Privacy Policy

Our Privacy Policy describes what personal data we collect, and how and why we use it. This policy also describes the options we provide for you to access, update or otherwise take control of your personal data that we process.

Coin Street Group is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you may be identified, you can be assured that it will be used in accordance with this policy.

  1. Who we are

For the purposes of this policy, ‘Coin Street’, ‘CSCB’, ‘the organisation’, ‘we’, ‘our’ and ‘us’ refers to entities within what is considered to be the ‘Coin Street Group’ including; Coin Street Community Builders (CSCB), Coin Street Secondary Housing Co-operative (CSS) and Coin Street Centre Trust (CSCT). Data may be shared internally within the Group where legitimately required. In most circumstances, the parties are separate controllers of your personal data. There are limited circumstances in which two or more Coin Street entities may be joint controllers of your personal data. Full details of the entities can be found on our website.

If you have any questions regarding your personal data or its use and to exercise any of your rights in relation to your personal data, please contact us using the details set out in the ‘Contact us’ section below.

  1. What personal data we collect

When we refer to “personal data,” we mean information that can be used to identify a person or can be linked directly to an individual. It does not include information where the identity of the individual has been fully and effectively removed (anonymous data). 

We may collect personal data about you including: 

  • identity data including first name, last name, title, together with identity data such as your passport details and national insurance number;
  • contact data such as your email address, telephone numbers and home or business address; 
  • your date of birth;
  • financial and payment information such as your bank details;
  • recruitment data including information about your current and past employment, job title or role, qualifications and certifications and interview and assessment data;
  • data relating to your housing needs, and those of your dependents;
  • data relating to your (or your company’s) lease or licence of our property;
  • diversity information, when you apply for a role with us, apply for housing or to access our services;
  • data required when you or your dependents access any of our services, such as our family support or nursery services;
  • minutes of meetings relating to the administration of Coin Street group entities which may contain your personal data;
  • device data including information related to the browser or device you use to access our website, such as your IP address. We typically collect this information through the use of cookies and similar technologies – [please see our Cookies Notice for more information]; 
  • marketing and communications data including your preferences in terms of receiving marketing and communications from us;
  • data collected by our security service providers such as images of you through CCTV – see our CCTV privacy notice [here];
  • data processed when you contact our help desk; 
  • data processed in respect of any complaint, dispute or legal claim that relates to you; and
  • the content of your communications or any other personal data you provide to us directly.
  • racial or ethnic origin; 
  • religious beliefs; or
  • health information.

If you contact us, for example to provide your feedback, we may keep a record of that feedback and correspondence, as well as your name and contact details. 

Sensitive Personal data

Under data protection legislation, certain personal data is considered more ‘sensitive’ (e.g., information relating to race, religion, political affiliation and health). This is also known as ‘special category data’. 

Where required or where you are participating in our family support, nursery or community programmes we also hold sensitive personal data such as:

We treat this data with extra care and confidentiality.

  1. How we obtain your personal data

We collect personal data about you that you have given us in different ways, for example where you:

  • submit information through our online forms; 
  • attend an event or community session or programme; 
  • use our services such as our nursery and/or family support services;
  • apply for a role with us;
  • enter into a lease or conference contract; 
  • contact us via email, phone, or post, or in person;
  • when you come onto our premises and your data is processed by our security services;
  • engage with us via social media platforms;
  • make a donation or payment to us;
  • subscribe to our mailing lists; and
  • access this website.

 

We may collect personal data about you from third parties, including:

  • where you have told a third party you are happy to share your data (such as when you give consent for us to collect a reference); or 
  • from publicly available and privately subscribed sources as part of our fundraising and recruitment activities. 

 

  1. How we use your personal data

We offer a wide range of services and as such the personal data you provide will be processed in a number of ways. The areas of the organisation and how data is used are outlined below:

  • Commercial
    The commercial team uses personal data for contractual verification of bookings, leases, licences and contracts. This is used for the collection of financial payments as specified in the leases, licences or contracts; for the processing of applications and supplying information regarding vacant units; and for activities on site and conference information. 
  • Housing
    The housing team uses personal data provided by the Coin Street co-operatives to fulfil our duties as a housing landlord in respect of the repairs and maintenance of our housing developments. Personal data that you supply when joining our housing register is used for the allocation of empty properties within the co-ops and is, therefore, shared with the co-ops. From time to time the data is analysed anonymously for policy research purposes.

  • Safety and security

    Coin Street collects security data such as CCTV footage in certain public spaces outside the housing it provides using a security team to supply these services. The CCTV footage is only stored for a short period of time. 

  • Family support
    The family support team uses personal data for monitoring, attendance, and for providing family support services for families with children aged 5 years and under on behalf of the London Boroughs of Lambeth and Southwark Children’s Services.
  • Nursery
    The nursery team uses personal data as part of the contract to provide nursery services. This includes compliance with Ofsted as well as our own health and safety requirements. Personal data is also securely shared with Lambeth and Southwark local authorities, including health and education, to meet funding requirements. 
  • Youth and community programmes
    The youth and community programmes team uses personal data to provide youth community activities and ensure that activities are run in accordance with appropriate safeguarding, health and safety requirements. We may communicate with you to offer relevant and useful opportunities and inform you of changes to services we offer. 

Coin Street collects security data such as CCTV footage in certain public spaces outside the housing it provides using a security team to supply these services. The CCTV footage is only stored for a short period of time. 

5. Our lawful bases

We will only use personal data when the law allows us to (i.e., where we have a ‘lawful basis’). Most commonly, we will use your personal data in the following circumstances: 

  • 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. For example, we have a legitimate interest in providing our services to you and in administering leases, licenses and payments;
  • where it is necessary for the performance of a contract with you;
  • where it is necessary to comply with a legal obligation on us (for example, reporting to HM Revenue and Customs, Companies House or the Charity Commission).
  • in some circumstances, we may ask for your consent to use your personal data for a specific purpose. In particular, we may obtain your consent before we send you any email marketing, newsletters or other communications about topics and events which we think might interest you.

Where we process special category information we may do so on the basis of your explicit consent.  We may also rely on various conditions for processing under Schedule 1 to the Data Protection Act 2018 including: 

  • where the processing is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law in connection with employment, social security or social protection (see paragraph 1 of Schedule 1 to the Data Protection Act 2018;
  • where the processing is necessary for health or social care purposes (see paragraph 2 of Schedule 1 to the Data Protection Act 2018);
  • where the processing is necessary for the exercise of a function conferred on a person by an enactment or rule of law (see paragraph 6 of Schedule 1 to the Data Protection Act 2018);
  • where the processing is necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people specified in relation to that category with a view to enabling such equality to be promoted or maintained (see paragraph 8 of Schedule 1 to the Data Protection Act 2018);
  • where the processing is necessary for the purposes of the prevention or detection of an unlawful act (see paragraph 10 of Schedule 1 to the Data Protection Act 2018);
  • where the processing is necessary for the exercise of a protective function (see paragraph 11 of Schedule 1 to the Data Protection Act 2018);
  • where the processing is necessary for the purposes of complying with, or assisting other persons to comply with, a regulatory requirement (see paragraph 12 of Schedule 1 to the Data Protection Act 2018);
  • where the processing is necessary to provide support to individuals with a particular disability or medical condition (see paragraph 16 of Schedule 1 to the Data Protection Act 2018);
  • where the processing is necessary is for the provision of confidential counselling, advice or support or of another similar service provided confidentially (see paragraph 17 of Schedule 1 to the Data Protection Act 2018);
  • where the processing is necessary for the safeguarding of children and of individuals at risk (see paragraph 18 of Schedule 1 to the Data Protection Act 2018).

You may unsubscribe from our email communications by following the instructions in any email that we send you, or you can withdraw your consent and request us to remove your personal data at any time by emailing us at privacy@coinstreet.org.

We do not carry out any automated decision-making using personal data which produces legal effects or otherwise significantly affects individuals.

  1. How we share your personal data 

We may share your personal data with third parties, including the following:

  • with other entities in the Coin Street Group, as well as with contractors, suppliers, or other third parties that provide services on our behalf (such as website host providers);
  • as part of a sale, merger or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
  • pursuant to a court order, or other legal process or as otherwise required or requested by law, regulation, or public authority, or to protect our rights or the rights or safety of third parties; 
  • with our professional advisors, lawyers, accountants and auditors; or
  • with your consent or as otherwise disclosed at the time of data collection or sharing.

 

  1. International data transfers

Information that you provide when signing up for our e-newsletters is stored outside of the UK.  We have put in place appropriate safeguards in accordance with data protection legislation to protect this personal data. 

Other than the e-newsletter storage outlined above, we do not transfer any further personal data we hold to a country outside the UK. If we do so, we will take steps to ensure that your personal data is protected in accordance with appropriate safeguards, where these are required. In particular, we will rely on the appropriate safeguards under data protection legislation, such as approved standard contractual clauses, to protect your personal data. 

  1. How we keep your personal data safe

To protect your privacy we will make sure your personal data is kept securely and disclosed only to relevant organisations or representatives who need to access it to perform their roles. We seek to use appropriate organisational, technical and administrative measures to protect personal data within our organisation, If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact us” section below.

  1. Your rights

You may exercise any of the rights described in this section by emailing privacy@coinstreet.org .

Please note that we may ask you to verify your identity before taking further action on your request.

  • You may access and request copies of any information we hold about you;
  • You have the right to ask us to correct inaccurate or incomplete personal data concerning you;
  • In certain circumstances you will be able to ask for your data to be deleted. This will not apply in all cases where we have a legal obligation or operational requirement to retain personal data in accordance with our Data Retention  Policy;
  • You may request that we stop processing your personal data. We may not be able to stop processing your personal data where we have a legal obligation or operational requirement to continue to process it;
  • You may object to the processing of your personal data in certain circumstances; 
  • You may request that your data is transmitted to a separate service provider or organisation;
  • You may withdraw consent where you have given us consent to use your personal data at any time. If you withdraw consent we will stop using your personal data, unless we are required to process it for a different purpose (for example, the information is necessary to comply with a legal obligation). If you decide to withdraw your consent, this will not affect the lawfulness of our processing before your consent was withdrawn; and
  • You can opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.

To exercise these rights, contact us via the “Contact us” section below. Please be aware that these rights are not absolute and may not apply in certain circumstances, for example if we are legally prevented from complying with the rights or where there are applicable exemptions.

Additionally, you have the right to lodge a complaint against us by contacting the Information Commissioner’s Office (“ICO”). 

The ICO’s address is: 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113 

ICO website: https://www.ico.org.uk

  1. Links to other websites 

Our websites contain links to other websites. However, once you have used these links to leave our sites, you should note that we do not have any control over that other website. In order to understand how your personal data is used on that website you should look at the Privacy Policy applicable to the website in question.

  1. Cookies

Our websites use cookies to enhance your experience while using those sites. Cookies are pieces of information that some websites transfer to the computer or device that is browsing that website and are used for record-keeping purposes at many websites. For further details about our use of cookies, please visit our Cookie Notice here - https://coinstreet.org/cookie-policy 

  1. Changes to this Privacy Policy

We may update this notice to reflect changes in the way we use personal data – for example, to take into account changes in our processes or to reflect changes in legislation. This privacy policy was last updated on [include date]. 

  1. Contacting us

If you have any questions or queries relating to this Privacy Policy please contact us at privacy@coinstreet.org