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Your Privacy – updated in line with GDPR

Welcome to the Chatham Maritime Trust privacy notice, which sets out how we comply with the General Data Protection Regulation (GDPR), which will apply in the United Kingdom from 25 May 2018.

1. Important information and who we are

Purpose of this privacy notice

The privacy and security of your personal data is extremely important to us. This privacy notice explains how and why we use your personal data in the delivery of our charitable activities, to make sure you stay informed and can be confident about giving us your data, and tell you about your privacy rights and how the law protects you.

  • We will never sell your personal data and will only share it with organisations we work with when it is necessary and the privacy and security of your data is assured.
  • We will never buy personal data from third parties.

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.

Controller – who we are

The Data Controller, including our website (www.cmtrust.co.uk), is Chatham Maritime Trust of East Wing, Ground Floor, The Observatory, Brunel, Dock Road, Chatham Maritime, Kent ME4 4AF. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at info@cmtrust.co.uk or please write to us at Chatham Maritime Trust, East Wing, Ground Floor, The Observatory, Brunel, Dock Road, Chatham Maritime, Kent ME4 4AF.

We are registered with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), under registration reference Z4934686, which is renewed annually on 28 August. You have the right to make a complaint to the ICO at any time about the way your personal data is managed by us, either via their website at www.ico.org.uk/for-the-public or by calling their help line 0303 123 1113 or in writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

However, we should appreciate the chance to address any concerns you may have before you approach the ICO, so please contact us in the first instance, as above.

Changes to the privacy notice and your duty to inform us of changes

This version of our privacy notice was last updated on 23/05/2018. 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.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name and family name. If you are a trustee or employee of Chatham Maritime Trust this will also include two documentary forms of identification, one of which must be photographic identification.
  • Contact Data includes postal address, email address and land line and/or mobile telephone numbers. If you are a trustee or employee of Chatham Maritime Trust this will also include contact data for you next-of-kin.
  • Financial Data includes payment information such as credit or debit card or direct debit details
  • Technical Data includes internet protocol (IP) address browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to contact us by email or to access our website.
  • Communications Data includes your communication preferences.
  • Contractual Data includes any information we may collect in the course of pre-contractual discussions with you, including unsuccessful tender enquiries, and any information we may collect in the provision of our services to you, including advice and guidance on alterations to domestic or commercial properties situated on the Chatham Maritime Estate.
  • CCTV and ANPR Images includes any photographic images we may record in the process of carrying out surveillance of public spaces across the Chatham Maritime Estate via closed circuit television cameras and Automatic Number Plate Recognition image processing technology. These images are captured for crime prevention, detection, apprehension and prosecution of offenders, and maintaining the safety of members of the public, staff and visitors.

We also collect and use Aggregated Data such as statistical or demographic data for internal purposes.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an answer to an enquiry). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Identity Data, Contact Data, Financial Data, Communications Data and Contractual Data by providing it to our staff in meetings, filling in forms or by corresponding with us by phone, email, post, fax or SMS. This includes personal data you provide when you:

  • complete a contact details form
  • complete a direct debit mandate form
  • enter into a contract with us
  • volunteer it to us in the course of using our services;
  • submit an enquiry; or
  • request our newsletter to be sent to you.

Automated technologies or interactions.

  • When you visit public areas of the Chatham Maritime Estate your images may be recorded by our closed circuit television monitoring equipment.
  •  As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see www.cmtrust.co.uk/use-of-cookies for further details.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Identity Data, Contact Data, Financial Data, Communications Data and Contractual Data by providing it to our staff in meetings, filling in forms or by corresponding with us by phone, email, post, fax or SMS. This includes personal data you provide when you:

  • complete a contact details form
  • complete a direct debit mandate form
  • enter into a contract with us
  • volunteer it to us in the course of using our services;
  • submit an enquiry; or
  • request our newsletter to be sent to you.

Automated technologies or interactions.

  • When you visit public areas of the Chatham Maritime Estate your images may be recorded by our closed circuit television monitoring equipment.
  •  As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see www.cmtrust.co.uk/use-of-cookies for further details.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you;
  • to make contact with you for the first time (for example, where you have made an enquiry to our offices);
  • 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; and
  • where we need to comply with a legal or regulatory obligation.
    recruitment and employment, including appointment of trustees

In order to comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including ‘sensitive’ personal data, from job applicants and employees.

Such data can include, but is not limited to, information relating to health, racial or ethnic origin, and criminal convictions. In certain circumstances, we may process personal data or sensitive personal data, without explicit consent. Further information on what data is collected and why it is processed is given below.

  • Contractual responsibilities: Our contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll, bank account, postal address, sick pay; leave, maternity pay, pension and emergency contacts.
  • Statutory responsibilities: Our statutory responsibilities are those imposed through law on the organisation as an employer. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax, national insurance, statutory sick pay, statutory maternity pay, family leave, work permits, equal opportunities monitoring.
  • Management responsibilities: Our management responsibilities are those necessary for the organisational functioning of the organisation. The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment, training and development, absence, disciplinary matters, e-mail address and telephone number.
  • CCTV is used to provide security and protect residents, businesses, the universities and visitors and the public spaces and public realm assets on the Chatham Maritime Estate. CCTV images will only be viewed when necessary (e.g. to detect or prevent crime) and footage is stored for one month after which it is recorded over.  Chatham Maritime Trust complies with the Information Commissioner’s Office CCTV Code of Practice and we put up notices so you know when and where CCTV equipment in use.

Generally, we do not rely on consent as a legal basis for processing your personal data other than when you sign up to our newsletter. You have the right to withdraw your consent to this at any time by contacting the us at info@cmtrust.co.uk .

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.

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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity

Type of Data

Lawful basis for processing including basis of legitimate interest

To provide our estate management services to you

(a) Identity
(b) Contractual

Performance of a contract with you

To procure goods and services from you

(a) Identity
(b) Contractual

Performance of a contract with you

To appoint you as a trustee or to employ you

(a) Identity
(b) Contractual

Performance of a contract with you

To provide closed circuit television monitoring services

(a) CCTV Images
(b) ANPR Images

(a) Necessary for our legitimate interests (for the security of public spaces and public realm assets across the Chatham Maritime Estate)

(b) Necessary in the public interest

To respond to your enquiry submitted at one of our offices or via phone, email, post, SMS or via the website

(a) Identity
(b) Contact
(c) Contractual

(a) Performance of a contract with you; or

(b) Necessary for our legitimate interests (where you have made contact with us prior to entering into a contractual relationship with us.)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security or to prevent fraud)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website

(a) Technical

Necessary for our legitimate interests (to keep our website updated)

Marketing

We only use your information for marketing purposes where you have given us your express consent and only for the purpose for which the consent was given.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.cmtrust.co.uk/use-of-cookies for further details.

Change of purpose

We will only use your personal data for the purposes for which we collected it, 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 on info@cmtrust.co.uk.

5. Disclosure of your personal data

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:

  • External third parties for the purpose of maintaining security across Chatham Maritime Estate Those parties are:
  • Ward Security Limited, our private security contractor;
  • Kent Police, to facilitate neighbourhood policing, crime and accident investigation or comply with a legal or regulatory obligation;
  • PCN UK Parking, to facilitate site wide parking control; and
  • Driving and Vehicle Licensing Authority (DVLA)

We may from time to time need to share your personal data with other authorised contractors working on the Chatham Maritime Estate where it is necessary for our legitimate interests.

  • Where you have instructed professional advisers in connection with the purchase or sale of a property or the acquisition or disposal of an interest in property (for example a commercial lease) on the Chatham Maritime Estate, we may need to share your personal data with your professional advisers in order to respond to their queries or requests for information.

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.

6. International Transfers

Neither of the external third parties listed above are based outside the European Economic Area (“EEA”) so their processing of your personal data will not involve the transfer of data outside the EEA.

7. Data Security

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.

Payment Card Security

Chatham Maritime Trust has an active PCI-DSS (Payment Card Industry Data Security Standards) compliance programme in place. This is the international standard for safe card payment processes. As part of our compliance to this very stringent standard, we ensure that our IT systems do not directly collect or store payment card information; for example the full 16 digit number on the front of the card or the security code on the back.

8. Data retention – 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.

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.

In most circumstances we will keep your personal data for up to six years after your relationship with Chatham Maritime Trust ends, unless we are required to keep it longer to comply with a legal or regulatory obligation.

Closed circuit television recordings are kept for one month before being recorded over.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. For more information on Your Legal Rights, please see section 10 below.

  • 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 at info@cmtrust.co.uk

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.

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.

10. Glossary of Terms

Lawful basis

Legitimate Interest means the interest of our organisation in conducting and delivering our charitable activities across the Chatham Maritime Estate. 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. 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 a 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.

Public Interest means the interest of our business in protecting public spaces and public realm assets across the Chatham Maritime Estate

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.

 Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on our website (www.cmtrust.co.uk).

 Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us at info@cmtrust.co.uk

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