Website Privacy Notice

INTRODUCTION

This is The Southern Co-operative Limited’s (“Southern Co-op”) privacy notice.  We respect your privacy and are committed to protecting your personal data. This privacy notice tells you how we look after your personal data when you visit our website (regardless of where you visit it from); about your privacy rights generally in relation to the information we hold about you as a member and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1.  IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Southern Co-op collects and processes your personal data through your use of this website, your membership of Southern Co-op, when trading with Southern Co-op, taking part in a competition or otherwise where we hold data relating to you.

Although we do accept children from the age of 14 as members, we do not use their data other than in relation to their status as members. We have a policy of not sending any marketing information to under 18s, even if they have ticked to receive such information. Under 16s are not permitted to vote or attend member meetings, so they will not receive communications about these matters. Under 18s will receive other communications about governance matters.  Our website is not intended for children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

The Southern Co-operative Limited (Southern Co-op) is the data controller in most cases, for example, in respect of data collected through your use of this website, data collected in relation to your status as a member which includes information we obtain through use of your membership card in store or in funeral homes, data is also collected through our relationship with suppliers, contractors, landlords, tenants or where you apply for funding through our community support programmes.  Southern Co-op is also responsible for this website.

Southern Co-op owns a number of different legal entities that may also process personal data:

  • Southern Co-operative Funerals Limited, Mutual Services (Portsmouth) Limited, South of England Funeral Partners Limited, East Devon Crematorium Limited and Sussex Woodlands Limited – these companies offer End of Life services including funeral services, pre-need funeral plans, burials, crematoria, masonry and floristry.  Personal data will be collected from clients and users of our services via third party funeral directors.
  • Co-operative Independent Living Limited – this company owns the Co-op Mobility brand, the business of which is operated under contract by a third party Complete Care Network Limited to provide aids to daily living.  Personal data will be collected via Complete Care Network Limited in relation to customers to monitor brand standards and deal with dispute resolution.
  • Co-operative Franchising Limited – this company manages the franchise relationship for businesses operated in partnership with Southern Co-op under both ‘The Co-operative Food’ and ‘Welcome’ brands.  Personal data will be collected in relation to franchisees and their employees, where services are provided on their behalf.
  • Mutual Associates Limited, Southern Co-operative Retailers Limited, Southern Co-operative Properties Limited – these companies are property holding companies.  Personal data will be collected in relation to landlords and tenants.

This privacy notice is issued on behalf of the whole group of Southern Co-op owned entities so when we mention Southern Co-op, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Southern Co-op Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us, or through the relationship we hold with you.

Data collected as a result of our relationship as an employer is detailed in a separate privacy notice for this purpose.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, our use of your data or anything relating to the data we hold about you, please contact the DPO using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity:  The Southern Co-operative Limited (Registered number: 1591R)

DPO:   dataprotectionofficer@southerncoops.co.uk

Postal address:  1000 Lakeside, Western Road, Portsmouth, P06 3FE

You 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.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 25 May 2018. Historic versions can be obtained by contacting us.

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

Our 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 our website, we encourage you to read the privacy notice of other websites.

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, or is identifiable. 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 follows:

  • Identity Data includes first name, last name, title, date of birth and gender.
  • Contact Data includes postal address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us whether through the use of your membership card or otherwise.
  • 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 this website.
  • Profile Data includes purchases or orders made by you, your preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Bespoke Data includes in individual cases specific data such as health information provided in relation to a specific enquiry or arrangement.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your website Usage Data to calculate the percentage of users accessing a specific website feature or anonymised customer data may be shared with a partner to validate market profiles designed to identify potential new store locations. 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 privacy notice.

We do not collect any 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). Nor do we collect any information about criminal convictions and offences.  Aspects of this data may be held for our employees, details of which are covered in our Colleague Privacy Notice.

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, to provide you with membership, goods or services). In this case, we may not be able to provide you with a membership number or may have to cancel a product or service but 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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise, or through meetings with our employees. This includes personal data you provide when you:
    • purchase our products or services which could include food and retail products and services, funeral products or services, bereavement and counselling services, florist products or services, community engagement services through our Love Your Neighbourhood programme, become a supplier or contractor, or become a tenant in one of our residential or commercial properties;
    • become a member, vote, stand as a candidate in our directors’ elections or attend a members’ meeting;
    • contact our Membership and Customer Services team;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as independent funeral directors who are arranging for us to provide services to you on their behalf, or from review sites such as Google, Facebook etc when you carry out a review of our business or services.

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 such as when you join as a member or purchase products or services.
  • 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 such as where we analyse data in order to improve our products and services.
  • Where we need to comply with a legal or regulatory obligation for example in relation to reducing or tackling criminal activity.

If you are a member of Southern Co-op, we are required to communicate with you in relation to governance matters as you are a part owner of our Society. This includes information about members meetings (such as our AGM), directors’ elections and Share of the Profits.  This means we will process your personal data in order to send you these communications.

We will only send you marketing information in accordance with your preferences. To change these please visit our website membership page or contact Member Support on membersupport@southerncoops.co.uk or on 0800 652 0124. 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 dataprotectionofficer@southerncoops.co.uk 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 a new member

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver an order or service including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(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 our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and 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 customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS 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 products, services and offers may be relevant for you.

You will receive marketing communications from us only if you have requested this sort of information from us.

THIRD-PARTY MARKETING

We will only tell you about the products and services offered by entities outside the Southern Co-op group of companies, such as our Charity Partners or other trusted third parties, if you have asked us to do so by consenting to this form of marketing communication when telling us about your preferences. We will not pass your personal data to these third parties.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe links on any marketing message sent to you or by contacting Member Support at membersupport@southerncoops.co.uk or on 0800 652 0124 at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of becoming a member or a product/service purchase and we will continue to be permitted to contact you in relation to these matters provided we have a lawful basis to do so.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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 dataprotectionofficer@southerncoops.co.uk

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.  DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with third parties for the purposes set out in the table in paragraph 4 above.  These may be Internal or External Third Parties as defined in the glossary.  For example we may use mailing houses to process and distribute the Share of the Profits to our members or may engage a marketing agency to run a specific promotion on our behalf or we may pass your details to funeral service professionals such as ministers so that the funeral you require can be provided.

 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.

6.  INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA), however, systems held to hold personal data may be accessed by system providers, or be hosted, outside of the European Economic Area.  Where this is the case we require our system providers and host to secure your personal data in a manner consistent with the requirements of UK law.

7.  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.

8.  DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 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 our Data Protection Officer on dataprotectionofficer@southerncoops.co.uk

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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.

9.  YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:

  • 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

If you wish to exercise any of the rights set out above, please contact dataprotectionofficer@southerncoops.co.uk

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 may 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 may 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.

10.  GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 dataprotectionofficer@southerncoops.co.uk

Performance of Contract 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.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

INTERNAL THIRD PARTIES

Other companies in the Southern Co-op Group acting as controllers or processors and who are based in the UK and who provide products and services:

Company

Products/services

Mutual Services (Portsmouth) Limited

Funeral services

Southern Co-operative Funerals Limited

Funeral services

South of England Funeral Partners Limited

Crematorium

Sussex Woodlands Limited

Natural Burial Ground

East Devon Crematorium Limited

Crematorium

Co-operative Independent Living Limited

Co-op Mobility e-commerce of aids for daily living

Co-operative Franchising Limited

Franchise management for food retail businesses

Mutual Associates Limited

Property holding company

Southern Co-operative Properties Limited

Property holding company

Southern Co-operative Retailers Limited

Property holding company

EXTERNAL THIRD PARTIES

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • Service providers such as market researchers, advertising agencies, property services agencies, contractors, mailing house fulfilment, funeral service providers (embalmers, cemeteries, gravediggers, monumental masons, etc)