Beat the Cold Privacy Notice
Charitable Incorporated Organisation April 2018
Registration No: 1159027

Beat the Cold respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Beat the Cold collects and processes your personal data, whether this is provided through our website, by telephone, in person or by any other means of data collection.

Where we collect personal data relating to children (for example, as part of a health scheme), we will comply with our enhanced obligations under the General Data Protection Regulation (EU) 2016/679). This will include compliance with the data protection principles, with fairness always being central to our processing activities.

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

Beat the Cold is the controller and responsible for your personal data (collectively referred to as “we”, “us”, or “our” in this privacy notice)

Data Privacy Manager – we have appointed our Services & Operations Manager to this role. They are responsible for overseeing questions in relation to this privacy notice.

Data Protection Officer – we have appointed a designated trustee of Beat the Cold to this role. They are responsible for monitoring compliance with GDPR and other data protection laws, our data protection policies, awareness-raising, training and audits.

Contact details

Beat the Cold. Charitable Incorporated Organisation.

Data Privacy Manager: Services & Operations Manager
Data Protection Officer: Designated Trustee

Email address: enquiries@beatcold.org.uk

Postal address: Beat the Cold. The Bridge Centre, Birches Head, Stoke on Trent. ST2 8DD

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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

This privacy notice was last updated in August 2018 and can be accessed through our website at any time at www.beatcold.org.uk/privacy-notice.

We may update this privacy from time to time. When we do so, the updated version will be uploaded to our website (and where appropriate and having regard to your marketing preferences (if any) we will notify our customers, suppliers and mailing list of this by email.

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 from time to time 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 theses third-party websites and are not responsible for their privacy statement. When you leave our website, we encourage you to read the privacy notice of every website you visit.

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 as follows:

Identity data includes first name, maiden name, last name, marital status, title, date of birth and gender.
Contact data includes billing address, service delivery address, email address and telephone numbers.
Financial data includes household income and benefits information.
Health condition data includes information on illnesses and disabilities.
Lifestyle data includes household resident situation (for example, number of residents working over 20 hours, number of residents working under 20 hours etc)
Transaction data includes details about payments to and from you and other details of products
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 our website.
Usage data include information about how you use our website, products and services.

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 information about criminal convictions and offences. We may however collect Special Categories of Personal Data about you (includes details about your race or ethnicity, or information about your health (Health condition data), but only if we have received your prior express consent to do so.

If you fail to provide personal data

Where we need to collect personal data by law, or under 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.

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 filing in forms or by corresponding with us by post, telephone, email or otherwise. This include personal data you provide when you:

Apply for our products or services
Apply for funding in relation to our products or services
Subscribe to our service or publications
Request marketing to be sent to you
Enter a competition, promotion or survey
Give us 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 and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources:

Contact, financial and transaction data from providers of technical, funding, payment and delivery services.
Installer generated measures referrals.
Local authority or housing company generated measures referrals.
Housing agencies and other public and private agencies that we may receive referrals from.

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 :

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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 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 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.
Consent means where you have provided us with prior, express consent.

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.

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 in the table below.

Table 1

Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
To register you as a customer
a) Identity
b) Contact
Consent
To process and deliver our services
a) Installing energy efficiency measures
b) Delivery of benefits advice
a) Identity
b) Contact
c) Financial
d) Health condition
e) Transaction
Consent
To manage our relationship with you which will include:
a) Contractor quality assurance inspections
b) Asking you to provide feedback or take a survey
a) Identity
b) Contact
c) Transaction
Consent

To offer new energy efficiency measures of services that may become available in the future
a) Identity
b) Contact
c) Usage
d) Technical
Consent
To use data analytics to improve our website, customer relationships and experiences
a) Technical
b) Usage
Necessary for our legitimate interests to keep our website updated and relevant

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 and usage 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 and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of Beat the Cold for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us
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

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We may from time to time use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They are allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited ad the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parities for this purpose.

Please note that third parties (including for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies,over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

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 prior knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your personal data

We may have to share your personal data with the parties set out below for the purpose set out in table 1 above (purposes of processing).

Funding partners who provide full or partial payment for delivery of our goods and services
Contractors who we may engage to supply our goods and services. We will ensure that those contractors are bound by terms and conditions ensuring the safety and security of your personal data, as set out in this privacy notice.
Service providers based in the United Kingdom who provide IT and system administration services.
Professional advisers including lawyers, banker, auditors and insurers based in the Untied Kingdom who provide consultancy, banking,legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

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.

If you require any further information regarding this third parties, please contact us.

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 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 legally required to do so. (Personal data security breach log appendix 1)

Data retention

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.

Beat the Cold’s (BtC) (Data retention policy appendix 2) sets the required periods for specified categories of personal data and sets out the minimum standards to be applied when destroying certain information within BtC.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as “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 to 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 enable 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 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 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.

Fees
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 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take 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.