20 May 2018
This policy applies to our websites, membership forms, room-hire forms, employment contracts, email newsletters, gift aid forms, and any other format where a person is asked for personal information by Primrose Hill Community Association (PHCA), or Primrose Hill Community Library (PHCL)
The purpose of this policy is to explain what information we collect, how we process it, any third-party that we share it with, and our obligations to you.
The data controller is Primrose Hill Community Association, 29 Hopkinson’s Place, Fitzroy Road, London, NW1 8TN
What information do we collect?
Information you provide:
We collect information about you when you register to become a member of, donate to, become an employee of, or hire space at PHCA or PHCL. This information may include, but is not limited to: your name, address, e-mail address, phone number, date of birth, gender, social media handles.
We may also request additional information if necessary to fulfil any special requests from you.
How do we process your information?
We process your personal information with your consent in the pursuit of our legitimate interests.
We collect your (and/or your children’s) name, date of birth, gender, address, telephone number(s), email address, and may collect additional information such as your social media handles if needed for a specific purpose.
The information is used to keep you informed of events, news, and information about PHCA / PHCL through our newsletters, and also allows us to be in touch about book requests, hire of the rooms, stall hire during various fairs, or anything related to the day to day running of the charity. In order to join PHCL as a library user, we do require proof of your address, but this is merely a visual inspection and we keep no record of the document other than a tick on the registration form to say we have seen it. We will retain this information until you cease to become a member of the charity, or until the charity ceases to exist.
Newsletters; Calls for Help; Local information
Should you wish to receive them, PHCA/PHCL will send you marketing emails around once a month (although this may vary) via Google Mail and/ or MailChimp. These detail forthcoming events and news about the charity (such as new books at PHCL, or holiday closing times etc).
PHCA will send more frequent public information emails which may be of interest to the local community (such as information from members about spare tickets for non-PHCA/PHCL events, furniture to give away etc).
If you have expressed an interest in volunteering with PHCA/PHCL, then you will be added to a separate mailing list and contacted when there is an opportunity for you to help.
We will retain this information until you withdraw your consent for us to process it, until you cease to become a member of the charity, or until the charity ceases to exist.
We process this data with your express written or verbal consent and within our legitimate interests to keep you informed about events, news, useful local information, and volunteering opportunities.
We may occasionally ask for feedback in the form of a poll, a questionnaire, or a survey. Your data and responses to questions will be randomised before we share the results with any third party.
Statistics, demographics and research
PHCL compiles monthly reports of library growth in three key areas:
- amount of new members (and their age breakdown);
- and total items loaned.
The information is added to the Library database in an anonymised way; i.e. we do not include any personally identifiable information, just the numbers. We may choose to share this database with third parties at our discretion.
PHCA / PHCL use CCTV for the purposes of crime prevention or to help legal redress in case of a crime being committed. Only employees and /or board members of PHCA / PHCL are authorised to view the recorded footage, except in such cases where we may be required to hand over footage to the police, solicitor, or any other authority with the power to require it.
We are required by law to keep some information such as accident reports, wages paid (in the case of employees), and gift aid declarations. Information pertaining to these is only kept, processed and shared according to legal obligations.
Who do we share your information with?
Your personal information may be shared with anyone involved in the day to day running or management of the charity. We have a high number of front-desk volunteers at PHCL who may have to access information which you have freely provided in order to pursue the legitimate interests of the charity, and to provide you with the best possible customer service.
PHCL / PHCA will share your personal information with trusted third parties. Below is a list of those parties with an explanation of why your information is shared with them and links to their own privacy policies where applicable.
- Legal Reasons: PHCA / PHCL will turn over any personal information if required to by a person or body with authority to require it (e.g. Police, courts, etc).
What are your rights?
Individuals have a number of rights under GDPR which we will list below along with an explanation of how to exercise those rights. Please note that some of these rights are not absolute and may be superseded by law or your exercising of other rights.
- The right of access: You have the right to request access any personal information we have relating to you. In the event that you wish to request access, please contact us via email, telephone, or post. See the ‘Contact Us’ section for details. Please give us as much information as you can about what you want from us to help us assist you as quickly as possible. Assuming there is no legal reason to prevent this and the request is not manifestly unfounded or excessive, we will respond in full within 30 days.
- The right to rectification: If there is any information we have about you which is incorrect then you have the right for it to be rectified without undue delay assuming there is no legal reason to prevent this or the request is not manifestly unfounded or excessive. Please provide as much detail as you can in order for us to assist you as quickly as possible. The rectification process applies to all third parties whom we have shared the relevant information with.
- The right to erasure: You have the right to withdraw consent for us to process your data at any time. Withdrawal can be requested verbally or in writing. Please note that in certain cases this would mean that you would cease to become a member of PHCA/PHCL. For example, we could not continue your library membership without a record of your name, address, telephone number or email address. Withdrawing your consent to be contacted via MailChimp or Google Mail for the purposes of marketing would not affect your ability to remain a member of PHCA/PHCL.
- The right to restrict processing: You have the right to suspend our ability to process your personal data (for example during a right of access request) beyond simply storing it. Assuming the request is not manifestly unfounded or excessive, and doesn’t interfere with our ability to fulfil a previous request you have made, then we will respond in full within 30 days.
- The right to data portability: The right to data portability gives you the right to receive personal data relating to you which we have acquired in a commonly used, or machine-readable format. Assuming the request is not excessively complicated, we will respond in full within 30 days.
- The right to object: You have the right to object to our use of your personal data for specific purposes such as marketing provided your objection does not interfere with our legitimate interests (i.e. our ability to provide you with a service).
- The right not to be subject to automated decision-making, including profiling: You have the right not to be subject to a decision that was made automatically by automation and without human involvement.
Should you wish to exercise any of your rights listed above, you can contact us in the following ways.
Telephone: +44 (0)20 7586 8327
Post: c/o The Manager, Primrose Hill Community Association, 29 Hopkinson’s Place, Fitzroy Road, London, NW1 8TN
You have the right to complain to the Information Commissioner’s Office if you are not satisfied with our response to your requests.
The ICO can be contacted in the following ways:
Telephone: 0303 123 1113 (local rate) / 01625 545 745 (national rate)
Fax: 01625 524 510
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF