The Retail Trust is committed to protecting your data and your privacy. We aim to ensure that any information you give us is held securely and safely. Please read this policy carefully (along with our terms and conditions) to understand how we collect, use and store your personal information.
The Retail Trust (Registered Charity 1090136/SC039684) operates three wholly owned trading subsidiaries:
The Retail Trust Events Limited (Registered Company Number 03253828)
RT Wellbeing Services Limited (Registered Company Number 09958483)
Cottage Homes Contracts Limited (Registered Company Number 09127894)
These subsidiaries support the efficient fundraising, income-generation and operational activities of the charity, and their activities are also covered by this policy.
The Retail Trust holds and processes personal details in accordance with Data Protection Legislation, which is the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679. Retail Trust is registered with the Information Commissioner (Registration Number Z8109661). If you have any questions about this policy or how your data is handled, please write to:
Telephone: 01332 554200 (during office hours, Monday to Friday, voicemail available for messages outside these hours)
The Retail Trust takes data protection very seriously. As you use our website, get in touch with us, use our services, or take part in our activities and events, we collect information. This deepens our understanding of what you are interested in, helps us understand how well we are providing our services, and helps us to improve the quality and relevance of all of our interactions with our residents, visitors, and other people who use our services.
The Retail Trust and its subsidiaries will never share your information with another organisation for their own marketing purposes and we will never sell your information for any reason whatsoever. We know that this is important and want to reassure you that you are always in control of how we use the personal information you give us.
We do however need to collect and use your personal information for carefully considered and legitimate business purposes, which will help to ensure that we can run the Retail Trust and its subsidiaries efficiently, raise funds effectively and deliver our charitable activities.
This notice sets out what data we collect, how we will use it, what the legal basis for this is, and what your rights are in respect of your personal information.
What we collect
The Retail Trust will be a “controller” of the personal information that you provide to us either electronically, on paper or by telephone (unless at the time of collection, we tell you otherwise).
We offer a wide range of charitable services to our residents, visitors and other people who use our services. When you interact with us, we may ask you for some or all of the following personal information:
- Basic contact details – name, address, email address, date of birth, etc.
- Employment – name of your previous employer, job title and how long you were employed, etc.
- Your current living arrangements – to assess your priority for accommodation
- Your support needs e.g., mobility or health needs and the agencies involved in your care and support
- Equality information – for example, disability, etc.
- You may be photographed or included in a video recording if you attend our events.
We use closed circuit television (CCTV) images to provide a safe and secure environment for our residents, visitors and staff, and to protect the property. If you live on or visit one of our estates your image may be recorded on CCTV. Where we have set up CCTV cameras, appropriate signs are prominently displayed so residents, visitors and staff are aware they are in an area covered by CCTV. Recordings are only viewed by trained and authorised staff. Images recorded by CCTV are kept for one month unless needed for an investigation. We will provide CCTV recordings to the police and other authorities or legal representatives if they request it and where we consider it to be lawful under the data protection legislation.
Special categories of personal data
We also, where necessary, ask for sensitive personal information known in the data protection legislation as special categories of personal data – for instance, information about your health, racial or ethnic origin, or faith. This will only be asked for where there is a clear reason for doing so and both a lawful basis and special condition for processing apply under the data protection legislation, such as where we need this information to ensure that we provide appropriate facilities or support, or we are obligated to collect it to protect you or other people. For instance, we ask some residents for details about their health so we can help them get the care that is most appropriate for them. We will only use sensitive personal information for the purpose it is has been given and will dispose of it securely as soon as it is no longer required.
Why we need your personal information – consent
We will always ask for your consent to send you marketing communications by email, SMS or other electronic means. We will also ask you for your consent before contacting you by telephone for the purpose of marketing. In most cases, except where we are obligated to collect it, if you provide any sensitive personal information about yourself (called special categories of personal data in the data protection legislation), we will always seek your explicit consent to process this data. Where you give us consent to process your data, we will always keep a clear record of how and when this consent was obtained, and you can withdraw this consent at any time by contacting your estate manager. Withdrawing your consent may affect our ability to provide all or some of our services.
Why we need your personal information – contractual purposes
We need to collect your personal information so that we can carry out our obligations under a contract with you. For example, we need your personal information when entering into a tenancy agreement with you, and for communicating with you about repairs and maintenance to the property and other tenancy-related services that we provide. In each instance, we will only use your personal information to fulfil our obligations under the contract. If you do not provide us with all of the personal information that we need to collect, this may affect our ability to provide all or some of our services.
Why we need your personal information – legal obligations
We are under a legal obligation to process certain personal information relating to you for the purposes of complying with our obligations under:
- The Housing Act and Housing Scotland Act
- Any other legislation that places an obligation upon us to process personal information.
Why we need your personal information – equality monitoring requirements
In some cases, our commitment to giving everybody fair and equal treatment requires us to use your personal information relating to your ethnic origin or disability, etc. for equality monitoring purposes.
We will process such personal information to identify and keep under review the existence or absence of equality of opportunity or treatment between groups of people within the same categories to promote or maintain equality across our services.
Why we need your personal information – legitimate interests
The data protection legislation allows personal information to be legally collected and used by an organisation if it is necessary for a legitimate interest of the organisation - as long as its use is fair and balanced and does not unduly impact the rights of the individual concerned.
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact your estate manager. If we agree and comply with your objection, this may affect our ability to undertake the tasks below for the benefit of our beneficiaries and the funders who financially support the services we provide.
We process your personal information in pursuit of our legitimate interests in these areas:
- The delivery of our charitable mission as set out in our charitable priorities
- Internal and external audit for financial or for regulatory compliance purposes
- Statutory reporting
- Operational management
- Physical security, IT and network security
- Processing data for historical, scientific or statistical purposes.
- Communications designed to administer existing services that an individual has asked or registered for:
- Collating anonymous statistical information which may be shared with third parties
- Administrating Gift Aid
- Ensuring we respond properly to complaints
- Thank you communications and receipts
- Maintenance of “do not contact lists”.
Why we need your personal information – public interest
We may also process your personal information when it is required to perform a task in the public interest that is set out in law. We consider our financial management and control to be tasks we carry out in the public interest, this includes:
- Processing of financial transactions and the maintenance of financial controls
- Preventing fraud, the misuse of our services, or money laundering
- Enforcing legal claims, including debt collection via out-of-court procedures.
Other uses of your personal information
We may ask you if we can process your personal information for additional purposes. For example, where a new technology could allow us to offer improved services for you. Where we do so, we will provide you with an additional privacy notice that explains how we will use your information for these additional purposes.
Who we share your personal information with
We may share your personal information with our wholly owned trading subsidiaries to assist us with the efficient fundraising, income-generation and operational activities of the charity, and their activities are also covered by this policy.
We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include the local authority social services, police, health and safety executive etc. for the purposes of safeguarding vulnerable adults and fulfilling other statutory obligations.
We may also share personal information with our professional and legal advisors for the purposes of taking advice.
The Retail Trust employs third party suppliers to provide services, including property maintenance and servicing contractors etc. These suppliers may process personal information on our behalf as “processors” or “joint controllers” and are subject to written contractual conditions to only process that personal information in accordance with data protection legislation.
In the event that we do share personal information with external third parties, we will only share such personal information strictly required for specific purposes we have identified in advance, and will take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.
How we protect your personal information
Your personal information is stored in our secure electronic filing system, our servers are based in the UK, and are only accessed by trained and authorised staff and volunteers for the purposes set out above. We keep your personal information secure by using a range of technical and organisational security measures, including tools, systems and processes to:
- Restrict physical access to our computers and servers
- Encrypt, anonymise and pseudonymise as appropriate personal information
- Ensure the ongoing confidentiality, integrity, availability and resilience of our data processing systems
- Restore the availability and access to personal information in a timely manner, in the event of a physical or technical incident.
We also store some personal information in paper files. Where we do this, those files are kept in secure locations in locked cabinets that only authorised staff and volunteers have access to.
In addition, we regularly test, assess and evaluate the effectiveness of all our technical and organisational measures for ensuring the security of the personal information we process.
How long we keep your personal information
We only keep your personal information as long as is reasonable and necessary for the relevant activity. We may extend this period after the relevant activity has completed to comply with statutory restrictions or industry best practice, for example, tenancy agreements.
We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold. This sets out different retention periods for different forms of data and you can request a copy by contacting us at email@example.com or by asking your estate manager.
Your communications with us (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.
Your rights in relation to your personal information are:
- You have a right to request access to the personal information that we hold about you by making a “subject access request”
- If you believe that any of the personal information that we hold about you is inaccurate or incomplete, you have a right to request that we correct or complete it
- You have a right to object to and/or request that we restrict the processing of your personal information for specific purposes
- If you wish us to delete the personal information that we hold about you, you may request that we do so
- If you would like to obtain the personal information that we hold about you to reuse it for your own purposes, you may request that we do so
- If we undertake any automated decision-making and profiling, you have a right to object to your personal information being used in this manner.
You can exercise any of these rights by making a request your estate manager or emailing firstname.lastname@example.org.
Any requests received by the Retail Trust will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner’s Office.