North Manchester Jewish Cemeteries Trust Ltd (“NMJCT”)
Privacy and Cookies (GDPR) Policy
Welcome to NMJCT’S privacy and cookies policy (this “Policy”). In this Policy, NMJCT is referred to as “we”, “us” or “our”.
We respect your privacy and are committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when:
You visit our website at ww.nmjct.org (the “Website”), regardless of where you visit it from, including any data you may provide through this Website when you contact us;
You contact us otherwise through the Website, or use our premises or services;
and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this Policy
This Policy aims to give you information on how we collect and process your personal data through your use of the Website and when you contact us.
It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.
Controller
NMJCT is the controller (as defined in the Data Protection Act 2018) and responsible for your personal data.
If you have any questions about this Policy, including any requests to exercise your legal rights as set out in paragraph 10 below, please contact us using the details set out below:
Full name of legal entity: North Manchester Jewish Cemeteries Trust Ltd
Email address: [email protected]
Postal address: Rainsough Jewish Cemetery, Butterstile Lane, Prestwich, Manchester, M25 9UL
Telephone number: 0161 795 0735
Changes to this Policy and your duty to inform us of changes
We keep our Policy under regular review. This version was last updated in January 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Through the Website or if you otherwise contact us or use our premises or services
Identity Data includes first name, last name, title and gender.
Contact Data includes address, email address and telephone numbers.
Financial Data includes payment card details.
Transaction Data includes details about payments to and from you and other details of how you have used our services and premises.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
Usage Data includes information about how you use the Website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender and Hebrew name.
Family Data includes information about the members of your family, including parents, children and siblings, bereavements that may be suffered, by you or your family.
Contact Data includes address, email address and telephone numbers.
Financial Data includes payment card details.
Transaction Data includes details about payments to and from you and other details of how you have used our services and premises.
Feedback Data includes your interests, preferences, feedback and survey responses.
Communications Data includes your communication preferences for receiving postal and email correspondence, updates and newsletters from us.
We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We may also collect information about any criminal convictions and offences. We may collect this information for purposes of health and social care provision (including pastoral care) within our community, which is permitted by relevant data protection laws. If we need to collect any Special Categories of Personal Data from you for any other reason, we will first obtain your explicit consent.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, a permit to install a new memorial in one of our cemeteries ). In this case we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Family, Contact, Feedback, Communications and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
subscribe to our communications and publications;
use our premises or services;
request information to be sent to you;
provide a response to a or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with the Website, we will automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see paragraph 5 below for further details as to how the Website uses cookies.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you for a new memorial permit. This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This means the interest of our business in conducting and managing NMJCT to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as wanting to use or interested in the services of NMJCT |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To provide you with services or access that we have agreed to provide to you |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process manage payments, fees and charges, and collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to this Policy (b) Asking you to take a survey or provide feedback |
(a) Identity (b) Contact (c) Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how members use our services) |
|
To administer and protect NMJCT, the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical (d) Usage |
(a) Necessary for our legitimate interests (for running NMJCT, provision of administration and IT services, network security, to prevent fraud and in the context of a reorganisation or restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant Website and other content to you and measure or understand the effectiveness of that content |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Communications (f) Technical |
Necessary for our legitimate interests (to study how users use our services, to develop them, to grow our community and to inform our growth and development strategy) |
|
To use data analytics to improve the Website, services, relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of members and users of our services, to keep the Website updated and relevant, to grow our community and to inform our growth and development strategy) |
|
To make suggestions and recommendations to you about services or events that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Communications |
Necessary for our legitimate interests (to develop our services and grow our community) |
|
To provide relevant information on events within the community. |
(a) Identity (b) Family
|
Necessary for our legitimate interests (to encourage communication, social care, and communal and collaborative feeling within our community) |
|
To circulate bereavement and Shiva notices, which may include member names and addresses (and those of their immediate family) |
(a) Identity (b) Family (c) Contact |
Necessary for our legitimate interests (to encourage communication, social care, and communal collaborative feeling within our community) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotions from us: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services, events and offers may be relevant for you. You will receive these communications from us if you have requested information from us, and you have not opted out of receiving that marketing.
Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out: You can ask us or third parties to stop sending you messages at any time by following the opt-out links on any message sent to you or by contacting us at any time. Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of being a member of Stenecourt or otherwise in respect of services you have contracted to receive from us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Cookies
The Website uses cookies. Cookies are tiny text files which identify your computer to our server as a unique user when you visit certain pages on the Website, and they are stored by your Internet browser on your computer's hard drive. Cookies can be used to recognise your Internet Protocol address, saving you time while you are on the Website.
We only use cookies for your convenience in using the Website and not for obtaining or using any other information about you (for example targeted advertising). Your browser can be set to not accept cookies, but this would restrict your use of the Website.
If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.
Please note that we collect data from the Website about use of the Website using a web analysis tool which uses cookies that are (able to be) used to generate pseudonyms for a user’s profile. This means that use cookies (which may be stored on your computer after you leave the Website) can store information about your visit.
The Website uses the following cookies:
|
Name |
Expiration date |
Purpose |
|
_cfduid |
1 year |
Used to identify individual users behind shared IP addresses and apply security settings. It does not store any personally identifiable information. |
|
NID |
6 months |
We use Google services including ReCaptcha and Google Fonts. The NID cookie contains a unique ID Google uses to remember your preferences and other information, such as your preferred language (e.g. English), how many search results you wish to have shown per page (e.g. 10 or 20), and whether or not you wish to have Google’s SafeSearch filter turned on. |
|
_RequestVerificationToken |
End of session |
Used as an anti-forgery security measure. It does not store any personally identifiable information. |
6. Disclosures of your personal data
We may share your personal data with the external third parties set out below for the purposes set out in this Policy:
Service providers acting as processors based in the UK who provide IT and system administration services.
- Our payment services providers, such as PayPal.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- Third parties to whom we may choose to sell, transfer or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the updated organisation may use your personal data in the same way as set out in this Policy.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property or safety of our community, our member, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, as well as law enforcement authorities.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International transfers
Generally, we do not transfer your personal data outside the United Kingdom.
However, some of our external third parties are based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA. With any such third party, we ensure a similar degree of protection is afforded to your personal data by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers with a base in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see paragraph 10 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Rainsough Jewish Cemetery, Butterstile Lane , Prestwich, Manchester, M25 9UL | 0161 795 0735| ©2020 North Manchester Jewish Cemeteries Trust Ltd | Privacy Policy