Salisbury Community Energy Limited ("We") are committed to protecting and respecting your privacy. This Notice sets out how we handle personal data that we collect from you through your use of our website, including any data you may provide through our website when you sign up to our newsletter, or by taking part in a survey or competition. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The rules on processing of personal data are set out in the General Data Protection Regulation (GDPR).
You must read this Privacy Notice together with any other Privacy 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.
- Data controller - a controller determines the purposes and means of processing personal data
- Data processor - a processor is responsible for processing personal data on behalf of a controller
- Data subject – a natural person
- Categories of data:
- a) Personal data - GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR); for example name, passport number, home address or private email address; online identifiers include IP addresses and cookies
- b) Special categories personal data - GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR); the special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual; other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs
- Aggregated Data - data 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 use your postcode to map where people interested in us live
- Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
- Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data
2. Who are we?
Salisbury Community Energy Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Angel Cottage, 119 Lower Road, Lower Bemerton, Salisbury, Wiltshire SP2 9NH. For all data matters contact our Data Protection Officer at firstname.lastname@example.org.
3. The purposes of processing your personal data
We use your personal data to keep you informed about news, events and promotions.
You may give us information about you by filling in forms on our website www.salisburycommunityenergy.co.uk or by corresponding with us by phone, email or otherwise. This includes information you provide when you register for our newsletter (via our website, by email, at an event or orally), enter a competition, promotion or survey, and when you report a problem with our website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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.
4. Categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
• Personal data: name, email address, phone numbers, postcode, age group, gender or gender identity
• Special categories of data: we do not collect any Special Categories of Personal Data about you, nor do we collect any information about criminal convictions and offences.
5. What is our legal basis for processing your personal data?
For personal data of data subjects with a private email address, our lawful basis for processing general personal data is consent from the data subject. This includes data subjects that gave us their consent to hold their contact details before 25th May 2018.
For personal data of data subjects with an email address owned by a corporate entity, our legal basis is a legitimate interest. We have carried out a Legitimate Interest Assessment taking into account the interests or fundamental rights or freedoms of the data subject.
6. Sharing your personal data
Your personal data will be treated as strictly confidential. 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. We will get your express opt-in consent before we share your personal data with any third party for their own purposes.
7. How long do we keep your personal data?
We keep your personal data for a period of up to 30 days after you have opted out of receiving information about news, events and promotions.
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.
8. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But we will not be able to send you information about news, events and promotions.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. International Transfer of Data
We transfer and store data outside of the European Economic Area (EEA). All data processing services we use undergo independent third-party audits to provide verification of security, privacy and compliance controls. We use the services listed below, and details for their privacy can be found by following the link shown:
• GSuite and Google Cloud - https://cloud.google.com/security/gdpr
• MailChimp - https://mailchimp.com/legal/privacy
11. Automated Decision Making
We do not use any form of automated decision making.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
13. Cookies and 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 every website you visit.
15. 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.
While we will take all reasonable steps to maintain the security of our website, you should understand that the open nature of the internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. Therefore, we cannot and do not guarantee that personal information you provide will not be intercepted by others and decrypted.
16. Queries, requests and complaints
To exercise all relevant rights, raise queries and make requests or complaints please in the first instance contact our Data Protection Officer at email@example.com.
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than a 30 days 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.
If we do not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
Version 1.0 issued 6 June 2018
This website is owned and administered by Salisbury Community Energy Limited, Angel Cottage, 119 Lower Road, Lower Bemerton, Salisbury, Wiltshire SP2 9NH.
Use of this website by you constitutes acceptance by you of our Cookies Policy. If you do not wish to accept our Cookies Policy, please leave this website immediately.
What are Cookies?
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
To find out more about cookies, including to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
We will not sell or otherwise pass your personal information to third parties. It is completely up to you whether or not you want to provide personal information to third parties.
Version 1.0 issued 6 June 2018
Salisbury Community Energy (SCE) is a Community Benefit Society set up in March 2017, registration number 1708, which is regulated by the Financial Conduct Authority.
In order to ensure our services remain at a high and improving standard, we have a procedure through which you can let us know of for any reason you are not satisfied with the organisation, or any of our activities or decisions.
In the first instance, please speak to the Development Manager or any member of the Board (listed on our website and contactable via our website). If you are unhappy with an individual in SCE sometimes it is best to tell him or her directly. If you feel this is difficult or inappropriate then speak to any member of the Board and ask them to raise it.
Often we will be able to give you a response straight away. When the matter is more complicated we will give you at least an initial response within five working days.
If you are not satisfied with our response or wish to raise the matter more formally, please write to the Board of Directors at SCE’s registered address, currently 119 Lower Road, Salisbury, Wiltshire SP2 9NH.
All written complaints will be logged. You will receive a written acknowledgement within three working days. The aim is to investigate your complaint properly and give you a reply within ten working days, setting out how the problem will be dealt with. This may include consultation with the Financial Conduct Authority (see their guidance on how to complain here), Co-operatives UK (see their guidance on Community Benefit Societies here), and/or Community Energy England. If this is not possible, an interim response will be made informing you of the action taken to date or being considered. If after we have responded you are still not satisfied, please write to the Chair of the Board (at SCE’s registered address) who will report the matter to the next Board meeting, which will decide on any further steps to resolve the situation.
Finally, please also let us know if you are happy with SCE and our work.
Last revised 3 December 2018. Approved by SCE Board 3 December 2018.
The policy and procedures apply to the Salisbury Community Energy (SCE) Board of Directors and all paid contractors and volunteers.
SCE’s core business is the installation of renewable energy. In the course of that activity, some contact with vulnerable persons and children occurs.
All Directors are under a general legal duty to:
• protect vulnerable people and children from abuse;
• to be aware of the terms and procedures in this Policy and to follow them;
• to know how to access and implement the procedures in this Policy, independently if necessary;
• to keep a sufficient record of any concerns, discussions and decisions in accordance with this Policy; and
• to report any matters of concern in accordance with this Policy.
SCE has a designated Director responsible for safeguarding and the protection of vulnerable people and children (the Designated Safeguarding Lead or DSL) to whom any concerns or allegations should be addressed and who should be able to offer appropriate support, advice and expertise to Directors on matters of safety and
safeguarding, and to refer to other agencies as appropriate.
SCE’s Board of Directors is accountable for ensuring SCE has effective policies and procedures in place, in order for appropriate action to be taken in a timely manner to safeguard vulnerable people and children. This is reviewed regularly at Board meetings. The Board of Directors ensures that:
• safeguarding arrangements take into account the procedures and practice of the Wiltshire Safeguarding Adults Board and Wiltshire Safeguarding Children Board, including understanding and reflecting local protocols for assessment and the referral threshold document
• contributes to inter-agency working, including providing a co-ordinated offer of early help
• operates safe recruitment procedures, such as carrying out the required safeguarding checks including Disclosure and Barring Service (DBS) checks
• has arrangements to deal with allegations of abuse
• has designated persons with status and authority to deal with vulnerable people and child protection
• carries out training
• the DSL follows guidance from the Local Safeguarding Board threshold document, whenever a disclosure or allegation of abuse has been made.
Board Directors: role profile and code of conduct
- Governance framework
- Duties and expectations
- Recruitment process
- Term of office
- Code of Conduct
1. Governance framework
The role is set out in the constitution ‘Rules’ of SCE, clauses 61 to 86, Annex 1.
- SCE has a Board of Directors comprising not less than three Directors.
- Only persons aged 18 or over may serve on the Board of Directors.
- Directors must be Members of SCE.
- The Board of Directors may co-opt up to two external independent Directors who need not be Members and are selected for their particular skills and/or experience.
- The Board of Directors may at any time fill a casual vacancy on the Board by co-option. Co-opted individuals must be Members of the Society and will hold office as a Director only until the next annual general meeting.
- Directors of societies are protected by limited liability. This means that when the society goes into liquidation or is wound up with outstanding debts, they will not have to contribute to the assets of the society above the amount of the value of the shares they hold (usually a nominal sum). This protection is lost if fraud has been perpetrated and in certain other situations.
2. Duties and expectations
These are set out in the Co-operatives UK guide: The Essential Society Director – an in-depth guide, November 2015, Annex 2.
- Act in good faith
- Take care
- Obey the law
- Duty to use powers only for the purposes for which they were conferred
- Duty to act in the society’s best interests
- Exercise independent judgement
- Duty of care, skill and diligence
- Avoid conflicts of interest. Directors should avoid putting themselves in a position where their duties and responsibilities as a director conflicts with other personal interests. Where a conflict arises, they must comply with the society’s rules and processes
Duty not to misuse the society’s information or property or make secret profits
The role is honorary only: no remuneration is paid. Expenses can be paid only if a budget line for them has been specified.
Directors control, shape and influence the work of SCE and engage with Members, site owners, and the public to take forward SCE’s Objects:
The objects of the Society shall be to carry on any business for the benefit of the community including the development, financing, construction, operation and (if required) sale of renewable energy generation assets, for the purpose of:
- Supplying heat/electricity from renewable and low carbon sources;
- Enabling the local and wider community to share in the ownership of the renewable and low carbon electricity/heat generation projects;
- Providing funding and resources for flood prevention, mitigation and resilience;
- Initiating and delivering educational and other community activities which promote awareness of environmental issues focussing on climate change, flooding and renewable energy.
- Generating income to provide funding to community organisations and projects in the Local Community
4. Recruitment process
Recruitment of new Board Directors will involve:
- a written application (email can be accepted), submission of a CV, confirmation of identity, and confirmation based in the South Wiltshire area
- a minimum of two meetings (with one or more Directors) before a formal Board meeting
- the opportunity to attend up to three Board meetings as an Observer, before a decision about whether or not to join as a Board Director is required.
- a detailed Induction with one or more Directors to take a minimum of three hours, with regular updates and opportunities for learning.
5. Term of office
The procedure for a retirement cycle of Directors is specified in the ‘Rules’, clause 65, but no minimum or maximum term of office is stipulated. In SCE’s Code of Practice for Directors, a term of a minimum of one year, and a maximum of ten years is stipulated. A potential Board Director may attend, as Observer, a maximum of three meetings, before a decision on whether or not to join the Board is required.
6. Code of conduct
Conduct of SCE’s Directors should comply with the Duties set out in the Co-operatives UK guide, The Essential Society Director. For example, a Duty of Care involves:
- Reading papers before governing body meetings and arriving properly prepared
- Asking questions, requesting clarification if further information or explanation is needed, and challenging the members of the management executive when not satisfied with the answers given
- Taking advice both from the management executive and from independent advisors, when appropriate, in the best interests of the society
- Disclosing any material interest to the governing body as provided for in the rules of the society. Directors should also do this in conjunction with any Conflict of Interest Policy that the society may adopt and the Code of Conduct for Directors as approved by the governing body.
Directors should aim to carry out their role to the highest possible standards. It is not acceptable to leave things to other people, to fail to attend meetings without an unavoidable reason for doing so, or to treat other matters as more important than those of the society. A director who does not give an appropriate level of commitment to the society’s affairs is failing in his or her duty.
Maintaining excellent working relationships
The values of SCE, as a community membership organisation, are first and foremost about maintaining excellent working and community relationships. All our team are expected to do so.
In a small organisation it is inevitable that tensions and conflict will arise. When they do, it is critical that they are dealt with well. That means apologies, forgiveness, empathy and resolution. Work arrangements may need to be changed to restore harmonious working. Everyone working for SCE (in either a paid or voluntary capacity) is expected to put the interests of the organisation above any personal interest.
Gender discrimination policy
Men and women are entitled to expect exactly the same degree of respect and courtesy. It is not acceptable for male colleagues to adopt a brusque and neglectful manner towards female colleagues (or vice versa). Messages which are experienced by any team member as curt are unacceptable. The use of pejorative terms, for example, 'strident', or 'unattractive', to silence colleagues is unacceptable. No-one is above the requirement for polite, timely and responsive communication, so far as time-limitations allow.
Equal opportunities policy
SCE will not discriminate on the basis of ‘protected characteristics’ as follows:
- gender reassignment
- marriage and civil partnership
- pregnancy and maternity
- religion or belief
- sexual orientation
Approved by SCE Board, 14/01/2019. Last revised 14/01/2019.
Conflict of Interest Policy
The purpose of this policy is to protect the integrity of Salisbury Community Energy’s decision-making process, and to enable our members, supporters and partners to have confidence in our integrity, and to protect the integrity and reputation of our Board Directors and volunteers.
All Board Directors and volunteers of Salisbury Community Energy (SCE) will strive to avoid any conflict of interest between the interests of SCE on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.
Examples of conflicts of interest include:
- A Director who is also a contractor who must decide whether payments to contractors should be increased
- A Director who is related to a contractor and there is decision to be taken on contractor pay and/or conditions
- A Director who is also on the Board of another organisation that is competing for the same funding
- A Director who has shares in a business that may be awarded a contract to do work or provide services for the organisation.
SCE will ensure conflicts of interest are managed and addressed appropriately.
Advance authorisation from the Board as a whole must be in place for any benefit to a Board Director, and there should be a sufficient number of Directors who are not conflicted.
- Upon appointment each Director will make a full disclosure of interests, such as relationships, and posts held, that could potentially result in a conflict of interest. This disclosure will be noted in Board meeting minutes, kept on file and updated as appropriate.
- In the course of meetings or activities, Directors will disclose any interests in a transaction or decision where there may be a conflict between the organisation’s best interests and the Directors’ best interests, or a conflict between the best interests of two organisations that the Director is involved with.
- After disclosure, Directors may be asked to leave the room for the discussion and may not be able to take part in the decision depending on the judgement of the other Board members present at the time.
- Any such disclosure and the subsequent actions taken will be noted in the minutes.
Charity Commission: Conflicts of interest: a guide for charity trustees (CC29)
Small Charities Coalition: Conflicts of Interest
Voluntary Action Islington: Policies, Resources & Toolkits
Signed off by the Board of Salisbury Community Energy 7 October 2019
Last revised 7 October 2019