GDPR Privacy Notice For the Wash Road Allotments Association
Personal Information – Privacy Notice
Wash Road Allotments Association holds and uses personal data about its members. In the context of data protection legislation it is a ‘data controller’.
This privacy notice lets you know what happens to any personal data you give to us or we may collect from you. Your trust is important to us and we are committed to safeguarding your personal data.
In accordance with the General Data Protection Regulation (GDPR) which was incorporated into UK law on 25th May 2018 we are providing you with clarity on what data we have; how we use it; why we need it and who has access to it.
We are providing you with this privacy notice because:
§ you are an existing member of Wash Road Allotments Association and we are required to inform you of your rights relating to the personal information we hold, or
§ you are making an application for an allotment and if successful will become a member of Wash Road Allotments Association.
Compliance
Wash Road Allotments Association is categorised as a non-profit organisation and, as we process only information relevant to managing the allotment site, there is no requirement for us to register with the Information Commissioner’s Office.
The lawful basis under the GDPR which we rely on to process your personal data is known as ‘legitimate interests’.
Legitimate interests applies since, as an allotment organisation, we process personal data in order to manage our site and tenancies. This is information that we require in order to undertake our role and meet the conditions of our lease with the Brentwood Borough Council.
We do not collect special category or sensitive data as specified by the GDPR. Therefore we are not obliged to seek consent to hold data from our members or applicants for allotment plots.
By way of this notice we are communicating our privacy policy to both members and applicants. This privacy notice is posted on our website. New applicants will be directed to this privacy notice. New tenants will be reminded of the privacy notice at the time of signing tenancy agreements.
Data protection principles
We comply with data protection law and principles, which means that your data will be:
§ used lawfully, fairly and in a transparent way
§ collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
§ relevant to the purposes we have told you about and limited only to those purposes
§ accurate and kept up to date
§ kept only as long as necessary for the purposes we have told you about
§ kept securely
The information we hold about you
In connection with your membership of Wash Road Allotments Association we collect, store and use the following categories of personal information about you:
§ your title and full name
§ your postal address
§ your email address
§ your home and/or mobile telephone numbers
§ if claiming seniors discount your date of birth
§ your rental and associated charges for your plot
How is your personal information collected?
We collect personal information about you from the following sources:
§ your application form when applying for an allotment plot
§ a formal application for membership of Wash Road Allotments Association
§ completed and signed tenancy agreements
How we will use personal information
We collect information in order to manage our site and tenancies. We only use your personal information for the operation of your membership and this enables us to:
§ send annual invoices for rental and other related charges
§ communicate with you by email, telephone and post
Keeping your personal information up to date
If any of your personal information should change, such as your contact details or address, you should inform us as soon as possible so that we can keep our records up to date.
How we use special category or sensitive data as specified by the GDPR
We do not request or hold data or information within this category.
Data sharing
The names and addresses of all plot holders may be submitted to the Asset Manager of Brentwood Borough Council if such information is requested. Other than this one exception the Association will not sell or share data with any other party without the written consent of the member(s) concerned.
Data security
Data are only accessible to those who need to use it to undertake our organisation’s activities.
We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Members’ information is held securely in an electronic database. Appropriate tools such as firewalls are in place and antivirus software is kept up to date.
Where we use third parties, including marketing automation platforms, for bulk email or postal communications we ensure that such suppliers are, as appropriate, fully certified and compliant with applicable privacy shield frameworks.
Information held on paper (hard copies) is kept safely and to a minimum with access limited to those who need to use it.
We have in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office of a suspected breach where we are legally required to do so.
Data retention
We only hold data as long as we reasonably need it. We will retain your personal information for as long as you are a member and tenant of Wash Road Allotments Association and then for a short retention period.
For applicants who withdraw from our waiting list your information will be deleted immediately from our records.
Historical records and other non essential and time expired information will be routinely deleted and destroyed.
Rights of access, correction, erasure and restriction
The GDPR specifies your rights in connection with personal information. Under certain circumstances, by law you have the right to:
§ Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
§ Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
§ Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
§ Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
§ Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact: The Chairman by e-mail on info@washroadallotments.com.
Why is all of this necessary?
Wash Road Allotments Association is legally obliged to comply with current data protection obligations both in relation to the GDPR and the terms of the society’s lease from the Brentwood Borough Council. It is required to provide you with details on the kind of information that it may be holding about you and how it is processed.
Data protection issues
If you have any questions about this privacy notice or how we handle your personal information, please contact Wash Road Allotments Association, 1 Prower Close, Billericay CM11 2BU. 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.