Sir Malcolm Stewart Bart General Charitable Trust 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 when you visit our website (regardless of where you visit it from) 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 Sir Malcolm Stewart Bart General Charitable Trust collects and processes your personal data through your use of this website, including any data you may provide through this website or when you contact us.

This website is not intended for children and we do not knowingly collect data relating to children.

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.  These include information such as your name, address, telephone number, date of birth, national insurance number and next of kin details.  This policy will explain how we collect, process, manage and store your details when applying for a bungalow at the Sir Malcolm Stewart Homes, Stewartby, Bedford as a beneficiary of the Trust as a former employee of the London Brick Company, and on becoming a resident either as a beneficiary or an owner/occupier when purchasing a bungalow.

CONTROLLER

This privacy notice is issued on behalf of the Sir Malcolm Stewart Bart General Charitable Trust. When we mention "Sir Malcolm Stewart Bart General Charitable Trust", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Sir Malcolm Stewart Bart General Charitable Trust responsible for processing your data. Sir Malcolm Stewart Bart General Charitable Trust is the controller and responsible for this website.

We have appointed a data protection manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice please contact the DPM using the details set out below.

Beneficiary Application Form

 It is part of the Trustees’ responsibilities to ensure that applicants for the Sir Malcolm Stewart Homes are suitably qualified under the terms of the charity’s governing instrument.  By completing and signing the Application Form you agree to the Trustees investigating your personal circumstances.  Information collected from you via the Application Form is held confidentially by the Bursar to the Trust at The Trust Office and will not be made available to third parties.  The information contained in the Application Form is kept private and stored securely.  Periodically the Bursar will write to you to update the information held.

 Residents’ Census Form for Beneficiaries and Owner Occupiers

 On being allocated a bungalow or purchasing a bungalow further information is collected from you via the Census Form.  This will include your national insurance number and your next of kin details.  All information contained in the Census Form is held confidentially by the Bursar at The Trust Office.

 The national insurance number is required for submission to the TV Licensing as verification of your details to allow you to be added to the concessionary TV license the Trust has for the bungalows.

 We hold next of kin details for use in an emergency such as sudden illness or after a fall.

 Wardens

 Information from the Census Form such as your name, date of birth and next of kin details are provided to the resident Wardens to enable them to get the appropriate help on your behalf and notify your next of kin in cases of emergency.

CONTACT DETAILS

Email address: GDPR@smshomes.co.uk 

Changes to the privacy notice

This version was last updated on 25 April 2023.

THIRD-PARTY LINKS

This website may 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 these third-party websites and are not responsible for their privacy statements. 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).

Please note, calls to or from Sir Malcolm Stewart Bart General Charitable Trust may be recorded for training and monitoring purposes.

Where relevant we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

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

• Financial Data includes bank account and payment card details.

• 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, 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 do not collect the following Special Categories of Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships information about your health and genetic and biometric data). Nor do we collect information about criminal convictions and offences.

IF YOU Decline 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

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions by filling in forms or by corresponding with us by post, phone, email or otherwise. 

This includes personal data you provide when you:

• register your interest in one of our developments via the website;

• register your interest in one of our developments via the phone;

• subscribe to marketing communications or publications;

• attend an event

• 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 and other similar technologies. Please see our cookie policy below for further details.

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:

1. analytics providers;

2. advertising networks; and

3. search information providers.

• Identity and Contact Data from data brokers or aggregators.

• Identity and Contact Data from publicly available sources.

• Identity and Contact Data via estate agent customer referrals and/or homeowner referrals

4. 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 you have provided us with your specific and informed consent;

• 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; and

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

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below 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 below::

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To input you as a new customer on our internal database

(a) Identity (b) Contact

Consent

To progress your interest in our products and services

(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 (c) Consent (where appropriate)

To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to conduct surveys etc. (c) Inviting you to events/sending you newsletters

(a) Identity (b) Contact (c) Profile (d) Marketing and Communications

(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (c) Consent

To enable you to partake in a prize draw(s) and enter into a competition

(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) (c) Consent

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 advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent

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 other goods or services that may be of interest to you outside the scope of your primary request

(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Consent

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 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.

Data retention

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Our cookie policy

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, your computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.

What is a cookie?

A cookie is a small text file that is downloaded onto ‘terminal equipment’ (e.g. a computer or smartphone) when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions.

How does a Cookie relate to your personal data?

The GDPR explicitly states that online identifiers, even if they are pseudonymous or if they do not directly identify an individual, will be considered personal data if there is potential for an individual to be identified or singled out. Therefore, any persistent cookie that is unique to the device by virtue of its attributes or stored values fits the criteria for personal data.
Because of this, we must ask for your consent to use cookies when you access our site whilst also making it just as easy for you to withdraw this consent at a later date should you wish to.