Privacy Notice for The Ernest Cook Trust
This privacy notice sets out the way we process your personal information. We have done this to make sure you are aware of how we use your data at The Ernest Cook Trust, whether as a tenant/agreement holder (agricultural, residential or other), school/college/community group member (as a staff member or as a pupil/student/participant), grant applicant/holder, service provider, staff member, Trustee or otherwise. We will always refer to this page when we ask you for your consent and we will keep this page updated so you can be confident when sharing your information with us that it will be only used for what we describe here.
The Ernest Cook Trust (ECT) is a not for profit charity registered with the UK Information Commissioner’s Office with registration number ZA363475.
How we collect your information
We may collect your information in a few limited ways namely:
- Directly from you when you write to us, for example:
– in applying for a tenancy and once in place as a tenant;
– in applying for a grant and once in place as a grant-holder;
– in applying for a staff position at the Trust.
- From someone else such as our agents who act on our behalf in marketing tenancies, in recruiting staff, or school/college/community group staff in arranging visits.
- On rare occasions when we receive information about you from another organisation (for example when you, in the past, were a tenant of such an organisation).
The types of information we collect
We may collect the following types of personal data about you (and your family members, where relevant):
- Contact and communication information, including your contact details (including email address(es), telephone numbers and postal address(es) and records of communications and interactions we have had with you);
- Financial information, including Direct Debit details (but not your payment card details, which we never collect or store ourselves);
- Certain other information which you volunteer, for example:
– when you apply for a tenancy or write to us as an existing tenant;
– when you write to arrange an educational visit;
– when you report to us on grant outcomes;
– when you apply to us for a position.
We may also collect limited data concerning your health or medical conditions, for example when you have volunteered this, for example so that we can take this into account in the management of the estate or tenancy/agreement with you or for the planning and conduct of educational visits or in relation to your employment/workplace needs.
How we use personal information
Personal information provided to us will be used for the purposes outlined at the time of collection or application in accordance with the preferences you express.
Personal data collected and processed by us may be used for the following purposes:
- Administration of the estate
- Administration of educational visits and teaching
- Fulfilment of orders for goods and services
- Administration of grants
- Administration of the charity (and its pension scheme)
- Research and statistical analysis
- Communication about our work and other activities that we think may be of interest to you
Your communication preferences
ECT will always act upon your wishes in respect of the type of communications you want to receive and how you want to receive them. There are some communications, however, that we need to send you regardless of your communication and marketing preferences. These are what we would describe as essential communications to fulfil any contractual obligations to you. Examples of this type of communication would be:
- Transaction notifications, such as payment receipts or Direct Debit confirmations, for tenants/agreement holders, staff, Trustees, members of the pension schemes, customers and suppliers;
- Rent notices for tenants;
- Other matters concerning the Trust that may interest you as tenants/agreement holders, school partners, grant holders/applicants, staff, Trustees or other supporters.
You are always in control of how we communicate with you. You can update your choices by contacting us at the address below.
Sharing your information with others
We do not sell or share your personal information for other organisations to use other than as set out below. Personal data collected and processed by us may be shared with the following groups where necessary:
- ECT staff and Trustees for the purposes of administering your activity.
- Also, under strict obligations of confidentiality and with other appropriate contractual protections in place:
– our contractors;
– our advisors.
When we need to provide your information to third parties, we will ensure they meet the requirements to keep your data safe and secure.
How long your information is kept
We hold your information only as long as necessary for each purpose for which we use it. For most information this means we retain it for a period of six years after your last interaction with us (for accounting, tax reporting and record-keeping purposes). In the case of tenants, this means we retain it for so long as the tenancy runs and succession rules apply.
You have the right to ask us, in writing, for a copy of all the personal data held about you (this is known as a ‘subject access request’). A copy will be sent to you as soon as possible and this will be no later than one month after your request.
If you would like to access your personal data held by us, please apply in writing to the Director of Finance & Operations at the address below.
Once the GDPR takes effect on 25 May 2018, you will also have the right to:
- request a copy of your personal data which the Trust holds about you;
- require us to correct the personal data we hold about you, if it is inaccurate;
- request that we erase your personal data;
- request that we restrict our data processing activities (and where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you including for the purpose of you transmitting that personal data to another data controller;
- object on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply; for example, if we can show our processing is necessary for a lawful purpose set out in this Privacy Notice.
Updating your personal information
We will always try to keep your data as up-to-date as possible. If at any time you want to update or amend your personal data (or marketing preferences) then you can do so by contacting us at the address below. The verification, updating or amendment of personal data will take place within 28 days of receipt of your request.
If you have any queries about this privacy notice, or how we process your personal information, or if you wish to exercise any of your rights under applicable law, you may contact the Director of Finance & Operations:
The Ernest Cook Trust
The Estate Office, Fairford Park
Fairford GL7 4JH
If you are not satisfied with how we are processing your personal information, you can make a complaint to the Information Commissioner. You can find out more about your rights under applicable data protection legislation from the Information Commissioner’s Office website available at www.ico.org.uk.