Privacy Policy

Last Updated: January 2025

1. Introduction

Gosen Group Limited ("we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you interact with our services, visit our website, or engage with us in any capacity.

Company Details:

Company Name: Gosen Group Limited
Company Number: 11425704
Registered Address: 6k Red Rose Court, Sunnyhurst Road, Blackburn BB2 1PS

This policy applies to all personal data processed by Gosen Group Limited in connection with our land management, allotment services, biodiversity enhancement, and related activities across England, Wales, and Scotland.

2. Information We Collect

We collect and process various types of personal information depending on your relationship with us:

If you are an allotment plot holder or site tenant: We collect your name, address, telephone number, email address, emergency contact details, payment information, correspondence records, site access records, and any information you provide in your tenancy application or during the course of your tenancy.

If you are on our waiting list: We collect your name, contact details including address, telephone number and email, plot size preferences, accessibility requirements if disclosed, and the date of your application.

If you are a local authority or landowner partner: We collect contact details of relevant officers and representatives, correspondence records, site information, contractual documentation, meeting notes, and any information shared during partnership discussions or site assessments.

If you submit an enquiry or contact us: We collect your name, email address, telephone number if provided, the content of your message or enquiry, and any other information you choose to provide.

If you apply for a job with us: We collect your name, contact details, CV and employment history, educational qualifications, references, right to work documentation, and any other information you provide in your application or during the recruitment process.

If you visit our website: We may collect technical information including your IP address, browser type and version, time zone setting, operating system and platform, and information about your visit including pages viewed, time spent on pages, and navigation paths.

If you visit one of our sites: We may collect photographic or video records for security, site management, or promotional purposes. Where CCTV is in operation, signage will clearly indicate this.

3. How We Use Your Information

We use your personal information for the following purposes:

For plot holders and tenants: To manage your tenancy including plot allocation, rent collection, site access, maintenance coordination, and compliance with tenancy terms. To communicate with you about your plot, site matters, events, and any issues requiring attention. To maintain waiting lists and allocate plots fairly. To ensure site security and safety. To resolve disputes or complaints. To maintain accurate records for legal and operational purposes.

For partners and stakeholders: To assess partnership opportunities and conduct site feasibility studies. To develop and present proposals for land optimization projects. To manage ongoing partnerships including reporting, compliance, and service delivery. To communicate about projects, meetings, and strategic matters. To maintain contractual and legal records.

For enquiries and general contacts: To respond to your questions, comments, or requests. To provide information about our services. To assess whether we can help with your specific needs. To maintain records of correspondence.

For job applicants: To assess your suitability for roles with Gosen. To conduct recruitment processes including interviews and reference checks. To verify your right to work in the UK. To communicate with you about opportunities. To maintain records of applications.

For all categories: To comply with legal obligations including health and safety, employment law, tenancy law, and regulatory requirements. To establish, exercise, or defend legal claims. To improve our services and understand how people interact with our sites and business. To prevent fraud, security breaches, or other harmful activities.

4. Legal Basis for Processing

We process personal data under the following legal bases as defined by UK GDPR:

Contractual necessity: Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract. This applies to tenancy agreements, partnership contracts, and service provision.

Legitimate interests: Where processing is necessary for our legitimate business interests or those of a third party, provided these interests are not overridden by your rights and interests. This includes business development, site management, security, fraud prevention, and improving our services.

Legal obligation: Where we must process your data to comply with legal requirements including health and safety law, employment law, tax obligations, and regulatory requirements.

Consent: Where you have given clear consent for us to process your personal data for a specific purpose, such as receiving marketing communications or participating in promotional photography. You may withdraw consent at any time.

5. Data Sharing and Disclosure

We may share your personal information with the following categories of recipients:

Local authorities and landowners: Where we manage sites on behalf of councils or private landowners, we may share relevant information with these partners as necessary for site management, compliance, reporting, and contractual obligations.

Service providers: We work with third-party service providers who process data on our behalf including IT systems providers, payment processors, accounting services, professional advisors, maintenance contractors, and administrative support services. These providers are contractually bound to protect your data and use it only for the purposes we specify.

Legal and regulatory authorities: We may disclose information where required by law, in response to legal processes, to protect our rights or property, to prevent harm or illegal activity, or in connection with an investigation.

Professional advisors: We may share information with solicitors, accountants, auditors, insurers, and other professional advisors where necessary for obtaining advice or services.

Prospective buyers or investors: In the event of a sale, merger, or restructuring of our business, personal data may be transferred to prospective buyers or investors subject to appropriate confidentiality obligations.

We do not sell personal data to third parties. We do not share your information with third parties for their own marketing purposes.

6. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations.

Tenancy and plot holder records: We retain active tenancy records for the duration of your tenancy plus six years after termination to comply with financial record-keeping requirements and to manage any subsequent queries or claims.

Waiting list information: We retain waiting list records while your application is active. If you do not respond to allocation offers or communication attempts, we may remove your details after twelve months of inactivity.

Partnership and contract records: We retain partnership documentation for the duration of the partnership plus six years after termination to comply with contractual and legal requirements.

Correspondence and enquiries: General correspondence is typically retained for three years unless it relates to ongoing matters or legal requirements dictate longer retention.

Job applications: Unsuccessful applications are retained for twelve months to enable us to consider candidates for future opportunities. Successful applicant records are retained in accordance with employment law requirements.

Financial records: Financial information including payment records and invoices are retained for six years to comply with tax and accounting requirements.

Security footage: Where CCTV is in operation, footage is typically retained for thirty days unless required for investigation purposes.

After retention periods expire, we securely delete or destroy personal information unless we are required to retain it by law.

7. Your Rights

Under data protection law, you have the following rights:

Right of access: You have the right to request a copy of the personal information we hold about you. We will provide this within one month of your request unless the request is complex or we receive multiple requests, in which case we may extend this by two months.

Right to rectification: You have the right to request correction of inaccurate or incomplete personal information we hold about you.

Right to erasure: You have the right to request deletion of your personal information in certain circumstances, such as where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent on which processing was based.

Right to restriction: You have the right to request that we restrict processing of your personal information in certain circumstances, such as where you contest the accuracy of the data or object to processing.

Right to data portability: Where processing is based on consent or contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

Right to object: You have the right to object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests.

Right to withdraw consent: Where processing is based on consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing before withdrawal.

Right to lodge a complaint: You have the right to lodge a complaint with the Information Commissioner's Office if you believe your data protection rights have been violated. The ICO can be contacted at ico.org.uk or by telephone on 0303 123 1113.

To exercise any of these rights, please contact us using the details provided at the end of this policy. We may need to verify your identity before fulfilling your request.

8. Data Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage.

Security measures include secure storage of physical records, password protection and encryption of electronic systems, restricted access to personal information on a need-to-know basis, regular security assessments and updates, secure disposal of data when no longer required, and contractual requirements for third-party processors to maintain adequate security.

While we take reasonable precautions to protect your information, no method of transmission or storage is completely secure. We cannot guarantee absolute security but we are committed to protecting your data to the highest reasonable standard.

9. International Transfers

Your personal information is primarily stored and processed within the United Kingdom. Where we engage service providers located outside the UK, we ensure appropriate safeguards are in place to protect your information in accordance with UK data protection standards. This may include using providers subject to adequacy decisions or implementing standard contractual clauses approved by the UK authorities.

10. Children's Privacy

Our services are not directed at children under the age of sixteen. We do not knowingly collect personal information from children. Plot holders and site users must be eighteen or over. Where children visit sites accompanied by adults, we may collect minimal information for safety purposes such as names for emergency contact lists. If you believe we have collected information from a child inappropriately, please contact us immediately.

11. Cookies and Website Technologies

Our website may use cookies and similar technologies to improve functionality and user experience. Cookies are small text files stored on your device when you visit a website.

We may use essential cookies that are necessary for the website to function properly, analytics cookies to understand how visitors use our site and improve performance, and functional cookies to remember your preferences and enhance your experience.

You can control cookies through your browser settings. Blocking certain cookies may affect website functionality. Our website may contain links to third-party websites. We are not responsible for the privacy practices of external sites.

12. Marketing Communications

We may send you information about our services, site news, events, and opportunities that we believe may be of interest to you. We will only do this where we have a lawful basis to do so.

If you are a plot holder or tenant, we may contact you about matters directly relevant to your site or tenancy as part of our service provision. This is not considered marketing.

For other marketing communications, we will seek your consent or rely on legitimate interests where appropriate. You can opt out of marketing communications at any time by following unsubscribe links in emails, contacting us directly, or updating your preferences.

Opting out of marketing will not affect service communications necessary for site management or contractual purposes.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. The updated policy will be posted on our website with the revised date clearly indicated.

Where changes are significant or affect how we use your personal information, we will notify you by email if we have your contact details or through prominent notice on our website.

We encourage you to review this policy periodically to stay informed about how we protect your information.

14. Third-Party Links and Services

Our website and communications may contain links to third-party websites, services, or resources. We are not responsible for the privacy practices or content of external sites. We encourage you to review the privacy policies of any third-party services you access through our links.

Where we integrate third-party services such as payment processors or mapping tools, these services may collect information in accordance with their own privacy policies. We select reputable providers and require them to handle data responsibly, but we cannot control their practices.

15. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on individuals. Plot allocations, tenancy decisions, and partnership assessments involve human review and judgment.

16. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or need to discuss how we handle your personal information, please contact us:

By Post: Data Protection Enquiries Gosen Group Limited 6k Red Rose Court Sunnyhurst Road Blackburn BB2 1PS

We aim to respond to all enquiries within five working days. For subject access requests and formal rights exercises, we will respond within the timeframes required by law.

17. Supervisory Authority

If you are not satisfied with how we handle your personal information or believe we have violated data protection law, you have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner's Office (ICO) Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Telephone: 0303 123 1113 Website: ico.org.uk

This Privacy Policy is effective from January 2025 and applies to all personal data processed by Gosen Group Limited.