About this Policy
1. This policy explains when and why we collect personal and business information about our user members, how we use it and how we keep it secure and your rights in relation to it.
4. We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.org.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you
Who are we?
We are ‘Kingston Pound CIC registered Office 97 Ellerton Road Surbiton KT6 7UA Reg 10439038 established as a CIC in the 20th October 2016 and was formerly known as The Kingston Pound Community Association. As an non-commercial and therefore not for profit organisation we do not need to register with the Information Commissioners Office (ICO).
Who are the members?
Individuals and businesses registering an account on https://townpound.community-currency.org/cyclos/kingston/ will automatically become members of the Kingston Pound until such time that the scheme winds up or members ask to be removed from membership. Becoming a member will necessitate the use of some of your personal data and information. Registering via the URL above means there is an assumed consent to store and use your data but this does not affect your right to have your data transferred or deleted at any time. The motivation to retain your data is not a commercial one as we are an not for profit CIC and any profits we do generate will not benefit any private individual or Director.
Type of information
There are two types of information we need to collect. Essential information and Demographic information.
Essential Information is information that is essential for us to provide a service to members of the electronic Kingston Pound payment system. These include: Name; User Name; Mobile Number; and your email address. Demographic Information is information that is not essential but would be useful to the project. This information enables us to assess the relative impact or success of the project and how that differs in different parts of the borough. It is therefore useful if you provide an address and post code but this is not essential information.
We do not need any other information about you although, we may from time to time change the information we need to collect, if that was necessary to comply with other regulations. For example Money Laundering Regulations as defined in the Money Laundering Terrorist Financing and Transfer of Funds (information on the payer) Regulations 2017.
Why do we need the Essential information?
The electronic payment system runs on the Cyclos software via our payment app and can be used via Text2Pay. Both of these methods require a unique mobile number and email address. If you do not provide us with this information you cannot participate in the electronic Kingston Pound payment system.
Your email and mobile phone number will be used to confirm trades you make. You will receive an email and a text message confirming each trade. It is important that we can email you to inform you of any system developments and updates to the project or any other legitimate reason for operating the Kingston Pound.
How we protect your personal data?
We will not transfer your personal data to any outside party without your consent or unless this was essential to providing you with a good service. We will also not share any details with other members of the system. For example we would not provide a list of emails to a business member so they can market their products to you. Any information shared with a third party business would be governed by an agreement that would restrict what they can do with the information. Nor would we provide a list of business contact data to any other business wishing to do the same. Our affiliation with publishers, magazines or press will not lead to the sharing of any of your personal data. If you are a business the only data we would make visible would be that already existing in the public domain.
When you register as an individual member or business member on the ‘Town Pound’ system, it will show other members that you are also a member and identify you by your user name. No other data will be displayed. It is therefore possible to use a user name that does not identify you.
The payment system is run on the Cyclos Banking Software which is hosted by Bristol Pound CIC, one of the largest local currency systems in the world. They have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
The Kingston Pound WebsiteOur general web site www.kingstonpound.org is the place where you will find information about the project such as resources and guides as to how to participate. The web site will contain information about the businesses involved in the system but not private individual members. The list of businesses will only contain information that would normally be available in the public domain from the web sites of the individual businesses. Links to business web sites and a map location is useful to help people find businesses and useful for businesses for visibility.
The TownPound Web Site https://townpound.community-currency.org/cyclos/kingston/
The payment system registration is reached via the URL above. You will notice that this has the ‘https’ prefix which is a secure internet protocol. This is the place where you register a Kingston Pound account and enter your Essential information and the option to enter Demographic information such as your address and postcode. It might be deemed important for a business member to enter their business address but some businesses have no High Street presence and operate on market stalls etc. An address or location is therefore optional.
The electronic payment system will hold details of trades you have made, with whom and when. Over time this would build into a large list of transactions. Individual users can see where they have been spending their Kingston Pounds. Businesses can see the receipts of Kingston Pounds and can interrogate the data relating to their business for the purposes of financial reporting. They will be able to identify their Kingston Pound customers but only to the extent of the usernames given. No other demographic information will be made available to business users.
Converting Sterling into Kingston Pounds
This is done by sending money to our bank account with Boom Credit Union and you do not need to share any information with Boom Credit Union unless you decide to open an account with them. When a payment is made to them this will trigger a top up to your Kingston Pound account and you will be notified of this via text and email. Obviously, this is an essential task needing certain Essential information.
Who else has access to the information you provide to us?
The only organization with access to your information is Bristol Pound CIC who host the Kingston Pound system on their secure servers. They will treat your information in exactly the same way as Kingston Pound and not share your data or sell your data to anyone else.
We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf or to meet reporting requirements. However, we only disclose personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
How long do we keep your information?
We will hold your personal data on our systems for as long as you are a member of the Kingston Pound.
Withdrawing consent for us to hold your data will essentially mean that you want us to delete the Demograpic and or the Essential information we hold. As described above, if you ask us to delete your Essential information, this will involve deleting your Kingston Pound account. Deleting an account may prevent you and us from being able to comply with certain legal obligations. For example, a business is required to keep financial records for at least six years for Tax purposes. Under these circumstances it would make sense to keep the Kingston Pound account open so that you can access transactional records held by the system. If you ask us to delete your account we will do so if you instruct us via email but, Kingston Pound take no responsibility for any loss of financial records that you might need later on.
An alternative to deleting your account is to ask us to deactivate it so that it remains in an archived form. This will able you and us to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
How do you withdraw your consent?
You may ask us to delete your data from our system at any time via an email to firstname.lastname@example.org
If asked to delete an account we will destroy all data and transaction history. However, it might be better to deactivate the account and keep the archived records for a further six years (in line with accounting and reporting to HMRC) and then permanently delete the account and transaction history at the end of six years. We will still require you to email us the instruction to delete your account at the end of six years.
If you are making a regular payment to Boom Credit Union, your bank details will be protected by the GDPR policy of the credit union. Kingston Pound will never have access to your bank details.
It may be appropriate to delete your data immediately and we will do this if you email this request on the understanding that Kingston Pound is not held responsible for any legal consequences of doing so.
You have rights under the GDPR:
(a) to access your personal data
(b) to be provided with information about how your personal data is processed
(c) to have your personal data corrected
(d) to have your personal data erased in certain circumstances
(e) to object to or restrict how your personal data is processed
(f) to have your personal data transferred to yourself or to another business in certain circumstances.
You have the right to take any complaints about how we process your personal data to the Information Commissioner: https://ico.org.uk/concerns/
0303 123 1113. Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
For more details, please address any questions, comments and requests regarding our data processing practices to our Data Protection Manager email@example.com
If you have any queries, questions or comments on the information contained in this document kindly contact us at firstname.lastname@example.org
Kingston Pound Responsibility Statement:
Kingston Pound takes all reasonable care to ensure that the information contained in this guidance is accurate and that any opinions, interpretations and guidance expressed have been carefully considered in the context in which they are expressed. However, before taking any action based on the contents of this guidance, readers are advised to confirm the up to date position and to take appropriate professional advice specific to their individual circumstances.