Broadband Coop, Mobile Coop and Energy Coop – Privacy Notice
Introduction
Broadband Coop, Mobile Coop, Energy Coop (Trading Names for Central England Co-operative Limited) is committed to ensuring the privacy of colleagues is protected. Should we ask you to provide personal data, then it will only be used in accordance with this Privacy Notice. We will collect and process the personal data relating to you for the management of your relationship with our trading groups. We are committed to being transparent about how we collect and use that personal data and to meet our data protection obligations.
Who we are
Central England Co-operative Limited
ICO registration: Z616328X
Queen Street
Lichfield
Staffordshire
WS13 6QD
We have appointed a Data Protection Officer (DPO), who can be contacted via the following email address should you have any questions about the way your personal data is handled.
Email: enquiries@centralcoop.co.uk
Personal data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you and your child which we have grouped together as follows:
Category of personal information | Description |
Identity details | First name, last name, title, date of birth, gender, image, national insurance number, OurCoop membership number. |
Contact details | Telephone number(s), email address(es), postal address(es), work address(es), any site addresses where we provide our services. |
Sensitive data | Includes information relating to health, race, religion or ethnicity, criminal convictions or offences. |
Financial data | Sort code, card number, expiry date, account number, credit commitments, payment history, account name, bank branch, transaction date. payment details relating to childcare services provided. |
Technical data | IP address, operating system, web browser, device ID, cookies, |
Communication details | Feedback, questions, notes, any data that is contained within a message body or a subject from an individual. |
Profile details | Your interests and preferences. |
Marketing details | Your preferences to receive marketing. |
Health details | Medical history, mental health details, disability details, all data concerning an individual’s health. |
When you first order any services from us, or buy certain new services, we run a credit check on you. To do that we pass some of your personal information to credit reference agencies. Further details of how we use credit reference agencies are set out later in this notice.
We, and our suppliers, keep information about how you're using your broadband to help us understand and manage traffic flows on our network, and improve our services. That includes IP addresses and other traffic data including websites you've visited. We are sometimes contacted by third parties who monitor illegal online file sharing on behalf of copyright holders. If we receive a claim that there has been illegal sharing on your broadband service, we may use your IP address to notify you. But unless we are required to by law, we will not disclose your personal information to the copyright holder or any party acting on their behalf.
When you use our telecommunication services, we record certain things about that use. They include the amount you spend, the numbers you call or text (but not the content of the text), the numbers that call or text you, and the location of the cell that you make a call from. We also record the time and the length of all incoming and outgoing services like calls, texts and picture messages (MMS) and data use while you're in the UK and abroad.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be 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 Usage Data to calculate the percentage of users accessing a specific website feature. However, 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.
Apart from the Sensitive Data referred to above, we do not collect any other Special Categories of Personal Data about you (this also includes details about your race, sex life, sexual orientation, political opinions, trade union membership and information about your genetic and biometric data).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products and services). We will notify you if this is the case at the time.
How we collect your personal data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial, Sensitive and Transaction Data by filling in forms or by corresponding with us online or by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to purchase our products and services;
- enquire about our goods and services;
- subscribe to our services or publications;
- request marketing to be sent to you;
- enquire about our community involvement;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Profile and Usage Data. We will also collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Credit Reference Agencies. We and our service providers will search your record at credit reference agencies who will supply us with credit information as well as information from the Electoral Register, about you. We may use credit scoring or other automated decision-making systems when assessing your application and to verify your identity. Credit searches and other information which is provided to us and/or the credit reference agencies, about you and those with whom you are linked financially may be used by us and other companies on an ongoing basis to make other credit decisions about you, or other members of your household to support
Why do we process your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the collection and use of Sensitive Data and sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
In some circumstances we can use your personal data if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is. A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable. If we are relying on legitimate interests, we have set that out in the table below.
Purposes for processing | Categories of personal data | Lawful basis for processing | Legitimate Interests (if applicable) |
To carry out our obligations arising in connection with any contracts entered into between you and us, or between you and a third party supplier, including:
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| To Recover debts owed to us. |
To manage our relationship with you which will include:
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| To keep our records updated. To study how customers use our products/services. For colleague training and customer service. |
For research and insight purposes. Including data analytics. |
|
| Study how customers use our product/services. |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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| To study how customers use our products/services. To develop them, to grow our business and to inform our marketing strategy. |
To enable you to subscribe to our newsletter, partake in a prize draw, competition or complete a survey |
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| To study how customers use our products/services. To develop and grow our business. |
To administer and protect your business and this website. |
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| Running our business, quality assurance, training and IT systems and networks. |
When you provide your consent for OurCoop’s Family of Businesses to provide marketing materials to you, we may use your identity, contact, marketing and profile details to tailor the goods, products and service communications we send you.
We utilise a preference centre which allows customers to select their preferences on what content they would be most interested to receive.
Third-party marketing
We will gather your consent before we share your personal data with any internal third parties, such as other OurCoop trading groups, or any company outside of OurCoop for marketing purposes.
Opting out
We won't use your personal data for marketing purposes at all if you've told us not to. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Who we share your data with?
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal third parties such as other legal entities in the OurCoop group who provide administrative services and undertake management reporting.
- External third parties including the following:
- Government bodies or other organisations who are responsible for regulating the industries in which we operate.
- Third party suppliers who help us to provide services to you.
- Directory Enquiries (for relevant services only) unless you have requested to be ex-directory.
- Our Affinity partners or Agents who introduced you to our services in order to provide them with commission details.
- Organisations to which we may outsource certain of our activities, such as printing, mailing and distribution services.
- Organisations that provide customer identity and address verification services.
- Organisations doing research for us.
- Organisations for the detection, investigation and prevention of crime, such as the National crime Agency in respect of money laundering.
- Financial organisations for purposes such as payment processing, finance plans and refunds.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
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.
Transferring personal data outside of the EEA
The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. If we transfer your personal data outside of the EEA, we must tell you and we must rely on one of the following:
- Adequacy Decision: The country we send your personal data to provides an adequate level of protection which has been approved by the European Commission.
- Standard Contractual Clauses (with the IDTA Addendum): The recipient of your personal data has provided us with signed Standard Contractual Clauses with the IDTA Addendum include. This holds the recipient accountable to safeguard the personal data.
- International Data Transfer Agreement (IDTA): The recipient of your personal data has provided us with a signed IDTA which has been approved by the Information Commission. This holds the recipient accountable to safeguard the personal data.
Currently there are no circumstances where your personal data is transferred outside of the EEA.
How do we protect your personal data?
We take the security of your personal data seriously. We have internal policies and controls in place to ensure that we have implemented measures to ensure that your data is not lost, accidentally destroyed, misused, or disclosed without our authority, and is not accessed except by our colleagues only in the performance of their professional duties.
Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are operating under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
Retention of your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes of our processing. This includes satisfying any legal, accounting, or reporting requirements.
When we assess the retention of your personal data, we will take the following into consideration:
- Nature of the information;
- Sensitivity of the information;
- Potential risks if the information was breached;
- The purpose(s) for which we initially processed the information;
- Whether we can achieve the purpose(s) through less invasive means; and
- Any applicable legal requirements.
Your Rights
All individuals who engage with us have data subject rights relating to the processing of their personal data. These are the rights that apply to your personal data held by us.
- The right to be informed – you have the right to know what information we hold and process about you which is why we have provided this Privacy Notice.
- The right of access – you have the right to ask for a copy of the information we hold regarding yourself.
- The right to rectification – you have the right to ask for us to correct any information we hold which may be inaccurate or incorrect.
- The right of erasure – you have the right to have your personal data ‘erased’ in the following situations:
- Where the personal data is no longer required for the purpose(s) for which it was originally collected or processed;
- Where the processing was based on consent and you have withdrawn your consent;
- When the personal data was unlawfully processed; and
- When the personal data has to be erased in order to comply with a legal obligation.
We will erase your records when one of the above situations apply.
- The right to object – you have the right to object to the processing of your personal data in the following circumstances:
- The purpose of the processing activity is direct marketing;
- Where the processing is based on legitimate interests; and
- Processing for the purposes of scientific/historical research and statistics.
- The right to restriction of processing – you have the right to ask us to restrict the processing of your personal data in certain situations such as:
- Where you contest the accuracy of your personal data, we will restrict the processing until you have verified the accuracy of your personal data;
- When processing is unlawful, and you oppose erasure and request restriction instead; and
- Where we no longer need the personal data, but you require the information to establish, exercise or defend a legal claim.
- The right to data portability – You have the right to request that we transfer your personal data to a third-party. This right only applies to automated personal data which you have either provided your consent for us to use or where we have used your personal data to perform a contract with you.
- Rights in relation to automated decision-making including profiling – you have the right to question decisions being made about you without any human involvement.
If you would like to exercise any of these rights, please contact us at enquiries@centralcoop.co.uk
Changes to this Privacy Notice
We may update this Privacy Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions in relation to this notice, please contact our DPO at enquiries@centralcoop.co.uk
Links to other websites
This 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. When you leave our website, we encourage you to read the privacy notice of every website you visit, particularly third party websites as we do not control those.
We use live chat software on our website, this is provided by Click4Assistance, a 3rd party UK based Software Company. Information regarding how the data is processed and stored can be viewed here.
https://www.click4assistance.co.uk/click4assistance-web-chat-software-cookie-policy.
Not happy?
Please let us know if you are unhappy with how we have used your personal data by contacting our DPO.
As stated in The Data (Use & Access) Act 2025, you have the right to lodge a data protection complaint with us, should you be unhappy with the way we have processed your personal data.
Your complaint will be managed and responded to by our Data Protection Officer (DPO). Their role will be a conduct an independent investigation into the grounds for your complaint and provide an outcome to you. Your complaint will be responded to with a final written response within 30 days of receipt.
Should you wish to make a data protection complaint, this can be done by contacting the DPO in the following ways:
Email: enquiries@centralcoop.co.uk
If you are dissatisfied with how your data protection complaint has been managed, you also have the right to lodge a complaint with the Information Commission (ICO). We would be grateful for the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
You can find their contact details below:
Address: Information Commission
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF
Telephone: 0303 123 1113