Privacy Policy
This is the Privacy Policy of Cobham Community Stores CIC – registered office 35 The Street, Cobham, Kent DA12 3BZ. It is effective from 25 May 2018 in accordance with The General Data Protection Regulations.

Keeping your data safe

At Cobham Community Stores we are committed to keeping your personal data safe and secure, and handling it in accordance with our legal obligations. This Privacy Policy sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else we think it's important for you to know.

Who are we?
We trade as a village store for the benefit of local residents and passing customers. In addition to profits from general sales, we also receive various income from fund-raising activities and other donations. Any net profit at the end of each year is re-invested back into the shop or used for community purposes.

Who's in control?
It is important that you understand who is responsible for keeping your data safe. We are the "controller" of all personal data collected and used for the purposes of providing our services and for any other purposes set out in this Privacy Policy. This means that we are responsible for deciding how and why your data is used and for ensuring that your data is handled legally and safely.

We have appointed a Data Protection Officer (DPO) who has ultimate responsibility within Cobham Community Stores for making sure your data is treated in accordance with this Privacy Policy and the law. Our DPO is David Freeman (book-keeper for the company) who can be contacted by emailing davidj.freeman@yahoo.co.uk

 What data do we collect and where from?

1. Employees

The data we collect from paid employees includes the following:

a) your full name;
b) your postcode and address;
c) your telephone number;
d) your date of birth; 
e) your gender; 
f) your email address;
g) your National Insurance Number
h) your bank account details

Cobham Community Stores has a legal obligation to collect and process this data in order to comply with HMRC & Workplace Pensions regulations. As part of this process, the data will be shared with HMRC, our Payroll agent and the appointed Workplace Pensions provider.

In accordance with our legal obligation, the data will be retained for a period of 5 years after the end of the tax year in which your final payment is made.

2. Suppliers

The data we collect from our suppliers includes the following:

a) your full trading name;
b) your postcode and address;
c) your email address ;
d) your telephone number;
e) your VAT Registration Number;
f) your bank account details

Cobham Community Stores has a legitimate interest to collect this data in order to facilitate the processing of  orders and invoices when trading with you. We also have a legal obligation to collect and process this data in order to comply with HMRC VAT & Company trading regulations. As part of this process, the data may be shared with HMRC..

In accordance with our legal obligation, the data will be retained for a period of 6 years after the end of the Company accounting year.

3. Directors and Shareholders

The data we collect from our Directors & Shareholders includes the following:

a) your full name;
b) your postcode and address;
c) your email address;
d) your telephone number;
e) details of the number & value of shares owned by you.

Cobham Community Stores has a legitimate interest to collect this data in order to keep you, as Directors & Shareholders, informed of the progress of the company. We also have a legal obligation to collect and process this data in order to comply with Companies House regulations. As part of this process, the data may be shared with Companies House and as such may become a matter of public record.

In accordance with our legal obligation, the data will be retained for as long as the company is trading or for a period of 6 years after the Company ceases to trade and/or you cease to be a Director/Shareholder.

4. Volunteers

The data we collect from our Volunteers includes the following:

a) your full name;
b) your postcode and address;
c) your email address ;
d) your telephone number;

Cobham Community Stores has a legitimate interest to collect this data in order to keep you informed of news and progress and to facilitate your voluntary work with the company. As part of this process, the data may be shared with Directors, Shareholders, Employees or other Volunteers associated with the company.

The data will be retained for as long as the company is trading or until you indicate that you are no longer interested in hearing about company progress or being involved with the operation of the shop on a voluntary basis. 

What rights do you have?
You have a number of rights under data protection law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example to help us to locate the personal data that your request relates to.

a) We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.

b) You have a right to ask us to send you a copy of the personal data that we hold about you (subject to some exceptions). A request to exercise this right is called a "subject access request" and must be made in writing to: freeman@yahoo.co.uk or to: Data Protection Officer, Cobham Community Stores CIC, 36 The Street, Cobham, Kent, DA13 3BZ.

c) You have a right to object to us processing any personal data that we hold, where we are relying on legitimate interests as the legal basis of our processing. If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data. You can exercise this right by emailing davidj.freeman@yahoo.co.uk

d) You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.

e) You have a right to ask us to delete your personal data in certain circumstances, for example if we have processed your data unlawfully or if we no longer need the data for the purposes set out in this Privacy Policy. If you ask us to delete your personal data, we will endeavour to do so, but we may not be able or obliged to comply with this request if we have a legal obligation or a compelling legitimate interest to continue processing your data.

f) You have a right to have processing of your data restricted in some circumstances, for example if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights. Restricting your personal data means that we only store your personal data and don't carry out any further processing on it unless you consent or we need to process the data to exercise a legal claim or to protect a third party or the public.

How can you contact us?
If you have any questions or concerns about this Privacy Policy and/or our processing of your personal data, you can get in touch with our Data Protection Officer using: davidj.freeman@yahoo.co.uk

What if you have a complaint?
You have a right to complain to the Information Commissioner's Officer (ICO), which regulates data protection compliance in the UK, if you are unhappy with how we have processed your personal data, or have responded to a formal request concerning your personal data. You can find out how to do this by visiting www.ico.org.uk

What if this policy changes?
We may make changes to this Privacy Policy from time to time. The latest version is always available on request and we may also notify you by email if significant changes are made.