Data Protection Notice
Chapelton Community Interest Company (“CCIC”) is committed to processing data in accordance with its responsibilities under the Data Protection Act 2018 (“DPA”). This notice explains what information we collect, when we collect it and, how we use this. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information. This policy applies to all personal data processed by CCIC
Who are we?
Chapelton Community Interest Company (CCIC), The Hut, Liddell Park, Chapelton, AB39 8BA (“we”) are notified as a data controller with the Information Commissioner’s Office (ICO) under registration number A8469323 and we are the data controller of any personal data that you or a third party provide to us.
Any questions relating to this notice and our privacy practices should be sent to us at the above address or by email to CCIC_admin@chapeltonlife.co.uk.
Data Protection Principles
DPA requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the DPA in order to safeguard the rights and freedoms of individuals; and processed in a manner that ensures appropriate security of the personal data, including
- protection against unauthorised or unlawful processing and against accidental loss,
- destruction or damage, using appropriate technical or organisational measures.
How we collect information from you and what information we collect
We collect information about you;
- when you become a resident at Chapelton you enter into a Chapelton Community Interest Company Understanding Agreement with ourselves or otherwise provide us with your personal details;
- from your arrangements to make payment to CCIC relating to your Understanding Agreement Annual Subscription (such as bank details).
We collect the following information about you :- - Name;
- Address;
- Email address;
- Phone number;
- Bank Details;
- Plans of your property.
We receive the following information from third parties:- - name/s, email, address and plot price from the sales teams at Chapelton or solicitors;
- payments made by you to us.
We may sometimes collect additional information from publicly available information including Companies House, Registers of Scotland and the Land Registry.
Why we need this information about you and how it will be used
We need your information and will use your information:
- to undertake and perform our obligations and duties to you in accordance with the terms of our agreement with you;
- to enable us to supply you with the services and information which you have requested;
- to pass on your contact details to builders / developers / contractors in order they may reply to queries / issues you have raised with the CCIC;
- to analyse and collect so that we can administer, support, improve and develop the business we offer;
- to contact you in order to send you updates on the services we provide;
- to enforce the legal obligations undertaken by you;
- for all other purposes consistent with the performance of our operations and business; and
- to process Direct Debit payments for annual subscription payments.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing the information we hold are:
(a) We have a contractual obligation.
(b) We have a legitimate interest.
(c) We have consent
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in CCIC’s systems.
Sharing of your information
The information you provide to us will be treated as confidential and will be processed only by us, and any third party acting on our behalf. We may disclose your information to other third parties who act for us for the purposes set out in this notice, or for purposes approved by you, including the following:
- if we have to enforce legal obligations;
- if we enter into a joint venture with or merge with a business entity, your information may be disclosed to our new business partners or owners;
- if we instruct repair or maintenance works, your information may be disclosed to any
contractor; - if we are investigating a complaint, information may be disclosed to Police Scotland, local
authority departments, the Scottish Fire & Rescue Service and others involved in any
complaint, whether investigating the complaint or otherwise; - if we are investigating payments made or otherwise, your information may be disclosed to payment processors, the local authority and the Department for Work & Pensions; and
- if we are conducting a survey of our services, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
Where necessary, our data processors may share personal information outside of the UK.
Removal of Data
The CCIC shall retain personal data only for so long as that person is a resident at Chapelton, or until that person’s legal obligations have been fulfilled, or until they are required to do so by law . To ensure that personal data is kept for no longer than necessary, CCIC shall ensure that processes are in place for the removal of data at the appropriate time and such processes shall be reviewed annually.
Security
CCIC shall ensure that personal data is stored securely using modern software that is kept-up-to-date. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information. Personnel handling personal data shall ensure that computer equipment is locked when they move away from their equipment, undertake not to share passwords unless authorised to do so and shall ensure any hard copy documentation is kept in
a secure filing system. When personal data is deleted this should be done safely such that the data is irrecoverable. Appropriate back-up and disaster recovery solutions shall be in place.
Your rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal data.
Your right to rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.
You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.
If you would like to exercise any of your rights above, please contact us at
CCIC_admin@chapeltonlife.co.uk
Breach
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, CCIC shall report this breach to the ICO within 72 hours and shall also promptly assess the risk to people’s rights and freedom and if appropriate report this breach to the affected individuals.
CCIC shall keep a record of any data breaches.
Should you wish to complain about the use of your information, we would ask that you contact us to resolve this matter in the first instance. You also have the right to complain to the ICO in relation to our use of your information. The ICO’s contact details are noted below:
The Information Commissioner’s Office – Scotland
45 Melville Street, Edinburgh, EH3 7HL
Telephone: 0131 244 9001
email: scotland@ico.org.uk
The accuracy of your information is important to us, please help us keep our records updated by informing us of any changes to your email address and other contact details.