1. About this Policy
1.1 This policy explains when and why we collect personal information about our clients, how we use it and how we keep it secure and your rights in relation to it.
1.4 We will always comply with the General Data Protection Regulations (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
2. Who are we?
2.1 We are Elie Harbour Trust (the Trust) and can be contacted via:
Secretary, Elie Harbour Trust, Craigie Villa, Links Place, Elie, LEVEN KY9 1AX
3. What information we collect and why:
In the following table, “client” refers to those who lease (and those who apply to lease) facilities from the Trust:
|Type of information||Purposes||Legal basis of processing|
|Client’s name, address, telephone numbers, e- mail address(es).||Managing the allocation of berthing of vessels; dinghy parking; kayak storage; stores; beach huts; ground; and other facilities, and the provision of services.||For the purposes of our legitimate interests in operating the Trust.|
|Client’s insurance company.||Ensuring that craft, premises, etc are adequately insured.||Performing the Trust’s contract with the client.|
|The client’s vessel type, name, dimensions, sail number and category of use.||Managing the allocation of vessel berthing / parking / storage / launching.||For the purposes of our legitimate interests in operating the Trust.|
|The client’s details of charges and payment.||Managing the allocation of vessel berthing / parking / storage / launching.||For the purposes of our legitimate interests in operating the Trust.|
|The client’s car registration.||Managing the car parking and vessel launching within the harbour area.||For the purposes of our legitimate interests in operating the trust.|
|Individuals directly paid by the trust. NI number, tax codes, salary, bank details.||Managing salary payments.||To allow management and payment of wages to employees.|
4. How we protect your personal data:
4.1 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
4.2 Please note, however, that where you are transmitting information to us over the Internet this can never be guaranteed to be 100% secure.
4.3 For any payments which we take from you online we will use a recognised online secure payment system.
4.4 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
5. Who else has access to the information you provide us?
5.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where required to do so by law or as set out in the table above or paragraph 5.2 below.
5.2 We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
6 How long do we keep your information?
6.1 We will hold your personal data on our systems for as long as you are a client of the Trust and for as long afterwards as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment exercise or defence of legal claims.
6.2 We securely destroy all financial information once we have used it and no longer need it.
7. Your rights:
7.1 You have rights under the GDPR:
(a) to access your personal data
(b) to be provided with information about how your personal data is processed
(c) to have your personal data corrected
(d) to have your personal data erased in certain circumstances
(e) to object to or restrict how your personal data is processed
(f) to have your personal data transferred to yourself or to another business in certain circumstances.
7.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner.
- Online: https://ico.org.uk/concerns
- By ‘phone: Helpline on 0303 123 1113
- By post: Information Commissioner’s Office, Wycliffe House, Water Lane, WILMSLOW SK9 5AF
Should you have any queries regarding our Data Processing Policy, please contact: firstname.lastname@example.org