Islay Energy Community Benefit Society
Privacy Policy- Reviewed March 2020
This Privacy Policy applies to information that we, Islay Energy Community Benefit Society (IECBS), collect about individuals who interact with our organisation. It explains what personal information we collect and how we use it.
If you have any comments or questions about this notice, feel free to contact us at info@islayenergycbs.co.uk
1.1 Personal data (Members/Shareholders/Members of Public)
The following table explains the types of data we may collect and the legal basis, under current data protection legislation, on which this data is processed.
| Purpose | Data (key elements) | Basis |
| Enquiring about our organisation and its work | Name, email, message | Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect. |
| Subscribing to email updates about our work | Name, email | Consent – you have given your active consent. |
| Signing up as a shareholder and making an investment | Name, email, address, payment information | Contract – by applying to be an investor you have entered into a contractual relationship with us as set out in our offer documents. |
| Website functionality | Website activity collected through cookies | Legitimate interests – it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality. |
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1.2 Directors and Office Bearers – personal data
If you become a Board Director or Office Bearer your name will be published on our website and further details (age and links to other companies) will be published on the Mutuals Public Register. Furthermore your details will be passed to the Auditors, currently Wylie & Bissett. Here is a link to their Privacy Policy:-
We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this policy.
For example, we may use your personal information to:
- reply to enquiries you send to us;
- handle investments, issue share certificates and interest payments or other transactions that you initiate;
3 When we share your data
Note that the only times we would share data is when we are bound to report to HMRC and when our Annual Accounts are audited. Our underlying policy is that we will only pass your data to third parties in the following circumstances:
- you have provided your explicit consent for us to pass data to a named third party;
- we are required by law to share your data.
IECBS uses a third party, the Islay Energy Trust (IET) for administrative purposes and to oversee the running of the Community Benefit Fund. IET acts as a processor of personal information on our behalf and is subject to written contractual conditions to process that information only under our instructions and to protect it. Their Privacy Policy may be viewed by contacting IET on the following link:- https://www.islayenergytrust.org.uk/contact
4 How long we keep your data
We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.
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5 Rights you have over your data
You have a range of rights over your data, which include the following:-
● You have the right to ask for rectification of your information
- You have the right of access to your information
- You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed
A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.
6 How your personal information is protected
Your personal information is stored on password secured laptops and servers based in the UK and is accessed by Directors of IECBS and one employee of IET.
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.
Where cookies are used to collect personal data, we list these purposes in Section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information, but that do help us collect anonymous information about how people use our website. For this purpose we use WordPress and their Cookie Policy (which refs their privacy policy) is at https://automattic.com/cookies/
Islay Energy Community Benefit Society 