This statement explains what information we collect for membership purposes and how we use that information.
What is the legal basis for holding your data and what do we use it for?
As a member owned organisation there are certain legal obligations we must meet to comply with the Co-operative and Community Benefit Societies Act 2014, for example as a member we must inform you of the details of the AGM, OGM and any other relevant meetings which you can attend to hear about, participate in the debate and vote on matters relevant to the Society. We will also inform you how the Society is performing, the work we are doing in supporting local charities and communities. As member you are entitled to certain membership benefits which we will inform you about from time to time. We may also offer you information about current promotions.
We offer a Membership app which allows us to send you information about Society offers and to obtain regular information about the Society. This app then stores your name, email address and membership number. For further details please see the terms and conditions of the app.
Community Connect initiative
We also have recently embarked on our community connect trial initiative which enables you to vote for selected local groups who are looking to benefit from our community funding. This means we can link your membership number with your transactions and on occasion we may use data analytics to analyse this data to determine our members’ economic activity, to review the success of the scheme and potentially to detect fraud. We may use this data in the future to send you more detailed offers and benefits but we do not do this currently. This selection would be based on what members in general, or members in particular regions, are purchasing rather than you as an individual.
What information do we share?
Some of our service providers may have access to your data in the course of providing software and IT support. Their access is strictly controlled and they are subject to appropriate confidentiality obligations.
We have not shared your personal information with any other third parties for marketing purposes. We may share anonymised data with third parties including others in the Cooperative movement for statistical analysis.
How long do we keep your data?
Currently we may hold your name, address, possibly email address, date of or year of birth. We also hold your share balance. This is held on a secure database and is only accessed by specific employees or contractors, primarily in the membership team for the purposes noted above. We hold this data during the time you are a member of the Society and will retain some outline information for administrative or archiving purposes if you close your account.
Members’ data rights and obligations
Members should inform us of any changes to their contact details. Details of Members’ data rights and obligations are given in the Appendix attached. If you have a concern regarding the accuracy of your personal data held by the Society regarding your membership, please contact the membership team to request an amendment to the data. Membership contact details firstname.lastname@example.org 0131 335 4433.
If you have a complaint regarding the Society’s use of your data or the way we have handled any request from you to exercise any of the rights requested above then we ask that you contact our Data Privacy Manager, email@example.com or by telephone on 0131 335 4400 in the first instance so we can take remedial action, however you also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at www.ico.org.uk or call 0303 123 1113.
We have put in place appropriate technical and organisational security measure to protect the security and confidentiality of your personal data. In addition we have procedures to deal with any data security breach and will notify any affected members and/or the Information Commissioner in compliance with the law if a breach occurs.
Members’ data rights and obligations
Under certain circumstances, members 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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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.
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 data’s accuracy; (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 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If a Member wishes to make a request on any of the above grounds you may contact our Data Privacy Manager, on the contact details below. Please note that depending on the nature of the request, the Society may have good grounds for refusing to comply. If that is the case, we will provide an explanation to you. Generally no fee will be payable, however, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive (particularly if it is repetitive). We may also charge a reasonable fee to comply with further copies of the same information. Alternatively, we may refuse to comply with your request in these circumstances.