We have a legitimate interest in keeping and processing the data to maintain a database to provide information requested to operate and administer the Trust and its activities. The processing is undertaken by staff of the Trust and other selected persons, and used for the purposes of administering the Trust. Your data will not be shared with any other party. We have set out below, in a table format, a description of some of the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identify|
|Performance of a contract with you|
|To process and deliver your order||(a) Identity|
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (e.g. to recover debts due to us)
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our organisation and our website||(a) Identity|
|(a) Necessary for our legitimate interests (for running our organisation, provision of administration and IT services, network security, or to prevent fraud)|
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to invite participation in surveys)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time ([email protected]). Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transaction.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Except where there is a legal requirement for us to provide information, we will refer any enquiry asking for your personal information to you should it be requested.
- External third parties such as service providers who provide IT and system administration services and professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities who require reporting of processing activities in certain circumstances.
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Subject to Your legal rights (see paragraph 9 below), we will keep data for as long as we have a relationship with you and no longer than 2 years thereafter unless there is a specific reason to retain it. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data: see Request erasure below for further information. We will remove your data unless there is a legal reason to keep that information.
Removal of your data may result in your relationship with the Trust being terminated if we are no longer able to administer the relationship properly. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at [email protected] or by post at the above address. We will correct any errors in data that you alert us to.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Legitimate Interest means our interest in managing the Trust to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.