Last updated: 18 May 2020
Who we are
Campaign for Borders Rail (CBR) is an unincorporated association based in the United Kingdom. CBR is run by a committee elected by the membership at the annual general meeting. Membership of CBR is open to any individual who supports the Campaign’s aims, agrees to abide by the terms of the Campaign’s constitution, and agrees to uphold the good name of the Campaign.
Our website address is: https://campaignforbordersrail.org
1. Personal data that we process
The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.
| Purpose | Data (key elements) | Basis |
| Enquiring about our organisation and its activities | Name, address, email address, telephone number, message | Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect. |
| Subscribing to updates about our work | Name, address, email address | Consent – you have given your active consent. |
| Making a donation | Name, address, email address, telephone number, payment information | Legitimate interests – this information is necessary for us to fulfil your intention of donating money and your expectation of receiving a confirmation message. |
| Purchasing merchandise from our online shop | Name, address, email address, telephone number, payment information | Legitimate interests – this information is necessary for us to fulfil your intention of making and receiving your purchase. |
| Signing up as a member | Name, address, email address, telephone number, area of expertise or interest, written correspondence | Legitimate interests – by paying your membership fees you have entered into a relationship with us as set out in our membership terms and conditions. |
| Website functionality | Website activity collected through cookies | Legitimate interests – it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of your order before you have fully completed the process or posting a comment. We may also use anonymised data from cookies for analytical purposes. |
| Leaving a comment on our website | Data shown on the comments form, visitor’s IP address and browser user agent string | Legitimate interests – to help spam detection. |
2. How we use your data
We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table above.
For example, we may use your personal information to:
- reply to enquiries you send to us;
- handle donations or other transactions that you initiate;
- send you our regular newsletter;
- where you have specifically agreed to this, send you marketing communications relating to our activities which we think may be of interest to you.
3. Rights you have over your data
You have a range of rights over your data, which include the following:
- You have the right of access to your information.
- You have the right to ask for rectification and/or deletion of your information.
- You have the right to withdraw consent for us to process your data.
- You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed. The Information Commissioner’s Office is at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, tel. 0303 123 1113.
A full summary of your legal rights over your data can be found on the Information Commissioner’s website at: https://ico.org.uk/
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.
Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you.
4. When we share your data
We will not sell, distribute or lease your data to third parties unless:
- you have provided your explicit consent for us to pass data to a named third party;
or
- we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party which fulfils our legal obligations in relation to the use of third party data processors;
or
- we are required by law to share your data.
In addition, we will only pass data to third parties where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation.
5. How and where we store your data
We are committed to ensuring that the privacy of your personal data is secure and protected. If we ask you to provide particular information by which you can be identified, then you can be assured that it will only be used in accordance with this privacy policy. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure all the information we collect.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data, we will promptly assess the risk to members’ rights and freedoms and if appropriate report this breach to the Information Commissioner’s Office.
Membership data
We store most of the data in password-protected files held by the Membership Secretary, and simultaneously in a dedicated part of our on-line membership administration system. The Membership Secretary also holds all the physical correspondence received in a secure filing storage system.
Other data
Data relating online activity – including donations, purchases, membership subscription payments, and comments on news articles on our website – is held on the secure systems of the sub-data processors engaged by CBR to provide services necessary for the administration of the Campaign. These include our: bank; website content management system; e-commerce platform; payment service provider; website hosting; IT support; commercial printers and distributors.
6. How long we keep your data
We take the principles of data minimisation and removal seriously and we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.
If you leave a comment on our website, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users who register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information. Visitor comments may be checked through an automated spam detection service.
7. Cookies and usage tracking
Cookies
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, such as remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.
Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect.
If you leave a comment on our website you may opt in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me” your login will persist for two weeks. If you log out of your account the login cookies will be removed.
Embedded content from other websites and external links
Articles on our website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. Similarly our website contains links to external websites.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
CBR is not responsible for the content of external websites.
Analytics
However we also use some cookies that do not collect personal information but which do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose. Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users’ computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google’s privacy policy is available at http://www.google.com/privacypolicy.html.
8. Modifications
We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights we will notify people whose personal data we hold and which is affected.