CROW Recycling Data Policy

1 Customers and Scrapstore members have contracted and consented with CROW to use our services or access our facilities.

2 Customers and Scrapstore members will have a signed copy of the Annual Contract as will CROW.

3 Data relating to persons accessing CROW be they employees, volunteer work placements, school/college students will also be kept in offices secured at night, weekends and holiday closures.

4 To withdraw from the contract customers/members are required to contact CROW in writing.

5 Data relating to a company/organisation is used only for the provision of service to your company/organisation.

6 Data is only shared as follows

  • when we are legally obliged to

  • with an e mail marketing platform when you sign up to a consent based e mail marketing campaign

  • when you join the Scrapstore your data is shared with our customer relationship management platform. See our privacy policy below for more details about how we use Scrapstore members’ data

7 Data is kept in offices locked at night/weekends/holiday closures.

8 Documents/papers for confidential shredding and disposal are kept in a locked area at night/weekends and holiday closures.

9 Every effort is made to ensure that your data is secure at our premises.

10 Data will only be kept as long as is necessary for the purpose for which it was collected. For more details see our personal data retention policy below.

11 People have a right to complain to the Information Commissioner’s Office if they feel their data has been mishandled.

CROW Recycling Privacy Policy

Who we are

CROW Recycling, Sparkbrook Street, Hillfields, Coventry, CV1 5LB

The information we collect

We collect names of individuals and organisations, e mail addresses, postal addresses, website cookie data and next of kin details for those on work experience. We also collect bank account details.

Most of the personal information is provided directly by customers, employers, volunteers or people signing up to e mail marketing campaigns for the following reasons.

Reasons for processing personal data

We collect names, postal addresses and e mails to administer the services we provide collecting waste paper and used drinks cans.

We collect names, names of schools and colleges and next of kin details for staff and volunteer administration including administration for people on work experience.

Financial details such as bank account numbers are collected to make payments to employees and suppliers.

We also collect e mail addresses and names to administer educational visits.

We collect e mail addresses for marketing and promotions including opt in e mail marketing campaigns

Names, postal addresses and e mail addresses are collected for processing Scrapstore membership applications including sending out membership cards and renewal reminders.

We collect cookie preferences for website visitors. The cookie records whether they have consented to cookies or not.

The lawful bases we use for processing information

The GDPR sets out a number of lawful bases for processing information. These are the ones that apply to CROW Recycling.

Contractual

The processing of customer information, staff and volunteer information including people on work experience and the processing of Scrapstore membership applications

Consent

The e mail addresses used for opt in e mail marketing campaigns are processed on the basis of consent. People can withdraw that consent at any time.

A website cookie processes information from our website users who consent.

Legitimate interests

This applies to a small amount of our marketing and promotions. This is when we send unsolicited e mails to schools and colleges which may be interested in educational visits or work experience. From time to time we also e mail organisations which may be interested in buying animal bedding from us.

Who we share information with

From time to time we use e mail marketing platforms to publicise our educational visits and work experience. People who consent to sign up to our e mail marketing campaigns are asked to consent to information being shared with the e mail marketing platform we are using. They can withdraw that consent at any time.

Scrapstore members Scrapstore members have their names, organisations if they have one and e mail addresses stored in a customer relationship management system. This allows us to quickly and easily communicate contractual information such as holiday shutdowns and Saturday openings. It also allows us to send e mail newsletters to those who opt in to them.

We only use customer relationship management systems which comply with the Privacy Shield Framework providing a level of privacy and security in line with the UK Data Protection Act. Scrapstore members who don’t want their data shared in this way should let us know in writing and we will delete their information from the system.

We also share information about customers, volunteers and staff when we are legally obliged to.

Transfer of data outside the UK

Those subscribing to the opt in e mail marketing campaigns have their data stored outside the UK in the USA. We only use e mail marketing platforms which provide an adequate level of protection in line with the UK Data Protection Act by compliance with the Privacy Shield Framework.

Scrapstore members have their names, organisations if they have one and e mail addresses stored in a customer relationship management system which stores their data in data centres outside the UK in locations worldwide. As with e mail marketing platforms we only use customer relationship systems which provide an adequate level of protection in line with UK Data Protection Act by compliance with the Privacy Shield Framework.

Retention periods for personal data

We will only keep your data as long as we need to for the purpose it was collected for. Please see our personal data retention policy for more information.

Rights for individuals in relation to the data processing

People have the right to see the personal data Crow Recycling holds about them. Contact Crow Recycling on 02476552444 or crow@talktalkbusiness.net to make a subject access request to see the data.

There is a right to ask CROW to correct information which is incorrect and complete information which is incomplete.

If we are processing data on the basis of consent there is a right to withdraw consent.

CROW has one month to respond to a request. Contact CROW Recycling at Orchard House, Sparkbrook Street, Coventry, CV1 5LB on 02476552444 e mail crow@talktalkbusiness.net.

The right to make a complaint

Complaints can be made to the UK data commissioner

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, 03031231113 www.ico.org.ukcro

CROW Recycling personal data retention policy

Background

General Data Protection Regulations, which are law at the moment, say personal data should not be stored for longer than needed for the purpose for which it was collected.

Personal data is anything with people’s names, personal e mail addresses, addresses, job titles or telephone numbers.

Which personal data do we hold

Invoices sometimes have a name and personal contact e mail on them

e mails – many of these are from personal e mail addresses

volunteer records

employment records

trustee meeting documents including minutes, agendas and reports

staff meeting documents

photographs of people

Names, addresses and e mail addresses of Scrapstore members

Retention periods

Employment records – six years after someone has left. This is because it is possible to bring a case in civil courts for discrimination at work up to six years after leaving a job.

Volunteer records – six years in line with employment records

Records of unsuccessful candidates – six months because this is the time limit for bringing a discrimination claim

Staff meeting minutes Three years

Trustee meeting minutes – permanent

Other trustee meeting documents – three years

Invoices – six years after the end of the financial year they were raised in line with guidance on retention of accounting information

Scrapstore membership forms – during the membership and no more than a year after membership has lapsed and not been renewed

Customer information names and contact numbers on the Sage database three years after the last order

General e mails enquiries about the Scrapstore, cans and paper and other general e mails – one year