Data Privacy Policy for Save the Kings Arms

  Privacy Notice for Shareholders and Members of a Charitable Community Benefit Society Operating a Community Pub

1. Introduction

This Privacy Notice explains how we collect, use, store, and protect the personal data of our shareholders and members. As a Charitable Community Benefit Society (CCBS) operating a community‑owned pub, we process personal data to manage membership, run the Society, and operate the pub responsibly and lawfully.

We are committed to handling your information lawfully, fairly, and transparently in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data Controller

Polebrook Community Hub Limited
A Charitable Community Benefit Society registered with the Financial Conduct Authority
Registration Number: 9794
Registered Address: Polebrook Village Hall, Hemington Road, Polebrook, Northants., PE8 5LR
Email: info@savethekingsarms.co.uk

 

Data Protection Officer (DPO)

Emma Morehen

Email: info@savethekingsarms.co.uk
Address: c/o Polebrook Village Hall, Hemington Road, Polebrook, Northants., PE8 5LR

 

3. Personal Data We Collect

We may collect and process the following information about you as a shareholder or member:

Membership and Shareholding

• Name, postal address, email address, telephone number
• Date of birth (where required for eligibility)
• Shareholding details (number of shares, certificate numbers, membership status)
• Records of payments (share purchases, withdrawals, interest payments)
• Attendance and voting records at general meetings
• Communications between you and the Society

Pub Operations (if relevant to you as a member)

• Volunteer rota information (if you volunteer at the pub)
• Training records (e.g., food hygiene, licensing)
• Incident reports (only where necessary for safety or legal compliance)

Identification

• ID documents where legally required (e.g., anti‑money laundering checks for certain transactions)

We do not collect unnecessary data.

4. How We Collect Your Data

We collect your personal data:

• When you apply for membership or purchase shares
• Through pledge forms, share application forms, transfer forms, or online submissions
• When you communicate with us by email, phone, or in person
• When you volunteer or participate in Society activities
• From publicly available sources where relevant (e.g., Companies House for directors)
• From third parties where legally required (e.g., banks, payment providers)

5. Purposes for Processing Your Data

We process your personal data to:

Society Governance

• Maintain the statutory Register of Members
• Manage your shareholding and membership rights
• Communicate with you about meetings, votes, and Society business
• Issue share certificates and manage share transactions.
• Pay interest on share capital (where applicable)
• Meet our legal and regulatory obligations as a registered society

Running the Community Pub

• Manage volunteer rotas and training
• Ensure health, safety, and licensing compliance
• Respond to incidents or complaints
• Support the smooth running of the pub and its community activities

General Administration

• Respond to enquiries
• Maintain accurate records
• Produce anonymised or aggregated data for reporting or impact measurement

6. Lawful Bases for Processing

Our lawful bases under UK GDPR include:

• Legal obligation — maintaining the Register of Members, issuing statutory notices, complying with FCA and licensing requirements, effective governance, communication, and operation of the Society and pub
• Contract — managing your rights and obligations as a shareholder/member
• Consent — for optional communications not required by law (you may withdraw consent at any time)

7. Who We Share Your Data With

We may share your personal data with:

• The Financial Conduct Authority (FCA) or other regulators where required
• Professional advisers (legal, financial, auditors)
• Banks or payment providers for share transactions or interest payments
• IT and administrative service providers supporting our operations
• Licensing authorities or insurers where necessary
• Law enforcement or government bodies where legally required
• Auditing purposes

We do not sell your data or share it for marketing.

If data is transferred outside the UK, we ensure appropriate safeguards are in place.

8. How Long We Keep Your Data

We retain personal data only for as long as necessary to fulfil our legal and operational obligations.

Typical retention periods include:

• Register of Members — retained permanently, as required by law
• Financial records (e.g., share transactions, interest payments) — 6 years
• Volunteer records — up to 3 years after involvement ends
• Incident reports — as required by law or insurance
• General correspondence — up to 6 years

9. How We Protect Your Data

We use appropriate technical and organisational measures to keep your data secure, including:

• Restricted access to membership and financial systems
• Secure digital storage and encrypted communications where appropriate
• Staff and volunteer training on data protection
• Regular review of data handling practices

10. Your Rights

You have the following rights under UK GDPR:

• Access to your personal data
• Correction of inaccurate or incomplete data
• Erasure (in certain circumstances)
• Restriction of processing
• Objection to processing based on legitimate interests
• Data portability (where applicable)
• Withdrawal of consent (where consent is the lawful basis)
• The right to complain to the Information Commissioner’s Office (ICO)

ICO website: www.ico.org.uk

11. Contact Us

If you have questions or wish to exercise your rights, please contact:

Polebrook Community Hub Limited
Registered Address: Polebrook Village Hall, Hemington Road, Polebrook, Northants., PE8 5LR
Email: info@savethekingsarms.co.uk

12. Complaints

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact 

Polebrook Community Hub Limited
Registered Address: Polebrook Village Hall, Hemington Road, Polebrook, Northants., PE8 5LR
Email: info@savethekingsarms.co.uk

Alternatively, you can make a complaint to the Information Commissioner’s Office:

• Report a concern online at https://ico.org.uk/concerns/

• Call 0303 123 1113

• Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF