We know that there is a lot of information here, but we want you to be fully informed about your rights, and how the Devonshire Group uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
About the Devonshire Group
The Devonshire Group is made up of a number of related businesses:
- The Chatsworth Settlement – the entity that owns and runs our estates in Derbyshire, Yorkshire and Eastbourne.
- Chatsworth House Trust (CHT) – the charity responsible for the house, garden and farmyard
- Chatsworth House Enterprises Ltd (CHEL) – the organisation that runs events including the horse trials and country fair
- Chatsworth Estate Trading Ltd (CETL) – the organisation that manages the shops and restaurants on the Chatsworth Estate
- Devonshire Hotels and Restaurants Group Limited and the Peacock Hotel (Baslow) Limited – the organisations that run our hotels and holiday cottages business.
- The Lismore Estate and Lismore Castle & Gardens – our estate and hospitality business in Ireland.
For simplicity throughout this policy, ‘we’ and ‘us’ refers to the organisations listed above.
Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. Eg. When you tick a box to receive email newsletters
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. Eg. If you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and we may pass them to our courier.
If the law requires us to, we may need to collect and process your data. Eg. We can pass on details of people involved in fraud or other criminal activity affecting the Devonshire Group to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. Eg. We may use your purchase history or specified interests to send you or make available personalised offers, or may also use your email address to send you direct marketing information, telling you about products and services that we think might interest you.
When do we collect your personal data?
- When you visit our websites, and use your account to buy tickets, or redeem vouchers, book rooms, cottages or tables in our restaurants
- When you create an account with us
- When you purchase a product or service on the estate or by phone but don’t have (or don’t use) an account
- When you engage with us on social media
- When you purchase a Friends membership
- When you contact us by any means with queries, complaints etc
- When you enter prize draws or competitions.
- When you choose to complete any surveys we send you
- When you comment on or review us
- When you’ve given a third party permission to share with us the information they hold about you
- We may collect data from publicly available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law
- When you visit our establishments or use our car parks, which usually have CCTV systems operated for the security of both visitors and employees. These systems may record your image during your visit
- When you sign up to use our public wifi
- When you ask us to send you e-newsletters
What sort of personal data do we collect?
- If you have a web account with us; your name, billing/delivery address, orders, email and telephone number. For your security, we may also keep an encrypted record of your login password.
- Details of your interactions with us online, on the phone or on the estate. Eg. We may collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items, web pages you visit and how and when you contact us
- Details of your interests and visiting habits. Eg. Which tickets you purchase, and when you visit us and/or details of your activities when you stay with us
- Details of your visits to our website and which site you came from to ours
- Personal details that help us to recommend items of interest. Eg. If you live close to Chatsworth, we may send you details about Friends memberships. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your experience with us. Of course, it’s always your choice whether you share such details with us
- Payment information
- Your comments and product reviews
- Your image may be recorded on CCTV when you visit our establishments or use our car parks
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback
How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We may then use this to offer you promotions and products that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Here’s how we may use your personal data and why:
- To process any orders that you make by using our website, on the phone or on site. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. Eg. Your details may need to be passed to a third party to supply or deliver the product that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our visitors, premises, assets and employees from crime, we operate CCTV systems across the Devonshire Group, which record images for security. We do this because of our legitimate business interests.
- To process payments and to prevent fraudulent transactions. We do this because of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
- With your consent, we may use your personal data, preferences and details of your transactions to keep you informed by email, web, text and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time by contacting us.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time by contacting us.
- To administer any of our prize draws or competitions that you enter, based on your consent given at the time of entering.
- To comply with our contractual or legal obligations to share data with law enforcement.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time by contacting us.
- To build a rich picture of who you are and what you like, and to inform our business decisions, we may combine data captured from across the Devonshire Group, third parties and data from publicly available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest. Eg. by combining this data, this will help us personalise your experience and decide which content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide our advertising plans
- To process your order (for example if you order a hamper for home delivery). Sometimes, we may need to share your details with a third party who is providing a service (such as delivery couriers). Without sharing your personal data, we’d be unable to fulfil your request.
Combining your data for personalised direct marketing
We want to bring you information, offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we may combine your personal data gathered across the Devonshire Group as described above. For this purpose we may also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry mentioned above.
How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all areas of our website using ‘https’ technology.
Access to your personal data is password-protected.
We regularly monitor our system for possible vulnerabilities and attacks.
How long we will keep your personal data
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
An example of a customer data retention period is when you make a purchase from us. When you make a purchase, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties. Eg. Delivery couriers, the organisations set out in ‘About the Devonshire Group’ above.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- Ticket fulfilment/processing companies, such as See Tickets
- IT companies who support our website and other business systems
- Operational companies such as delivery couriers
Sharing your data with third parties for their own purposes. We will only do this in very specific circumstances, for example:
- For fraud management, we may share information about fraudulent or potentially fraudulent activity on our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government bodies, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis, and take the privacy of our customers into consideration.
Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. Eg. Some third parties we use to store your data, such as those we use to send e-newsletters, may be based outside the EEA.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, we only work with organisations who have robust and trusted data protection policies, that meet the standards required within the EEA. If you wish for more information about these companies, please contact us.
What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete. Eg. when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a Friends membership).
- That we stop using your personal data for direct marketing (through either specific, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that the Devonshire Group holds at any time, and to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection, The Information Technology Department, The Devonshire Group, The Estate Office, Bakewell, Derbyshire, DE45 1PJ, or email firstname.lastname@example.org. To ask for your information to be amended, please update your online account, or contact our Customer Services team.
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data because of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular organisation. Please note that if you are subscribed to communications from more than one of the organisations listed in section 2 ‘About the Devonshire Group’, we will only stop communications from the specific organisation that you unsubscribe from.
- Email email@example.com
- Write to Data Protection, The Information Technology Department, The Devonshire Group, The Estate Office, Bakewell, Derbyshire, DE45 1PJ
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Contacting the regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK, or elsewhere.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK, or elsewhere.
If you have any questions that haven’t been covered, please contact us:
- Email us at firstname.lastname@example.org
- Or write to us at Data Protection, The Information Technology Department, The Devonshire Group, The Estate Office, Bakewell, Derbyshire, DE45 1PJ, The Estate Office, Bakewell, Derbyshire, DE45 1PJ
This policy was last updated on 21/05/2018
Devonshire Group Privacy Notice - Recruitment
Data controller: The Devonshire Group (referred to as ‘we’ below)
The Estate Office
As part of any recruitment process, we collect and process personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
What information do we collect?
We collect a range of information about you. This includes:
- Your name, address and contact details, including email address and telephone number
- Details of your qualifications, skills, experience and employment history
- Information about your current level of remuneration, including benefit entitlements
- Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process
- Information about your entitlement to work in the UK
- Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief (this information is held and processed anonymously).
We collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, or collected through online applications, interviews or other forms of assessment.
We will also collect personal data about you from third parties. This could be from recruitment agencies to which you have submitted an application and given permission to pass on to us. Or it could be references supplied by former employers and information from criminal records checks - we will seek this information only once a job offer to you has been made and will inform you that we are doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why do we process personal data?
We need to process data to fulfil the requirements of the recruitment process. We also need to process your data to enter into a contract with you.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of employees or workers and have concluded that they are not.
We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.
For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.
We will not use your data for any purpose other than the recruitment exercise for which you have applied.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you and the Disclosure and Barring Service to obtain necessary criminal records checks, if that is a requirement of the role.
We will not transfer your data outside the European Economic Area
How do we protect data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Details of these policies and controls are outlined in the employee handbook or are available from the HR department at the address above or HR@chatsworth.org.
For how long do we keep data?
If your application for employment is unsuccessful, we will hold your data on file for no longer than six months after the end of the relevant recruitment process. At the end of that period your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held are available in our data retention policy.
As a data subject, you have a number of rights. You can:
- Access and obtain a copy of your data on request
- Require us to change incorrect or incomplete data
- Require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
- Object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing
- Ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact the HR department at the address above or HR@chatsworth.org. You can make a subject access request by completing the relevant form (available from HR department).
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Recruitment processes are not based solely on automated decision-making.
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