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Privacy Policy

This Privacy Policy describes the policies of Poltimore House (email: info@poltimore.org; phone: 01392 248938) on the collection, use and disclosure of your information that we collect when you use our website (https://poltimore.org) (the “Service”). By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.

Poltimore House in this document refers to Poltimore House Trust, Friends of Poltimore House, and Poltimore House (Branches Café) Limited.

We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.

1. How We Use Your Information

We will use the information that we collect about you for the following purposes:

1. Site protection
2. Manage user account

If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.

2. How We Share Your Information

We will not transfer your personal information to any third party without seeking your consent, except in limited circumstances as described below.

We require such third party’s to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose.

We may also disclose your personal information for the following: (1) to comply with applicable law, regulation, court order or other legal process; (2) to enforce your agreements with us, including this Privacy Policy; or (3) to respond to claims that your use of the Service violates any third-party rights. If the Service or our company is merged or acquired with another company, your information will be one of the assets that is transferred to the new owner.

3. Your Rights

Depending on the law that applies, you may have a right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at contact@workplaceinnovation.eu. We will respond to your request in accordance with applicable law.

You may opt-out of direct marketing communications or the profiling we carry out for marketing purposes by writing to us at info@poltimore.org.

Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.

4. Cookies policy

What are cookies?

This Cookie Policy explains what cookies are and how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to manage the cookie settings.

Cookies are small text files that are used to store small pieces of information. They are stored on your device when the website is loaded on your browser. These cookies help us make the website function properly, make it more secure, provide better user experience, and understand how the website performs and to analyse what works and where it needs improvement.

How do we use cookies?

As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data. The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.

Types of cookies we use

Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data. 

Cookie: Cookieyes-consent
Duration: 1 year
Description: CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors.

Manage cookie preferences

You can change your cookie preferences through your internet browser. Different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.

Chrome https://support.google.com/accounts/answer/32050  
Safari https://support.apple.com/en-in/guide/safari/sfri11471/mac
Firefox https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data- firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US
Internet Explorer https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in- internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

If you are using any other web browser, please visit your browser’s official support documents.

5. Security

The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorised alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

6. Grievance / Data Protection Officer

If you have any queries or concerns about the processing of your information that is available to us, you may email our Grievance Officer at Poltimore House, Poltimore, Exeter EX4 0AU, UK, email: info@poltimore.org. We will address your concerns in accordance with applicable law.

Last updated: November 2023

GDPR Compliance Statement for the Poltimore House Group

Poltimore House and Grounds in this document refers to Poltimore House Trust, Friends of Poltimore House, and Poltimore House (Branches Café) Limited.

Our Commitment

Poltimore House and Grounds is committed to ensuring the security and protection of the personal information that we process, and to providing a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Act 2018.

Poltimore House and Grounds is dedicated to safeguarding personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the GDPR regulatory framework. Our preparation and objectives for GDPR compliance are summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

How we are compliant with GDPR

  • Information Audit – we have carried out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
  • Policies and Procedures – we have data protection policies and procedures in place to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
    • Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
    • Data Retention and Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
    • Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
    • International Data Transfers & Third-Party Disclosures – where Poltimore House and Grounds stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
    • Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
  • Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Act are met.
  • Privacy Notice/Policy – we have revised our Privacy Notices to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
  • Obtaining Consent – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
  • Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
  • Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
  • Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
  • Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and only where we have first identified the appropriate Article 9(2) basis or the Data Protection Act Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information (via our website, in the office, and during induction) of an individual’s right to access any personal information that Poltimore House and Grounds processes about them and to request information about:

  • What personal data we hold about them
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from them, information about the source
  • The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
  • The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision- making that we use
  • The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Information Security & Technical and Organisational Measures

Poltimore House and Grounds takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including storage of data on a secure cloud-based database with password protection and restricted access.

GDPR Roles and Employees

Poltimore House and Grounds has designated Peter Totterdill as our Appointed Person and has appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

Poltimore House and Grounds understands that continuous volunteer and employee awareness and understanding is vital to continued compliance with GDPR and has involved our team in the design and implementation of our policies. We have implemented an training program specific to our GDPR policies which forms part of our induction and annual training program.

If you have any questions about our GDPR policy, please contact Peter Totterdill at Poltimore House, Poltimore, Exeter EX4 0AU, UK, email: info@poltimore.org.