This policy explains:
- how we process your personal information
- how we collect, use and share your personal data and your rights regarding it
- how the policy applies to our websites and our processes
The policy applies to all websites operated by or on behalf of Harborough Energy Limited (‘ we’ or ‘us’) and to our internal and partner processes. In summary, these are the things you need to know:
Who are we?
We are a not for profit cooperative set up in December 2014 to provide affordable, clean energy to the communities in and around Market Harborough. Our local energy projects are designed to offer attractive investment opportunities, as well as, reasonable returns to the landowners and landlords that we use.
What types of information do we collect and how?
We only collect personal data when it is needed to deal with a request and with your informed consent – such as if you fill out a form, subscribe to our mailing list or respond to a survey.
In specific circumstances, such as our Harborough Solar One community share offers, we will ask to collect personal details (online, via email, by post or in person) sufficient to allow you, as a prospective investor, to advise us of your interest and for us to provide you with offer information, form a contract, allocate shares and process investments.
In the case of a Warm / Healthy Homes referral, we will ask you to supply us with sufficient personal information for us to put you in touch with the relevant advisor / installer and to manage the referral processes. As this is subject to eligibility, you will be asked to provide us with some basic health and economic data.
How is your information held and how do we use it?
Your data is used solely to respond to a specific request, to inform you about our projects (if requested) and your investment (if applicable) or to enable a Warm / Healthy Home referral. We do not profile you and will never sell your data.
As a small social enterprise, we do not own, host or operate our own in-house information systems. We use email, file storage, list management and web hosting services from a number of Internet Service Providers (ISPs) such as Microsoft, Gmail, Dropbox, MailChimp, Ideal Marketing and WordPress.
We also use Social Media Providers (SMPs) such as Facebook and Twitter to promote our community energy services and share offers but we do not pass on any of your personal data to these or any other social platforms.
We are committed to ensuring that your information is secure – this includes confidentiality, integrity, availability and resilience. In order to prevent unauthorised access or disclosure, we have suitable physical, electronic and managerial procedures, tested at appropriate intervals, to safeguard and secure the information we collect online and otherwise.
When you send emails or other communications to us, we may retain those communications in order to process your enquiries, respond to your requests and improve our services. Any personal information you provide to us will only be used and retained with your informed consent (eg Mailing) or as part of our contracted services with you (eg Member).
How long do we store your information for?
We will keep your information for as long as was originally agreed when it was provided to us – unless you specifically contact us otherwise. It is held securely but only for as long as is required for the stated intended purpose:
- Enquiry data will be held until we have been able to deal with your request (but no longer than 3 months).
- Mailing List data will be held on an ongoing basis with the option for you to request your removal at any time.
- Referral data will be held for 12 months from the date of referral and then deleted (unless there is a subsequent query or complaint that requires resolution).
- Member data will be held whilst your membership is maintained (normally 20 years or earlier, if agreed).
- Member data will be held in archive for a further 6 years to comply with legal and financial requirements.
- Directorships/Committee/Meetings/Annual Returns data will be held indefinitely.
Our ISPs and SMPs will each have their own bulk data archiving and disaster recovery policies in order to perform full data recovery in the event of a full disaster, often for at least seven years.
What are your rights?
You have the right to ask us, in writing or by email to our address below, for a copy of all your personal data – this is known as a ‘subject access request’. We will check your details match our records and we will then send you a copy of your information (to the address we hold in your personal data), in a suitable format, as soon as is practical but no later than 30 days after we receive your request.
Do you have any concerns regarding your data?
Email: Harbor[email protected]
Post: c/o The Stables, 32 Main Street, Ashley, Market Harborough, Leicestershire LE16 8HF
If you are not satisfied with our response, you can make a complaint to the UK Information Commissioner via https://ico.org.uk/concerns/
On behalf of the Directors – Harborough Energy / Harborough Solar One