Personal Information – Privacy Notice

Your trust is important to us and we are committed to safeguarding your personal data. Pointalls Allotments Limited is a ‘data controller’.

This privacy notice lets you know what happens to any personal data you give to us or we may collect from you.

In accordance with the UK General Data Protection Regulation (UKGDPR) tailored by the Data Protection Act 2018 (DPA) we are providing you with clarity on what data we have; how we use it; why we need it and who has access to it.

We are providing this Privacy Notice because:

you are an existing member of Pointalls Allotments Limited and we are required to inform you of your rights relating to the personal information we hold
or you are making an application for an allotment and if successful will become a member of Pointalls Allotments Limited

Compliance

Pointalls Allotments Limited is categorised as a non-profit organisation and as we process only information relevant to managing the allotment site there is no requirement for us to register with the Information Commissioner’s Office.

The legal ground under UKGDPR that we rely on to process your personal data is known as ‘legitimate interests’.

As an allotment organisation the lawful basis, ‘legitimate interests’, applies as we process personal data in order to manage our site and tenancies. This is information that our organisation requires in order to undertake our role and meet the requirements of our lease with the London Borough of Barnet.

We do not collect special category or sensitive data as specified by the UKGDPR. Therefore we are not obliged to seek consent to hold data from our members or applicants for allotment plots at Pointalls Allotments Limited.

By way of this Privacy Notice we are communicating our privacy policy to both members and applicants. This Privacy Notice is posted on our website and copies are available on request. New applicants will be directed to this Privacy Notice. New tenants will be reminded of the Privacy Notice at the time of completing membership application forms and signing tenancy agreements.

Data protection principles

We comply with data protection law and principles, which means that your data will be:

used lawfully, fairly and in a transparent way
collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
relevant to the purposes we have told you about and limited only to those purposes
accurate and kept up to date
kept only as long as necessary for the purposes we have told you about
kept securely

The information we hold about you

In connection with your membership of Pointalls Allotments Limited we collect, store and use the following categories of personal information about you:

your title and full name
your postal address
your email address
your home and/or mobile telephone numbers
date of joining Pointalls Allotments Limited
if claiming seniors discount your date of birth
your rental and associated charges for your plot

How is your personal information collected?

We collect personal information about you from the following sources:

from your application form when applying for an allotment plot
when formally applying for membership of Pointalls Allotments Limited
from completed and signed tenancy agreements

How we will use personal information

We collect information in order to manage our site and tenancies. We only use your personal information for the operation of your membership and this enables us to:

send annual invoices for rental and other related charges
communicate with you by email and post
keeping in touch through regular newsletters which may include site news, important notifications and alerts, communications about our products, special offers, gardening related topics, annual general meetings and other meetings, workshops, competitions and site activities

Keeping your personal information up to date

If any of your personal information should change, such as your contact details or address you should inform us as soon as possible so that we can keep our records up to date.

How we use special category or sensitive data as specified by the GDPR

We do not request or hold data or information within this category.

Data sharing

We do not share our database or closed register of members.

Data security

Data is only accessible to those who need to use it to undertake our organisations activities.

We follow the ICO’s accountability framework (published September 2020) to minimise the risks of managing personal data by way of effective procedures and measures.

We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Members’ information is held securely in an electronic database. Appropriate tools such as firewalls are in place and antivirus software is kept up to date.

Where we use third parties, including marketing automation platforms for bulk email or postal communications we ensure that such suppliers are, as appropriate, fully certified and compliant with applicable privacy shield frameworks.

Information held on paper (hard copies) is kept safely and to a minimum with access limited to those who need to use it.

We have in place procedures to deal with any suspected data security breach (ICO guidance updated October 2020) and will notify you and the Information Commissioner’s Office of a suspected breach where we are legally required to do so.

Data retention

We only hold data as long as we reasonably need it. We will retain your personal information for as long as you are a member and tenant of Pointalls Allotments Limited. Lapsed members’ data will be held for a short retention period in accordance with the Companies Act.

For plot applicants who withdraw from our waiting list your information will be deleted immediately from our records.

Historical records and other non essential and time expired information will be routinely deleted and destroyed.

Rights of access, correction, erasure and restriction

The UKGDPR and DPA 2018 specify your rights in connection with personal information. Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact: membership@pointalls.org

Why is all of this necessary?

Pointalls Allotments Limited is legally obliged to comply with current data protection obligations both in relation to UKGDPR and DPA 2018 and the terms of the company’s lease from the London Borough of Barnet. We are required to provide you with details on the kind of information that we may be holding about you and how it is processed.

Data protection issues

If you have any questions about this privacy notice or how we handle your personal information, please contact The Company Secretary, Pointalls Allotments Limited, 215A Squires Lane, London N3 2QS. 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.

September 2021