Smart Communities Ltd (SCL) takes safeguarding your privacy and information very seriously and this policy explains how we collect, use, and dispose of your information, the conditions under which we disclose it and how we keep it secure.
Who are we?
The Smart Communities Limited (SCL) is a Company Limited by Guarantee, No. 11480430 and VAT Registered No.311926619, created in 2018 as a subsidiary of Community Council of Somerset (CCS) is a Charitable Company Limited by Guarantee, No. 3541219 and a Registered Charity No.1069260, established in 1926.
How do we collect information about you?
We have the following ways to collect information about you:
• Anonymous cookie information online via SCL web page hosted by CCS
• Event or workshop forms
• Telephone enquiry
• Email enquiry
• Community Consultation
• E-newsletter sign-up
By filling out our contact form, or e-newsletter sign up, we will collect the following data:
• Your name
• Your contact information; email addresses
• Organisation name if applicable
We may collect additional information with written consent if you become a client/customer in receipt of one of our projects or services. This additional information can include sensitive data:
• Telephone number(s)
• Equal opportunities information
• Health information
• Action plans
This information is securely stored and accessed via the CCS cloud/web-based CRM Management Data Base.
How we collect your data Online
We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and service. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
How your information is used
We may use your data for the following reasons:
• To respond to your request
• To provide contracted services
• Internal records: accounts / insurance documents
• Improvement of our products/services
• Reporting to our funders – no personal data is shared unless consented.
In addition, with your consent, we will also:
• Send by email news, events and promotional materials that may be of interest of you if you sign up to our Thatch Newsletter.
We review our retention periods on a regular basis, but we are legally required to hold some information to fulfill statutory obligations. We will hold your information for as long as is necessary for the relevant activity or as long as is set out in any relevant contract you hold with us.
Third-party service providers
• We will not sell or share your information with third parties for marketing purposes.
• We may pass your information to our third-party service providers, subcontractors, and other associated parties for the purposes of completing tasks on our behalf.
• When we use third-party providers, we disclose only the information that is necessary 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 direct marketing purposes.
• We employ the services of other trusted parties for dealing with certain processes necessary for our operations for collating e-newsletter responses and for online payments.
• We use a secure Cloud-based CRM and accounts system for managing our customer details and service records.
We do not seek to collect Personal Information about children in delivering our projects and services or through the CCS website and are committed to protecting the privacy of online visitors under the age of 18.
Parents should supervise the online activities of their children, and consider the use of tools available from online services and software providers that help provide child-friendly Internet environments.
At any time you have the right to request and view your personal data held by SCL. Your rights also include:
• The right to be informed
• The right of access
• The right to rectification
• The right to removal of information
• The right to restrict processing
• The right to data portability
• The right to object
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity.
You may instruct us at any time not to process your personal information for marketing purposes. Please contact us firstname.lastname@example.org or call 01823 331222 if you would like to exercise any of the above rights. We will provide a response with 30 days.
See the SCL Individual Rights Policy: www.ccslovesomerset.org/smartcommunities-policies
You also have the choice to unsubscribe to any direct marketing that we send you. This feature is included in all e-marketing campaigns. If you are having problems unsubscribing please contact us. We will promptly take action to ensure you are “opted-out” from receiving further mailings. Although we will remove your name from our e-newsletter mail list as quickly as possible, please recognise that there may be a period of time after you unsubscribe during which you may still receive e-mails from us.
If you have a concern about how we have handled your information you can report this to the Information Commissioners Office (ICO).
Updating information and contact details
Please let us know if the personal information that we hold about you needs to be corrected or updated. CCS controls its website content and information can be changed easily
Data security is of great importance to SCL and to protect your data CCS have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected via our staff or volunteers.
SCL Data Security
SCL stores all data via CCS as its Data Processor
Cyber Essentials Accredited
CCS has achieved the Cyber Essentials Scheme accreditation. The Certificate certifies that this organisation was assessed as meeting the Cyber Essentials implementation profile [BIS/14/696/1.5] and thus that, at the time of testing, the organisation’s ICT defenses were assessed as satisfactory against commodity based cyber-attack. However, this does not in any way guarantee that the organisation’s defenses will remain satisfactory again cyber-attack.
Smart Communities Ltd is registered as a data controller with the UK Information Commissioner’s Office (ICO) our data protection registration number is A8484082. If you have any questions regarding the SCL on the CCS website or the data we may hold please contact CCS email@example.com or call 01823 331222 to make a Subject Access Request.
If password access is required for certain parts of the website, you are responsible for keeping this password secure and confidential.
We endeavour to protect your personal data. However, the transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your data transmitted to the website. We strongly advise you to have the latest cybersecurity on your personal computer or devices you use to access the internet.
We will inform you if a breach occurs and that we consider your data exposure to be a risk to you and your rights.
All Cookies used by CCS or Somerset Carers Website are used in accordance with current UK and EU Cookie Law.
Before the Website places Cookies on your computer, you will be presented with a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling CCS to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
Our Website may place the following Cookies:
Type of Cookie Purpose
Analytical/performance cookies Allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
You can choose to enable or disable Cookies in your internet browser and delete Cookies at any time.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help provided by your internet browser if you are unsure about adjusting privacy settings.
Links to other websites
You may contact CCS by email at firstname.lastname@example.org
Definitions and Interpretation
• Data: collectively all information that you submit to CCS via the Website or our staff. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998 and GDPR (2018).
• Cookies: a small text file placed on your computer by the CCS or Somerset Carers websites when you visit certain parts of the Websites and/or when you use certain features of the Websites. Details of the cookies used by both Websites are set out in the clause below (Cookies);
• UK and EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
• User or you: any third party that accesses the Website and is not either (i) employed by CCS and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to CCS and accessing the Website in connection with the provision of such services; and
• Website: the Website that you are currently using, either www.ccslovesomerset.org or www.somersetcarers.org and any sub-domains of this site unless expressly excluded by their own terms and conditions.
• The singular includes the plural and vice versa;
• A reference to a person includes firms, companies, government entities, trusts and partnerships;
• “Including” is understood to mean “including without limitation”;
• Reference to any statutory provision includes any modification or amendment of it;
Overall responsibility for this policy lies with the SCL Board of Directors / Trustees and its implementation with the Senior Management Team.
This policy is reviewed every two years and updated as required.