Privacy Policy

The Romney Marsh Community Hub is committed to ensuring your privacy is protected.

How we use your information

The Romney Marsh Community Hub is committed to ensuring your privacy is protected. This Privacy Notice explains how we collect information about you and how we process this information. RMCH takes its obligations with regard to your personal information seriously.

Your personal data will be collected by RMCH who will act as the “Data Controller”. A Data Controller determines the purposes and means of processing personal data.

The types of information RMCH processes

The types of personal data which can be collected includes:

• Name
• Address
• National Identity (Passport Numbers)
• Telephone Numbers
• Email
• Online Identifiers (e.g. Facebook IDs.)
• 3rd Party Cookie Identifiers
• Bank or Card Details
• Website pages viewed and emails opened and clicked

The types of special categories of data collected includes:

• Biometrics for identification (e.g. photographs, CCTV images)
• Medical Information
• Gender

The purpose and legal basis of processing personal data

RMCH will collect your personal information for specific purposes under a number of lawful methods of processing.

RMCH will process personal information:

• for the purposes of direct marketing under opt-in consent, e.g. marketing services we provide and updating;
• gathering visitor data to our website under opt-in consent;
• for the purposes of research and surveys based upon opt-in consent;
• to provision internet services to you around the facilities under contract;
• for the purpose of purchasing RMCH products or services under contract and associated information required in the fulfilment of that transaction and for communications regarding future similar transactions with the business;
• for the purpose of purchases of third party services under contract;
• to offer related information on products and services you have taken under soft-opt-in legitimate interest of the business;
• to enable request for information, making enquiries, reports or complaints under the legitimate interest of the business;

Where your consent has been sought, you have the right to withdraw your consent at any time.

Your personal data rights

RMCH will respect all of your data subject rights. If we do hold information about you, we will:

• authenticate you as the data subject;
• determine if a right can be administered;
• complete your request within 30 days; and
• communicate to you in clear and intelligible language.

These rights include, but are not limited to:

The Right of Access: at any time, you can ask for a copy of your personal information. RMCH will respond with whether data is held or not. If data is held then a copy of the information and the required supplement notice will be offered to you.

Right of Rectification: allows you to submit changes to your records and once changes are verified, they will be amended on RMCH records. Similarly, RMCH will periodically request you to check your data is held accurately.

Right of Erasure: if you request your data to be erased, and there is no other lawful basis to keep your data, then it will be removed.

If you would like to exercise your data subject rights including your right of access, rectification, erasure, restriction, or objection to processing, please contact the Data Protection Officer - contact details are contained within this notice.

Retention periods

All personal data collected under contract or legitimate interest will be held for a period of 3 years from your last interaction with the business, or it will be removed if no other lawful method of holding your data can be determined, e.g. UK finance law.

Data collected under consent will be used until consent is withdrawn or if it is no longer useful for the purpose for which it was collected. Some data may not be removed if it involves a disproportionate effort e.g. a website image of you is held by the Google search engine.

This does not affect your rights as a data subject.

Please note: after this retention period has expired, RMCH will be unable to reinstate the original data, assuming the data was held in the first instance.

Failing to provide necessary personal data

Failing to provide some or all the necessary personal data may result in:

• being unable send or receive a product or service;
• not being able to access data services;
• not receiving related news, updates, offers or notices of events.

Sharing personal data

RMCH will share your personal data with other organisations in order to supply services to you.

If RMCH shares your data on a regular basis it will perform due-diligence and hold written contracts and agreements with these organisations to legally safeguard your data.

If you have consented for us to share your data with other organisations for the purposes of direct marketing, we will keep your consent on record until it is withdrawn or the purpose of holding your data is no longer valid. On deletion of your data, RMCH will endeavour to contact you to confirm that your information has been removed.

Transfer to international countries

Your data may be transferred internationally. If your data is transferred, RMCH will legally safeguard your personal data by:

• transferring to the EEA countries (Members of the European Economic Area).
• transferring to an EU Adequate country, which are defined as countries outside the EU that offer adequate levels of data protection.
• transferring under “EU Model Clauses” agreement with the importing party. These are standardised contractual clauses that make specific guarantees around the transfer of personal data from EEA countries to the rest of the world.

Owing to the global nature of the internet infrastructure, the information you provide may be transferred in transit to countries outside the European Economic Area that do not have similar protections in place regarding the protection of your personal data. Where this is the case, end-to-end encryption will be employed to transmit the data securely. e.g. using industry standard data encryption (SSL or TLS) to connect to websites or using email encryption technologies.

Where RMCH is unable to utilise legal safeguards when transferring data to a third-country, RMCH will seek consent from you to facilitate the data transfer.

Information security

• Transmission: where personal data is electronically transmitted from one computing device to another over a public network an encrypted path will be used e.g. SSL. If your data is transmitted in a hard-copy format from one place to another a secure or locked method of transport will be used, suitable to the nature of the personal data.
• Storage: personal electronic records are located on servers in secure premises. If your data is required to be stored outside of the secure premises, the data will be in an encrypted format. Personal paper-based records will be stored in a locked filing cabinet in secure offices to prevent inadvertent access by unauthorised 3rd parties.
• Access: only personnel authorised by RMCH will have access to your personal data records on a need to know basis.
• Disclosure of personal data: we do not disclose personal data unless we’re required to do so to comply with the law, under contract, have your consent, or if it is in your vital interest.

Privacy and cookies

What are cookies?

Cookies are small text files which are stored on your computer when you visit certain web pages. At RMCH, we use cookies to understand how our sites are used which helps us to improve your overall online experience. Some of the cookies we use are necessary for some of our sites to work whilst other cookies are used to provide tailored advertising by trusted third parties. The cookies we and our third parties place on your computer do not collect personally identifiable information like your name, address or payment details. To find out more about cookies, visit aboutcookies.org.

The privacy of your information is important to us and we want to keep you well informed about cookies. We shall continue to work on initiatives in relation to recent cookie legislation to ensure you have the best experience when visiting our website.

The different types of cookies we use

RMCH use the following categories of cookies on our websites:

Strictly necessary – these cookies are essential for certain features of our websites to work. These cookies do not record identifiable personal information and we do not need your consent to place these cookies on your device. Without these cookies some services you have asked for cannot be provided.

Performance – these cookies are used to collect anonymous information about how you use our websites. This information is used to help us improve our websites and understand how effective our adverts are. In some cases we use trusted third parties to collect this information for us but they only use the information for the purposes explained. By using our websites, you agree that we can place these types of cookies on your device.

Functionality – these cookies are used to provide services or remember settings to enhance your visit e.g. text size or other preferences. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites. By using our websites, you agree that we can place these types of cookies on your device.

Targeting and advertising – these cookies are used by trusted third parties to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. Information contained in these cookies is anonymous and does not contain your personal information. To find out more about cookies used for targeting and advertising go to youronlinechoices.com and networkadvertising.org or contact us on our feedback page for further information about the trusted third parties we use.

Managing cookies

If you would prefer to restrict, block or delete cookies from RMCH and our third party advertisers, or any other website, you can use your browser to do this. Each browser is different so check the 'Help' menu of your particular browser to learn how to change your cookie preferences. If you choose to disable all cookies we cannot guarantee the performance of our websites and some features may not work as expected.

Automated decision making and profiling

The information you provided to RMCH will be provisioned on to the RMCH database. RMCH systems may from time to time rely on automated decisions and perform online profiling. This does not affect your rights as a data subject.

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Changes to this privacy notice

We keep our privacy notice under regular review and we will place any updates on this webpage. At the start of this privacy notice, we will tell you when it was last updated.

This privacy notice does not provide exhaustive detail of all aspects of RMCH ’s collection and use of personal information, however, please contact us if you require further detail and we will be happy to provide any additional information or explanation needed.

Complaints and queries

RMCH tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this seriously. We encourage people to bring it to our attention if they think our collection or use of personal information is unfair, misleading or inappropriate.

To make a request to RMCH for any personal information we may hold you need to put a request in writing using the address below:

PDQ Data Protection Officer
Romney Marsh Community Hub
Sunflower House
Rolfe Lane
New Romney
Kent
TN28 8JR

Tel: 01797 363888

You have the right of redress and you are welcome to contact the Information Commissioners Office, please see: ico.org.uk/make-a-complaint/ or call the ICO on 0303 123 1113.