1. Purpose

1.1. Overview

This policy explains how Grimsby Community Energy (GCE) processes personal data, the purposes for which we use it and the lawful bases on which we rely. It applies to the different groups of people with whom we interact, including members, customers, clients, supporters, website users and people who contact us.

The Grimsby Community Energy (GCE) is a registered society under the Co-operative and Community Benefit Societies Act 2014 (Registration Number RS007356) You can contact us using either post, email, or phone using the details provided at the bottom of this page. GCE is a non-profit membership organisation and was created to reduce energy costs and CO2 emissions through community renewable energy projects.

We aim to follow the principles of Article 5 of the UK GDPR lawfulness; fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; accountability.

1.2.Related Policies

  • Retention Policy

2. Scope

This policy applies to personal information processed by GCE in connection with our membership, projects, services, events, communications, website and related activities. It applies to staff, volunteers and others who process personal information on behalf of GCE.

We aim to use and promote high standards of data privacy and information security in the delivery of our services and products to our members, customers, and clients.

  • The right to withdraw consent at any time (where relevant i.e. you have previously given your consent to us for data processing).
  • The right to lodge a complaint with a supervisory authority (in this case ICO).

  1. Data Complaints Procedure

If you wish to make a complaint to GCE about any aspect of how we have handled your data, you should put your complaint in writing to:

email: info@grimsbycommunityenergy.coop

By post: Grimsby Community Energy, The Hub, Freeman St Market, Nelson Street, Grimsby, North East Lincs, DN32 7DS

We will acknowledge your complaint as soon as we can, and no later than 30 days after we receive it, as required by the Data (Use and Access) Act 2025. Your complaint will be investigated, and we will inform you of the outcome as soon as we can. If the investigation is complex and likely to take some time, we will keep you informed along the way.

You may also complain directly to the Information Commissioner’s Office. Full contact details, including a helpline number, can be found on the Information Commissioner’s Office website (www.ico.org.uk).

GCE has determined that it is not required to appoint a Data Protection Officer. Day-to-day responsibility for embedding this policy within GCE currently rests with Vicky Dunn (Managing Director).

Our data protection registration number is ZB471034.

Implementation of and compliance with this Policy is mandatory for all employees, relevant business partners and other third parties acting on behalf of Grimsby Community Energy. A breach of this policy may result in disciplinary action being taken up to and including summary dismissal.

 

  1. Personal Information

If you are a member, GCE is required to keep a record of your name and address. The fact that you are a member is also a matter of public record and your name is included in the Society’s publicly available register of members, subject to the applicable legal and Society requirements.

We will use member contact details to notify members of General Meetings or other proceedings of the Society as required by our rules. Other uses will only be made where we have an appropriate lawful basis.

Depending on how you interact with GCE, we may collect:

  • Name and postal address, including postcode.
  • Email address and telephone number.
  • Membership information and records of membership.
  • Information needed to provide products or services under contract.
  • Information you provide when contacting us, attending events or taking part in projects.
  • Information you provide when joining a mailing list.
  • Technical information needed to operate the website and community forum, including cookie information.

We will only collect information that is relevant and necessary for the purposes for which it is used.

4.1. Mailing lists

Mailing lists and communication. If you sign up to a GCE member or supporter email list, we use your email address to send news and information about GCE projects and events on the basis of your consent.

You can withdraw your consent and unsubscribe at any time. Each marketing email will include an unsubscribe mechanism.

We will not treat a business card, an email enquiry or other correspondence as automatic consent to marketing. Any marketing use of personal information will have an appropriate lawful basis.

4.2. Membership Hub

GCE provides members with access to the Membership Hub, a dashboard and portal for projects and events.

Grimsby Community Energy provides all members with access to the Membership Hub. This is a dashboard and portal for all of our projects and events.

Data collected through this service will be anonymised and aggregated with other personal data if at any stage we require to use for research or commercial purposes in pursuit of the objectives of the Society.

4.3. Partnerships

If GCE enters into a partnership with another organisation, we may retain names, email addresses and telephone numbers of relevant colleagues or employees where necessary to manage the partnership.

The previous draft proposed retaining these records indefinitely and for at least five years. That approach should be reviewed. GCE should define a retention period or documented retention criteria that reflect the purpose of the partnership and any legal or contractual requirements.

 

We do not rely solely on consent. Depending on the activity, the lawful basis may include legal obligation, performance of a contract, consent or legitimate interests.

Activity Typical information Possible lawful basis
Membership administration Name, address, membership record Legal obligation / Society requirements
Providing contracted services Contact and service information Contract
Member/supporter mailing lists Email address Consent
Responding to enquiries Contact details and enquiry information Legitimate interests / contract, as applicable
Website operation Technical information and necessary cookies Legitimate interests / technical necessity

The exact lawful basis depends on the circumstances of each processing activity. GCE will document and review its lawful bases where appropriate.

4.4. How we use information

  • To administer and maintain GCE membership.
  • To meet our obligations under the Society’s rules and applicable legal requirements.
  • To provide products and services to customers and clients.
  • To respond to enquiries and requests.
  • To communicate with members, supporters and project participants about relevant GCE projects and events.
  • To maintain internal records and manage relationships with partners.
  • To improve our services and website.
  • To operate the Membership Hub and community forum.

We do not use personal information for unrelated purposes unless we have a lawful basis to do so and, where required, have provided appropriate information to the individual.

Grimsby Community Energy is currently the sole data controller for this mailing list. No other organisation has access to, or control over, the personal data collected through it.

Partnership

If our organisation enters a partnership with your organisation we may retain a record of the names, emails, and telephone numbers of you and your colleagues/employees for the purpose of managing this partnership. These records may be retained indefinitely and at least for 5 years but will only be used in pursuit of related and proportionate activity.

Legitimate Interests

Grimsby Community Energy does not rely solely on consent as the lawful basis for processing personal information. Following an assessment of our legitimate interests we assert that:

  • We can use data relating to our members for purposes in pursuit of the objectives of our Society provided this data has been suitably pseudo-anonymised.

5. Operating Principles and Accountability

Our website and community forum uses cookies. At present these are all necessary for the functioning of the site.

These cookies are technically necessary for the site to work because of its underlying technology:

Name Purpose Kind of data Sessional or persistent?
PHPSESSID Used to differentiate the different users using the site– necessary for various site functions. Unique token Sessional