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Privacy Policy

1. Introduction

 Your privacy and trust are important to us and this Privacy Policy provides important information about how Newnham on Severn Community Benefit Society (“NoSCBS Ltd“), Company Registration Number: RS008012 trading as The George (“we”, “our” or “us”) handle personal information. This policy applies to personal information which we process in the course of doing business, including information processed through our website and the services we provide.

Please read this policy carefully and contact us if you have any questions about our privacy practices or your personal information choices.

It is important that you check back often for updates to this policy. If we make changes that we consider to be important, we will let you know by placing a notice on our website and/or contacting you using other methods such as email.

2. Purpose of the processing, legal basis, duration and retention periods

We may process personal information about you in different ways depending on our relationship with you.

2.1 You are a prospective, current or past member of NoSCBS Ltd

We will collect and store personal information including names, dates of birth, contact details (including postal addresses, mobile/landline telephone numbers and email addresses) of our shareholders/members so that we can provide you with information in relation to your prospective or existing shareholding/membership and/or in relation to the business of NoSCBS Ltd including but not limited to Annual Members’ Meetings, committee members, reports on fundraising and grant applications. We will also retain that information and any information relating to the shareholding/membership for a period of up to seven years following the severance of your shareholding/membership so that we can review our performance if any complaints or issues arise after the severance of your shareholding/membership.

We may use your information for analysis, where it is in our legitimate interests, to improve or develop our practices in relation to shareholders/members.

Unless you request us not to do so, we may also contact you with information that we think may be of interest to you. This contact may be made by telephone, email, social media platforms (including associated messaging platforms), post or text. We will only do this if we believe that it is in our legitimate interests to keep you informed of our matters relating to your shareholding/membership and if we believe that you would reasonably expect us to contact you in this way. We will not send you general marketing information in your personal capacity as part of a group emailing campaign unless you have consented to be contacted in this way. 

2.2 You are a current or historical customer of our Services

We will collect and store personal information including names, contact details (including postal addresses, mobile telephone numbers, Facebook, Instagram, WhatsApp and other social media platform details) and email addresses of our customers so that we can provide our services in accordance with our agreed engagement/contract(s) with you. We will also retain that information and any information relating to the contract(s) between us for a period of up to seven years following completion or termination of the contract(s) between us so that we can review our performance if any complaints or issues arise after completion of the contract(s).

We may use your information for analysis, where it is in our legitimate interests, to improve or develop our services and practice.

Unless you request us not to do so, we may also contact you with information that we think may be of interest to you. This contact may be made by telephone, email, social media platforms (including associated messaging platforms), post or text. We will only do this if we believe that it is in our legitimate interests to keep you informed of our services and if we believe that you would reasonably expect us to contact you in this way. We will not send you general marketing information in your personal capacity as part of a group emailing campaign unless you have consented to be contacted in this way. 

2.3 You are a supplier or an employee of a supplier to us

We will collect and store personal information including contact details of our suppliers and those employees of the supplier who are involved in the delivery of the contract so that we can receive your goods or services in accordance with our contract with you. We will also retain that information and any information relating to the contract(s) between us for a period of seven years following completion or termination of the contract(s) between us so that we can review your performance if any complaints or issues arise after completion or termination of the contract(s).

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We will do this where it is in our legitimate interests to expand and/or develop our business and explore new business opportunities with you. We will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information in your personal capacity as part of a group emailing campaign unless you have consented to being contacted in this way.

2.4 You are a third party with whom we are in contact during the delivery of services to our customers or the possible delivery of services to prospective customers

We will collect and store personal information including contact details of third parties with whom we are in contact during the delivery of services to our customers or discussions relating to services to prospective customers. We may receive that information from you, a customer, a supplier, an introducer or otherwise as a result of an interaction between you and our supplier or customers. We process that information because it is in our legitimate interests to do so in order for us to be able to perform our contracts for our customers or pursue business development opportunities with prospective customers. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair.

Where your personal information is kept as part of a file relating to the performance of a contract with one of our customers, we will also retain that information and any information relating to that contract for a period of up to seven years following completion or termination of that contract(s). This is so that we can review the file if any complaints or issues arise after completion or termination of the contract.

Where your information is stored in our contacts database, email archive or other records but is not kept in a customer or supplier file, we carry out a review of our records every two years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We are processing your personal information in this way because it is in our legitimate interests to expand our business and explore new business opportunities with you. We will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information in your personal capacity as part of a group emailing campaign unless you have consented to being contacted in this way.

2.5 You are: (a) a prospective customer or an employee of a prospective customer; or (b) a prospective supplier or an employee of a prospective supplier

We will collect, store and use personal information including names, email addresses and contact details of people who we might do business with as a supplier or a customer for the purpose of expanding our business and exploring new business opportunities. We may collect this information from you when you contact us (including through this website) or from a mutual contact. We will only collect contact information from your website or another third-party website if we have identified you specifically as someone who may be interested in receiving a service from us or delivering goods or services to us.

We may contact you about new business opportunities for us to work together with you and to keep you informed of our activities.

We do this where we have a legitimate interest to expand and/or develop our business and explore new business opportunities with you. We will only contact you in this way if we believe that you would reasonably expect us to process your personal information in this way and that such processing does not impact on you in a way that would make this processing unfair. Where your information is stored in our contacts database but is not kept in a customer or supplier file, we carry out a review of our contacts database every two years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We will not send you general marketing information in your personal capacity as part of a group emailing campaign unless you have consented to being contacted in this way.

2.6 You are an employee or a relative of an employee

Employees should refer to the Staff Handbook for further information about our privacy policy in respect of employees.
Where an employee has provided us with personal information about a spouse, civil partner or other family member/friend (perhaps in relation to pension or other benefits, or as an emergency contact), it is the employee’s responsibility to inform that person that the employee has provided us with their details and that we will be processing it as an emergency contact or in connection with the relevant benefit and/or policy in accordance with this privacy policy. 

2.7 You are a prospective employee or a referee of a prospective employee

If we have received your details in response to a recruitment initiative, we will store the personal information that either you, your recruitment agent or another third party has provided us with. We process that information because it is in our legitimate interests to do so in order for us to be able to make an informed decision about whether to interview you and, ultimately, recruit you. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair. Where your personal information is kept as part of a file relating to prospective employees of NoSCBS Ltd, we will retain that information and any information relating to that matter. This is so that we can review the file if any complaints or issues arise after the recruitment process. The length of time that we keep prospective employee files is usually six months after conclusion of the relevant recruitment process.

Unless you request us not to do so, we may also contact those individuals who are referred to in any information you provide us with, for example referees,. This contact may be made by telephone, email, post or text. We will only do this if we have your express permission to contact them in this way.

Where you have provided us with personal information about a referee or a previous employer, it is your responsibility to inform that person that you have provided us with their details and that we will be processing it in connection with your employment application. You should also give them our contact details (below) should they wish to discuss this with us.

2.8 We have received your information from a third party

If we have received your personal information from a third party, for example your employer or recruitment agency, that third party will normally be the controller in relation to that personal information and we will be processing it on their behalf. You should therefore contact that third party to review their privacy policy.

2.9 Your relationship with us is not covered by any of the above

We may hold your contact details and personal information as a result of an interaction between you and one of our members/employees/workers/volunteers. We are processing your personal information in this way because it is in our legitimate interests to retain a record of our members’/employees’/workes’/volunteers’ engagements with third parties. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair. We carry out a review of our contacts database every two years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

2.10 Where you provide us with personal information about another person

If you give us personal information about another person, you must ensure that:

  • you are legally entitled to give us that information;
  • the disclosure is in accordance with any applicable data protection or privacy laws; and
  • such other person has also read this privacy policy.

3. Personal information we hold and where we collect it

The information we collect about you depends on the products and services you use and how you purchase those products and services. It includes (but is not limited to):

  • your name, address, email address and other contact details;
  • financial details, including bank and credit card details to process payments only;
  • your communications with us, including data you have provided to us by filling in forms on our website, or by corresponding with us by telephone, email, social media or otherwise. It includes information you provide when you register to use our site, subscribe to our service, use our service, enter a competition, promotion or survey (where available), as well as notes and physical letters you send to us.

We will collect the information from you directly:

  • where you purchase our products and services directly from us through our website, our sales partners or otherwise;
  • where we contract with you for the supply of your goods and/or services;
  • where we liaise with and/or engage you for recruitment purposes; and
  • where you contact us to make an enquiry.

We may also process sensitive information, for example, relating to your health. Individuals are asked to give their consent for us to process their sensitive personal information and if you do not give that consent, then it is your responsibility to notify us of any sensitive personal information each time it may be relevant to the services we are providing or receiving from you. Such sensitive information will only be processed where that information is relevant to the goods or services we are providing or receiving from you.

We may be required to use and retain personal information for other legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.

When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed by us in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

4. When we share personal information

NoSCBS Ltd shares or discloses personal information when necessary to provide services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We do not sell any personal information to third parties. We may occasionally share non-personal, anonymised, and statistical data with third parties. Below are the parties with whom we may share personal information and why.

Within NoSCBS Ltd: Our society is supported by a variety of people who are part of NoSCBS Ltd’s teams and functions, and personal information will be made available to them if necessary for the provision of services, administration, sales and marketing, customer and technical support, and business development, for instance. All employees, workers, volunteers and contractors are required to follow our data privacy and security policies when handling personal information. 

Our business partners: We occasionally partner with other organisations to deliver services, provide content, or to host events, conferences, and seminars. As part of these arrangements, you may be a customer of both us and our partners, and we and our partners may collect and share information about you. NoSCBS Ltd will handle personal information in accordance with this policy, and we encourage you to review the privacy policies of our partners to learn more about how they collect, use, and share personal information.

Our third-party service providers: We partner with and are supported by service providers around the UK and European Union. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, including (without limitation) software, system and platform support; direct marketing services; cloud hosting services; advertising; data analytics; accountancy; insurance; and order fulfilment and delivery. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us. 

Other third parties: We will share personal information when we believe it is required or in our legitimate interests to do so, such as:

  • to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities;
  • in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
  • to protect our rights, systems, and services.

5. Where we store and process personal information

We take steps to ensure that the information we collect is processed according to this policy and the requirements of applicable law wherever the data is located.

We store information in hard copy files, which are stored in our offices and/or in archived storage space in the UK. We also store information in electronic format using computer-based systems and cloud-based servers within the European Union. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law.

6. How we secure personal information

We are committed to ensuring that your information is secure. 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, workers, volunteers, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions.

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.

7. How long we keep personal information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

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 to 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, or other requirements.

When we no longer need personal information, or when you request us to delete your information, where this is legal, we will securely delete or destroy it. See Section 2 above for further information on our retention periods.

8. Your legal rights

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.

Access to personal information: You have the right 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. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.

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 accuracy of the data; (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 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.

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. 

Correction of your data: You have the right to request that we correct or amend your personal information if it is inaccurate or requires updating. You also have the right to request that we complete your personal information on our records, if the information we hold is incomplete. 

Withdrawal of consent: If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by emailing management@thegeorgeatnewnham.co.uk or let us know in writing or by telephone. 

Marketing preferences: To opt out of email marketing, you can email management@thegeorgeatnewnham.co.uk or let us know in writing or by telephone. 

Filing a complaint: If you are not satisfied with how we manage your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk).

9. 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 email us at management@thegeorgeatnewnham.co.uk or let us know in writing or by telephone.

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, in compliance with the above rules, where this is required or permitted by law.

10. 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 our Services). In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.

11. Third-party links

Our website has 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.

12. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. 

13. Children’s privacy

Our services are not directed to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us.

14. How to contact us

Please feel free to contact us in one of the following ways:

Email: info@thegeorgeatnewnham.co.uk

Attn: [NAME]
Newnham on Severn Community Benefit Society Ltd
The George
Lower George House
High Street
Newnham on Severn
Gloucestershire
GL14 1BS