Privacy Notice for

East Harpenden Gardening Club

Personal Information – Privacy Notice 

East Harpenden Gardening Club (the ‘Club’) holds and uses personal data about its members. In the context of data protection legislation, it is a ‘data controller’.

This privacy notice lets you know what happens to any personal data you give to us or we may collect from you. Your trust is important to us and we are committed to safeguarding your personal data.

In accordance with the General Data Protection Regulation as retained in domestic law (the ‘UK GDPR’) we are providing you with clarity on what data we have, how we use it, why we need it and who has access to it.

We are providing you with this privacy notice because either:

  • you rent an allotment plot managed by the Club (“Full Member”)

  • you share an allotment plot with a Full Member (“Partner Member”)

  • you are not a plot holder but you are interested in gardening and you are entitled to use the Club Shop at the Holcroft Road site (“Associate Member”) or

  • you are applying for or seeking to renew any of the above types of Club membership,

and we are required to inform you of your rights relating to the personal information we hold. 

Compliance

The Club is categorised as a non-profit organisation and, as we process only information relevant to our devolved management of the allotment sites, there is no requirement for us to register with the Information Commissioner’s Office (‘ICO’).

The lawful basis under the UK GDPR that we rely on for processing personal data is known as ‘legitimate interests’.

Harpenden Town Council owns six allotment sites in East Harpenden and has devolved the management of these sites through an agreement with the Club. Legitimate interests apply since the Club needs to process certain personal information in order to undertake our devolved management role and meet the conditions of our agreement with Harpenden Town Council. This processing activity includes:  

  • managing tenancies with Full Members whose plots may or may not be shared with their Partner Members and who can show they reside in an AL5 postcode, and

  • managing arrangements with Associate Members.

By way of this notice, we are communicating our privacy policy to both existing members and anyone seeking to become a new member. This privacy notice is posted on our website. New applicants will be directed to this privacy notice by the application form they complete when seeking to join the Club. Existing members will be reminded of the privacy notice at the time of renewing their Club membership. 

Data protection principles

We comply with data protection law and principles, which means that your data will be:

  • used lawfully, fairly and in a transparent way

  • collected for specified, explicit and legitimate purposes and not further used in any way that is incompatible with those purposes

  • relevant to the purposes we have told you about and limited only to those purposes

  • accurate and kept up-to-date

  • kept only as long as necessary for the purposes we have told you about

  • kept securely

The information we hold about you

In connection with your application for membership and/or your membership of the Club, we collect, store and use the following types of personal information about you:

  • your title and full name

  • your postal address

  • your email address

  • your home and/or mobile telephone numbers

  • your rental and associated charges for your plot

How is your personal information collected?

Most of the personal information we process is provided to us directly by you from the following sources:

  • your expression of interest/request for more information submitted through the Club’s website

  • information that you provide (including through Membermojo, as explained further below) when completing the application form when applying for an allotment plot including any documents used to prove your address

How we will use personal information

We use the information you have given us in order to manage our allotment sites and tenancies and for the operation of your membership. This enables us to:

  • send invoices for plot holder fees and any other related charges

  • manage plot and key deposits in accordance with the Club Rules

  • process requests for the reimbursement of costs reasonably and properly incurred on behalf of the Club

  • keep proper accounting records, including customer account records in relation to the Club Shop

  • communicate with you by email, telephone and post, for example, to communicate allotment news and events, including if there has been damage to an allotment site or plot or shed, if the plot is being neglected or for other reasonable purposes.

Keeping your personal information up-to-date

If any of your personal information should change, such as your contact details or address, you should inform us as soon as possible, to help us satisfy the data protection principle of holding accurate and up-to-date information about the Club’s members.

Data sharing

Harpenden Town Council

The names and postal addresses of all tenants and details of payments made by them in respect of their plot are made available to the Town Clerk or other designated representative of Harpenden Town Council on a six-monthly basis or more frequently if such information is requested. Harpenden Town Council’s Privacy Notice is available here.

Membermojo

The Club obtains online membership services from Membermojo Limited to facilitate its devolved management of the allotment sites. This involves the Club using software that includes functions such as the processing of plot applications and renewals, electronic payments, group email distribution and the provision of a central member database. For information on how Membermojo Limited uses your personal information in their capacity as our data processor, please see their privacy notice available here and statement on the General Data Protection Regulation available here.

National Allotment Society

In the event the Club seeks association membership of the National Society of Allotment & Leisure Gardeners Ltd (operating as the ‘National Allotment Society’ and referred to from now on as ‘the NAS’), the Club will be required by the Rules of the NAS to provide a list of signed up plot holders. Providing such a list will be necessary to demonstrate that the Club is paying the correct joining fee, as charges are set according to the number of such plot holders. It will also enable those individuals to access the benefits and support services that come with the NAS association membership.  

Benefits are expected to include the ability of the Club to enrol signed-up plot holders on to the ‘Allotmenteers Liability Insurance’. This policy is arranged by the NAS at no extra cost. To be added to the policy it will be necessary for the Club to advise the NAS of enrolment and provide full member contact details and keep these up-to-date as plot holders leave and are replaced. 

If you are a signed-up plot holder and if the Club is seeking or has secured association membership through the NAS, the Club shall be entitled, where you have given your express consent, to share your name and postal address and email address with the NAS with a view to you benefitting from the Club’s association membership of the NAS, including enrolment onto the Allotmenteers’ Liability Policy. The NAS state that any such information will not be passed to any third party without consent. The privacy notice of the NAS is available here. 

Other than these three exceptions, the Club will not share data with any other party without the written consent of the member(s) concerned. The Club will not sell any data to any third parties.

Data security

Data are only accessible to those Committee members who need to use it to undertake the Club’s activities.

We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Members’ information is held securely by the Club in an electronic database stored in Google Drive. Appropriate tools such as firewalls are in place and antivirus software is kept up-to-date. 

Information held on paper (hard copies) is kept safely in a locked cabinet and to a minimum with access limited to those who need to use it.

Members’ information is also held securely by Membermojo Limited in accordance with their ‘Security and Member Policy’ available here.

We will notify you and the ICO of any suspected data security breach where we are legally required to do so.

Data retention

We only hold data as long as we reasonably need it. We will retain your personal information for as long as you are a member of the Club and, should you inform us during the period of your tenancy or at the time of annual membership renewal that you no longer wish to be a member of the Club, for a short retention period (up to 12 months from the end of your tenancy) in case you need to be contacted about your former plot. 

For applicants who withdraw from our waiting list, your information will be deleted promptly from our records.

Rights of access, correction, erasure and restriction

Under data protection law, you have rights including:

  • Your right of access - You have the right to ask us for copies of your personal information.

  • Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

  • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

  • Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at team.ehgc@gmail.com if you wish to make a request.

If you want to review, verify, correct or request erasure of your personal information or object to the processing of your personal data, please contact: The Chair by e-mail on chair.ehgc@gmail.com

Why is all of this necessary?

The Club is legally obliged to comply with current data protection obligations both in relation to the UK GDPR and the terms of the Club’s agreement with Harpenden Town Council. It is required to provide you with details on the kind of information that it may be holding about you and how it is processed.

Data protection issues 

If you have any concerns about our use of your personal information, you can raise these with us at team.ehgc@gmail.com. 

You can also contact the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk