Privacy Notice

Privacy Notice WISH

Introduction

WISH the ‘controllers’ of the information (‘personal data’) that we collect about you, our ‘data subjects’, which means we are responsible for how your data is processed. The word ‘process’ covers the things that can be done with personal data, including collection, storage, use and destruction of data.

This privacy notice explains why and how we process your personal data, and explains the rights you have, including amongst others, the right to access your data, and to object to the way it is processed. Please see the section on ‘Your rights as a data subject’ for more details on your rights and how to exercise them.

WISH is an Unincorporated Association and is known as Women in Social Housing (WISH)

Our contact details are:

Address: WISH PO Box 395, Cobham, Surrey, KT11 9EY
Email: admin@wishgb.co.uk
Telephone number: 07568 080959

If you have any queries about this notice or anything related to data protection, you can contact Katie McDonald, Finance and Memberships Manager, at PO Box 395, Cobham Surrey, KT11 9EY, admin@wishgb.co.uk or on 07568 080959.

Personal data

‘Personal data’ is any information that relates to a living, identifiable person. This will usually include your name, address, contact details, and other information we collect as part of our relationship with you.

It can also include ‘special categories’ of data, which is the official term for information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation.

The use of this type of data, and of information about criminal convictions and offences, is subject to strict legal controls.

We are committed to protecting your privacy and all of your personal data. We only process data if we need to for a specific purpose, as explained below. Most often, we collect your personal directly from you, through our contact with you.

Your data and how and why we process it

Our data processing is so we can manage and support our relationship with you, comply with legal obligations, improve our services and achieve our legitimate business aims. The information below gives more details about our purposes for processing data, and the legal basis for each type of processing.

The data we collect about you

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 you which we have grouped together:

Identity Data includes – first name, maiden name, last name, username or similar identifier, marital status, title and gender.

Contact Data includes – billing address, delivery address, email address and telephone numbers.

Transaction Data includes- details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes – internet protocol (IP) address, your login data, 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 access this website.

Profile Data includes – your username and password, your job title, your social media links, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes – information about how you use our website, products and services.

Marketing and Communications Data includes – your preferences in receiving marketing from us and our third parties 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 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. Please note we do not penalize individuals who wish to withdraw consent.

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, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services;

  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

– Automated technologies or interactions. 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our 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

Technical Data from the following parties:

(a) analytics providers, such as Google based outside the EU;

(b)  Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU such as Paypal, Go Cardless, Companies House of Duedil.

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.
  • 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.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending thirdparty direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us.

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 register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) 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 prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
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, 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 communications to you and measure or understand the effectiveness of our communications (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to provide you with information on our services and your benefots of being a WISH Member)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
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 (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time or contacting us direct.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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.

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.

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.

 

Who we share your data with

Sometimes we share the data we process with other organisations. This list explains who we share it with, and why.

Disclosures 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 above.

  • Internal Third Parties including our website providers.
  • External Third Parties including Paypal, GoCardless, Mailchimp, Eventbrite and Survey Monkey.

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.

 

How we store your data

Your personal data is held in both hard copy and electronic formats.

Electronic data, including emails, is stored on our website hosts servers which are located in the UK and our software suppliers’ servers.

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 we keep your data

Information about how long we hold your data for can be found in our data retention schedule. Please contact us for a copy.

Some of our retention periods are based on legal requirements, and others are based on the practical reasons we need to keep the data for a certain period of time.

Once we reach the retention period, we will securely delete the relevant data, unless we are legally required to keep it longer, or there are legal reasons why we should keep it longer.

Your rights as a data subject

As a data subject, you have the following rights in relation to your personal data:

  • To be informed about how your data is handled;
  • To gain access to your personal data;
  • To have errors or inaccuracies in your data changed;
  • To have your personal data erased, in limited circumstances;
  • To object to the processing of your personal data for marketing purposes or when the processing is based on the public interest or other legitimate interests;
  • To restrict the processing of your personal data, in limited circumstances;
  • To obtain a copy of some of your data in a commonly used electronic form, in limited circumstances;

Rights around how you are affected by any profiling or automated decisions.

If you wish to exercise any of these rights, or for more information about these rights, please see the ICO’s website https://ico.org.uk/ or contact: Katie McDonald, Finance and Memberships Manager, at PO Box 395, Cobham Surrey, KT11 9EY, admin@wishgb.co.uk or on 07568 080959.

Withdrawing consent

If we are relying on your consent to process your data, you may withdraw your consent at any time by contacting us.

Complaints to the Information Commissioner

You have a right to complain to the Information Commissioner’s Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/.