Community Information Technology Ltd (Trading as Tiree Broadband)
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the UK General Data Protection Regulation 2016/679 (the GDPR). The EU GDPR was incorporated into the UK Data Protection Act and its regulations continue to apply post-Brexit. Examples of Personal Data include:
- Your email address
- Telephone number
- IP Address
Who are we?
TCDT is the data controller (contact details below). Community Information Technology Ltd (Trading as Tiree Broadband) is a subsidiary of TCDT. This means we that we process your personal data in accordance with the TCDT data processing policy. (Included below)
The basis which specifically applies to Community Information Technology Ltd (TA Tiree Broadband) is that of Processing data for the performance of a contract.
How we process payments
We process payments using a Third-Party Payment Processor called GoCardless. GoCardless handle payments on our behalf. When you set up your Direct Debit, you enter into an agreement with GoCardless in relation to your data. Community Information Technology Ltd (TA Tiree Broadband) does not process your payment information and does not have access to your bank details. You can read the GoCardless Privacy and Data Policies here. GoCardless complies with the requirements of the GDPR.
How does TCDT process your personal data?
- TCDT complies with its obligations under [the UK GDPR] by keeping personal data up to date
- by storing and destroying it securely; by not collecting or retaining excessive amounts of data
- by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the following purposes:
- To enable us to provide a voluntary service for the benefit of the community as specified in our constitution
- To administer membership records
- To fundraise and promote the interests of the charity
- To manage our employees and volunteers
- To maintain our own accounts and records
- To operate the TCDT website and deliver the services that individuals have requested
- To inform individuals of news, events, activities or services running at TCDT
- To process gift aid applications
- To contact individuals via surveys to conduct research about their opinions of current issues, services or of potential new services that may be offered
What is the legal basis for processing your personal data?
As per Article 6 of the UK DPA (2018) There are different types of basis for processing personal data. The legal bases for TCDT data processing are below.
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
- Employment Contracts
- Contractor Contracts
- Tiree Broadband Subscribers Contract (CIT Ltd)
- Mooring or Berthing Contract (TCMAL Ltd)
- Friends of Nadair Thiriodh (part of Tiree Ranger Service)
- Processing is necessary for compliance with a legal obligation
- OSCR requires that we “Keep registers of charity trustees and of members “
- Processing is necessary for the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject
- The TCDT Constitution states ” The Directors shall maintain a register of members, setting out the full name and address of each member, the date on which he/she was admitted to membership, and the date on which any person ceased to be a member.”
- Grant Funding reporting and monitoring requirements may require that the Grantee must keep and maintain for a period of 6 years adequate and proper records and books of account
TCDT does not process or hold any Special Categories of Personal Data as per Article 9.
Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with other
organisations to comply with a legitimate interest or a legal obligation i.e. OSCR or funders.
We will only share your data with third parties outside of the organisation with your consent.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 6 years in order to comply with our statutory and funding obligations.
Your rights and your personal data
Unless subject to an exemption [under the UK GDPR], you have the following rights with respect to your personal data:
- The right to request a copy of your personal data which TCDT holds about you
- The right to request that the TCDT corrects any personal data if it is found to be inaccurate or out of date
- The right to request your personal data is erased where it is no longer necessary for TCDT to retain such data
- The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable)
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- The right to object to the processing of personal data, (where applicable)
- The right to lodge a complaint with the Information Commissioners Office (ICO)
Transfer of Data Abroad.
If the personal data is to be transferred to countries or territories outside the EU you must include details of how the data will be protected, together with details of how to obtain copies of the relevant safeguards].
If we wish to use your personal data for a new purpose, not covered by this UK Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
Where and whenever necessary, we will seek your prior consent to the new processing.