Raby

Our Privacy Policy is set out below. Our Tenancy Privacy Policy can be found here.       

Who we are         

Raby Estates is the business operations of 12th Lord Barnard, 12th Lord Barnard, Marwood Settlement, Executors of 11th Lord Barnard, Raby Maintenance Fund, Chattels Trust, Shropshire 1991 Settlement, Shropshire and Upper Teesdale Settlement and Raby Settlement known collectively as Raby Estates.

Raby Estates,

3 Office Square, Staindrop, Darlington, County Durham, DL2 3NF

Tel: 01833 660888, reception@raby.co.uk (general enquiries) gdpr@raby.co.uk (data protection enquiries)

www.raby.co.uk

Our Privacy Promise

Raby Estates is committed to the protection of your rights and your privacy. We promise to process your personal information lawfully, fairly and transparently.  We will only collect your personal information where we have a legal basis for doing so and where it is for a specific purpose.  We will limit our processing to that specific purpose, and endeavour to keep your personal information accurate, up to date, protected with adequate security measures and retained for no longer than necessary.

We are registered the ICO Data Protection Register.

What information we collect, who from, and why

The types of personal information we collect depends upon the purpose for which we collect it and the legal basis for collecting it, but it can include name, location, contact details, gender, date of birth, payment details, and IP address.  Please note this list is not exhaustive.

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for collecting and processing this information are:

  • We have your consent
    For example where you have given your express consent for Raby Estates to use your personal data for direct marketing purposes. Please note that you have the right to withdraw your consent at any time. You also have the right to ask Raby Estates to stop using your personal data for direct marketing purposes. To stop receiving an email from a Raby Estates marketing list, please click on the unsubscribe link in the relevant email received from us or contact us using the details below.
  • We have a contractual obligation
    Such as a sales purchase, tenancy agreement or employment contract.
  • We have a legal obligation

For example, in order to comply with the law.

  • We have a legitimate interest
    We sometimes use legitimate interest as our legal basis for processing personal data in some limited circumstances, in the following areas of our work: volunteering, data analysis, and our website. We always conduct a balance test when doing this, weighing the protection of your rights and personal data with our use of your data to continue supporting our interests.

We collect personal information from visitors, employees, volunteers, tenants, suppliers, and contractors in order to fulfil a contract or agreement, or to supply a requested service.   We do this both electronically and in paper format.

In addition, we also collect details automatically about the pages visited on our website, using cookies and other similar technologies to help distinguish one user from another on our website.  These can streamline a user’s online experience by saving them from re-inputting some information, and also allow us to make improvements to our website. 

When you visit our website, we may collect the following information: which pages you visited and the links you followed; your IP address and general location; and details of the hardware and software you are using to access the site.

Some of our locations and properties have Closed Circuit Television (CCTV) and you may be recorded when you visit them.  CCTV is used to provide security and to protect our staff/volunteers, contractors, visitors and Raby Estates.  CCTV will only be viewed when necessary (for example, to detect or prevent crime) and footage is stored for a set period of time, after which it is recorded over. Raby Estates complies with the Information Commissioner’s Office CCTV Code of Practice and we put up notices so you know when CCTV is used.  

We do not collect, store or process the personal details of persons under the age of 13 years, without the express consent of a parent or guardian.

How we use your information

We use the information you share with us to carry out reasonable administration of your bookings, purchases, membership, volunteering, employment, tenancies, and other contracts and services.  We will make sure that you receive the product or service you have requested, process any payments and send you information relating to that service.   Receiving marketing information will always be your choice.  You can change your mind at any time and we will keep your preferences up to date.

If you work or volunteer for Raby Estates (or you apply to work or volunteer with Raby Estates), we will process your personal information, including sensitive personal information, to comply with our contractual, statutory and management obligations and responsibilities.  Your information will only be processed for the purposes of recruitment/volunteering, including the processing of your application.  We will not send you marketing information.  We may however collect extra information about you, for example references, medical conditions and details of emergency contacts. We will keep this information for legal or contractual reasons, to protect us (including in the event of an insurance or legal claim), and for safeguarding purposes.  In order to carry out our contractual and management responsibilities, we may, from time to time, need to share an employee’s personal data with one or more external parties, for example our Human Resources consultant and HM Revenue & Customs.

We will only use your personal information for as long as is reasonably necessary to fulfil the purpose it was collected for.

Information Automatically Collected In The Raby Estates Mobile App

When using the App, we automatically collect specific data that are required for the Apps usage. This data includes:

  • Location, accuracy and date/time periodically throughout the day (only while at the venue)
  • Each visit to the venue including date/time first seen and last seen
  • Operating system
  • Operating system version
  • Device name
  • Battery level
  • Battery status (charging or not)
  • Bluetooth status (on or off)
  • Mobile network carrier name
  • Currently connected Wi-Fi SSID
  • Location permission status (on or off)
  • IP address
  • User’s preferred locale
  • Current time zone
  • App version and build number
  • App interactions (captured as events fed to Firebase Analytics
  • Date/time entered/exited geofence region (if you enter an offered geofence region)

This data is automatically sent to us, (1) so that we can make the service and the associated functions available to you; (2) to improve the functions and features of the App and (3) to prevent misuse and to rectify malfunctions and (4) to offer you a personalized guest experience. This data processing is justified on the basis that (1) the processing is required in order to fulfil the requirements of the contract between you as the data subject and us in accordance with Art. 6(1)(b) GDPR for the use of the App, or (2) we have a legitimate interest in guaranteeing the functionality and fault-free operation of the App and being able to offer a service that is in line with the requirements of the market and with the interests of the users and prevails over your rights and interests in the protection of your personal data in accordance with Art. 6(1)(f) GDPR

How we store your information
Raby Estates has Cyber Essentials accreditation and all information you provide to us is stored in a physically secure environment, on our secure servers, and on external party secure servers. We control who has access to this information. We will only store your personal information for as long as is reasonably necessary to fulfil the purpose for which it was collected.  When we dispose of your information, it will always be done securely. Raby Estates has

Disclosing and sharing your information
Your information will only be accessible to trained staff and volunteers, where it is appropriate and necessary for them to carry out their role and provide the services to you that you have requested.  We will never sell your personal information, or let other organisations use it for their own purposes. 

We sometimes allow trusted external processors to access your information where we have engaged with them to carry out a service on our behalf, however we always have complete control of what they see, how long they see it for and what they are allowed to do with it.  We are implementing data sharing agreements with these external processors, in line with this privacy policy.

Examples of external processors we may use include: IT providers; consultants; contractors; advisors; and agents

We may also disclose your personal information to third parties in order to comply with a legal obligation, or to enforce other agreements. It may also be used to protect the rights, property or safety of Raby Estates and our visitors. This includes exchanging information with other companies and organisations to protect against fraud.

Our website may contain links to other websites that are outside our control and are not covered by this privacy policy. Please be aware that if you access other sites using the links provided, the operators of these sites may collect information from you, in accordance with their privacy policy, which may differ from ours.

Your data protection rights
We want to ensure that you remain in control of your personal information and therefore draw your attention to your following rights.

  • The Right to be Informed
    We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this privacy policy to do just that, but if you have any questions or require more specific information, you may email us at gdpr@raby.co.uk
  • The Right of Access
    You have a right of access to personal information held by Raby Estates (the data controller).
    This right may be exercised by making a Data Subject Access Request, where you will be asked to provide the following details:
  • The personal information you want to access
  • Where it is likely to be held
  • The date range of the information you wish to access.
  • Confirmation of your identity (by providing two forms of identification, such as passport, driving license, recent utility bill).

If we hold personal information about you, we will give you a copy of the information in an understandable format together with an explanation of why we hold and use it. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (30 days). This timeframe may be extended by up to two months if your request is particularly complex.

  • The Right to Rectification
    You have a right to have inaccurate personal information rectified. When practically possible, once we are informed that any personal information processed by us is no longer accurate, we will make corrections based on your updated information.  The verification, update or amendment of your personal data will take place within 30 days of receipt of your request.

  • Other Data Subject rights
    As well as the rights referred to above, you may have other rights in relation to the personal information we hold, such as a right to erasure/deletion (‘right to be forgotten’), to restrict or object to our processing of personal data and the right to data portability.  

For more information on your rights, please refer to the ICO website.

If you wish to exercise any of these rights, please send an email to gdpr@raby.co.uk or write to us at Raby Estates Office, Office Square, Staindrop, Darlington, County Durham, DL2 3NF.

What to do if you’re not happy
In the first instance, please talk directly to us, so we can understand your request and seek to resolve your query.  You can do this by sending an email with the details of any data protection complaint to gdpr@raby.co.uk

You also have the right to contact the Information Commissioner’s Office (“ICO”), who are the UK data protection regulator, with your complaint, if you are unhappy with how we have used your data.  Their address is:   Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.  Helpline number: 0303 123 1113

Changes to this privacy policy
Any changes we make to this privacy policy in the future will be posted on this page.  Please check back frequently to see any updates or changes to this privacy policy.

This privacy policy was last updated on 15/06/2020