Table Of Contents
Welcome to Harrogate BID’s privacy notice.
Harrogate BID respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Harrogate BID collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete a survey.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Harrogate BID Limited is the controller and responsible for your personal data (collectively referred to as “Harrogate BID”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Harrogate BID Limited a company registered in England and Wales with registered company number 10747321 with its registered address at Crown Chambers, Princes Street, Harrogate, North Yorkshire, United Kingdom, HG1 1NJ
Name or title of data privacy manager: The Bid Manager
Email address: BIDManager@harrogatebid.co.uk
Postal address: Harrogate BID Limited, Crown Chambers, Princes Street, Harrogate HG1 1NJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 21 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about or relating to you as follows:
BID Data including the following:
- Organisation Name
- Property Address
- Unique Property Reference Number
- Rateable Value
- Name of Organisation Contact
- Position/ Job title
- Your feedback and survey responses
Marketing and Communications Data includes your preferences in receiving marketing from us and any third parties we mention and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your BID Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website;
- Provide us with a business card;
- request marketing to be sent to you;
- complete a survey; or
- give us some feedback.
- Cookies – we don’t capture any cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Identity and Contact Data from publicly availably sources such as Companies House based inside the EU.
- Organisation names and rateable values and incidental information provided by Harrogate Borough Council.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests or where we need to comply with a legal or regulatory obligation.
You have the right to withdraw consent to marketing at any time by contacting us or the data privacy manager whose contact details we list above.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Our main purpose is: to canvas opinion from businesses within the proposed BID area and help us (the BID Group) formulate a business plan which we will publish prior to the public ballot, setting out what a successful BID might bring to the town centre in terms of additional benefits (the “Business Plan”). Following the formation of the Business Plan, we will work to make the Business Plan a reality by working with businesses in the area and this may involve us partnering with other organisations in order to achieve this purpose.
We consider that, in light of the fact that we aren’t collecting a lot of personal data, and because the personal data that we do collect is quite limited and inherently either low risk or available publicly then we can rely on our “legitimate interests” and those of the participants, as the main legal basis under which we process your data.
There is also a legitimate societal interest in that a successful BID could lead to improving the economy of Harrogate Town Centre and the surrounding areas.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data for example:
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register your account||Necessary for both of our Legitimate interests so that we can process your survey results and inform you of the progress of the BID.|
|Formulation and carrying out the aims of the Business Plan||Necessary for both of our legitimate interests in trying to achieve the aims and objectives of the Business Plan and to generally improve or attempt to improve the economic, social and public status of Harrogate as a business district.|
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
|(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a survey||Necessary for our legitimate interests (to study your response, to develop the BID and grow our businesses and the economy of Harrogate and the surrounding area)|
|To administer and protect our business, the Business Plan and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Necessary for our legitimate interests (to develop our products/services and grow our business)|
Where you provide us with your details as part of an activity that is related to the Business Plan then we will send you certain marketing and other materials unless you opt-out specifically. We will only send you marketing that relates to the Business Plan. This might include networking or social events and will include updates relevant to the Business Plan itself.
We may share your data with third parties in order to meet the objectives of the Business Plan. Where we share your data with third parties, this will be limited to the purposes we have set out in this policy and this will not involve those third parties sending any marketing to you unless they have done so independently of the Harrogate BID in accordance with their own privacy policies.
We will not be sending you any marketing either on behalf of a third party or marketing relating to products or services that are wholly unrelated to the Business Plan.
We won’t give you details to third parties for their own marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you at any time.
Where you opt out of receiving these marketing messages, we won’t remove or suppress any of your data, we just won’t send you any more marketing.
This may not mean that you will stop receiving all emails to us, and we may still send you notices relating to changes to our policies, contracts or your legal rights.
We don’t capture any cookies.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it (i.e. to produce the Business Plan), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Third Party Partners acting as contractors to Harrogate BID under our explicit instructions.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and in any event no longer than 6 years.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For details of retention periods for different aspects of your personal data you can contact us.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to produce the Business Plan and to actually carry it out and further its aims and objectives. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests and the legitimate interests of anyone else. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
- Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
- Mosaic Futures Ltd (registered company number 06029848 whose registered address is at Moor Farm Prestons Lane, Coleorton, Coalville, Leicestershire, LE67 8FR) who we have engaged as consultants to Harrogate BID.
- Meercat Associates Limited (registered company number 06156522, whose registered office is at Meadowcroft House, 182 Balcombe Road, Horley, Surrey RH6 9ER) who we have engaged as consultants to further the aims of the Business Plan.
- Halo HR Limited (registered company number 08485419 whose registered office is at Progeny House, 46 Park Place, Leeds LS1 2RY) who we have engaged as consultants to provide HR services to Harrogate BID.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based
- in the United Kingdom who require reporting of processing activities in certain circumstances.
- Government departments who administrate or otherwise govern the BID process and for whom we are preparing the Business Plan.
YOUR LEGAL RIGHTS
You 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.