1. Introduction

Nairn Connects BID is a data controller and collects and processes personal data. The Nairn Connects BID is committed to being transparent on how it collects and uses your data and to meeting its data protection obligations. The Nairn Connects BID collects personal data - almost wholly basic contact details - from individuals and from businesses for a number of different purposes.  This notice sets out the various ways in which the Nairn Connects BID collects personal data, the ways in which personal data is processed and the lawful basis for processing.

Personal data relates to an individual who can be identified from data. Identification can be by the information alone or in conjunction with any other information in the data controller's possession or likely to come into such possession.

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (GDPR).

If you have any questions, please don’t hesitate to contact Nairn BID Manager.

2. Lawful Basis for Processing

2.1 Legitimate Interest

We process personal data because we have a legitimate interest in providing information to you about the work the Nairn Connects BID is undertaking on your behalf including our newsletter, advice, guidance, our events and on the services we provide and those of our key partners. We provide this information to you because you are a member, levy payer, or voluntary member of the Nairn Connects BID and / or your property is within the Nairn Connects BID area or have expressed an interest in the services provided by us.  We believe that this information is of benefit, as it will help to keep you informed of the activities of the Nairn Connects BID. We consider this as the basis for processing information and therefore necessary as there is no less of an intrusive way for us to provide you with information.

Some of the information we process under lawful basis includes, but is not limited to, name, position within business, company or organisation, postal address, e-mail address, telephone number(s) etc. and in some instances, financial information e.g. bank/payment details.

Where we are using lawful basis to process personal information we will always make sure that you understand that you can opt out of receiving this information and make it clear to you how you do this.

2.2 Legal Obligation

On occasions we may process some information because processing is necessary for compliance with a legal obligation to which the Nairn Connects BID as a data controller is subject. We consider this basis for processing is necessary because, where appropriate, we will: -

•Comply with a common law or statutory obligation

•Document our decision processing is necessary for compliance with a legal obligation

•Identify the appropriate source for the legal obligation in question

It will not be possible to anticipate every legal obligation; however we will rely on lawful basis for processing information when we are required to process personal information to comply with a common law or statutory obligation. Examples may include court orders or obligations to disclose information about Nairn Connects BID employees to HMRC.  The information processed will depend upon the nature of the obligation imposed.

3. How Do We Gather This Information?

We gather information from various sources including, but not restricted to, information provided by levy payers, from e-mails, business cards, questionnaires, surveys, from those applying for voluntary membership, for the services we provide or who have expressed an interest in the work of the Nairn Connects BID.

4. Where Do We Keep This Information?

We keep this information in both hard and electronic formats in hard copy files and computers systems, which are under the control of the Nairn Connects BID. We also keep some information on databases, computer systems and websites of companies that help us process and manage the information we hold.  These third parties must at all times provide the same levels of security for personal information as the Nairn Connects BID and, where required, are bound by a legal agreement to keep personal information private, secure and to process it only on the specific instructions of the Nairn Connects BID and not for their own purposes.

5. How Do We Keep This Information Safe?

We take every precaution to protect your information. To this end all personal information stored by us is kept in a secure environment. Only Directors and employees who need the information to perform a specific job are granted access to that correspondence.

If we are requested by the police or a regulatory or government authority investigating illegal activities to provide information we may be compelled do so and will act according to the Letter of the Law.

6. Information Shared With Third Parties

The Nairn Connects BID may share some of the personal information gathered from individuals applying to use the services we provide, e.g. to apply and take part in grant schemes or money saving initiatives for the benefit of levy payers, to become a voluntary member or with companies or individuals who have expressed an interest in the working with us for the benefit of levy and voluntary members of the Nairn Connects BID, with third parties but only in the strictly limited circumstances as set out below:

•We may supply personal information to third parties (such as our internet service providers, IT companies) who help us administer our information. These third parties must at all times provide the same levels of security for personal information as the Nairn Connects BID and, where required, are bound by a legal agreement to keep personal information private, secure and to process it only on the specific instructions of the Nairn Connects BID.

•We may also supply personal information to government bodies and law enforcement agencies but only: if we are required to do so by the requirements of any applicable law; in our reasonable opinion, such action is reasonably necessary to comply with legal process; to respond to any legal claims or actions; or to protect the rights of the Nairn Connects BID, its customers and the public. (please refer also to 2.2)

•Personal data will not be transferred to countries or territories outside the EU without your consent.

7. Retention Period

The personal information that we gather as described above will be kept by the Nairn Connects BID for the purposes set out in section 2 of this document.

Where we have provided services to a levy payer or voluntary member, we may keep the associated personal information for a period comprising of the current year plus 6 years unless there are any extenuating circumstances (e.g. bad debt, ongoing court proceedings).  Where this is the case and the information is retained out with this period, then we will fully justify and document our reasons for retaining the personal data.

In addition, the personal data gathered for the purposes of marketing will be retained and used for this purpose unless you tell us you no longer wish to hear from us. Thereafter we will keep minimal contact detail to ensure that you no longer receive our messages.

8. Your Rights - Correction or Updating of Personal Information

As a data subject, you have a number of rights in relation to your personal data. These are listed in brief below. A fee will not generally be charged for exercising any of these rights unless your requests are manifestly excessive.

•The right to access information about the personal data the Nairn Connects BID is processing and to obtain a copy of it;

•The right to require the Nairn Connects BID to change incorrect or incomplete data;

•The right to request that the Nairn Connects BID erases or stops processing your data; and

•The right to object to the processing of your data where the Nairn Connects BID is relying on its legitimate interests as the legal ground for processing;

If you would like to exercise any of these rights, or if you have any concerns about how your personal data is being processed, please contact us by e-mail at NairnBidManager@mail.com or at Nairn Connects BID, Nairn Community & Arts Centre, King Street, Nairn, IV12 4BQ, Telephone 07.

If you still believe that the Nairn Connects BID has not complied with your rights, you can complain to the Information Commissioner.  Contact details are available at www.ico.org.uk

9. Cookies

Cookies are small bites of information that are stored on and retrieved from your computer by websites. The use of cookies is an industry standard and you will find them in use at most websites.

Cookies may be used in analytics

Computers are pre-set to automatically accept cookies in most cases. There are options for you to reset your own personal browser settings to refuse cookies, or alert you when a cookie is being sent so you can choose to accept it or not. Should you choose to refuse our cookies, some parts of our service may be slower or not function properly.

As a BID company we do not control cookies and any computer settings are your personal responsibility. From time to time we may use third party advertising on the web for example Facebook, Google or Twitter. Please visit their policy pages for their compliance guidelines.

10. Other Websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

11. Changes to This Privacy Notice

The Nairn Connects BID reserves the right to update this privacy notice at any time and will provide you with a new notice when making any substantial updates. The Nairn Connects BID may also notify you in other ways from time to time about the processing of your personal data.

12. Monitoring and Review

This policy was last updated on 6th December 2018 and shall be regularly monitored and reviewed, at least every two years