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

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