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The Marble Arch Partnership Privacy Policy

Marble Arch London BID was established following a successful ballot of businesses in February 2016. The legal basis for BIDs is set out in The Local Government Finance Act 2003 and The Business Improvement Districts (England) Regulations 2004.

The Marble Arch Partnership collects and processes personal information from three groups:

  • BID levy paying companies and their employees;
  • Stakeholders assisting us to deliver the BID’s objectives;
  • Individuals who sign up to receive our newsletter and security alerts, via our website.

This privacy policy explains how we will process the personal data you provide us with and what we do with it.

BID Levy Paying Companies and their employees: BID levy paying company information is obtained in the first instance from Westminster City Council’s revenue collection agent, Capita. This information shows a unique property reference number, rateable value, occupation dates, amount of BID levy due, payment history and billing address. The information comes to us in encrypted format and is stored as a password protected file on a password protected server. This information is transferred to an ACT database, which is held on the same server and is password protected. We also add the following personal information to the ACT database, associating with the unique property reference; named voter and contact details, nominated security personnel, nominated marketing and sales personnel, nominated HR and CSR personnel, any executive support to these posts, plus the details of employees from these companies who have expressed an interest in the BID’s services or attended BID training or events. Employees of BID levy paying companies also contact Marble Arch Partnership to enquire about individual/team volunteering events delivered by our Community Programme. We ask all new contacts for consent to add their details to our newsletter mailing list.

Stakeholders: In order to deliver the BID’s objectives, we collect and process personal data (names and contact information) from key public and statutory agencies, such as Westminster City Council, Transport for London, the Greater London Authority, Metropolitan Police and local amenity societies. This data is held on an ACT database. We ask all new contacts for consent to add their details to our newsletter mailing list. Our Community Programme also works with companies/charities/schools who may be just outside of the BID levy area or are below rateable value for the purpose of delivering local volunteering activities.

Individuals who sign up to receive our newsletter and security alerts via our website: The newsletter sign-up section of the www.marble-arch.london website allows interested individuals to keep in touch with what the BID does. We do not transfer this information to the ACT database.

The Marble Arch London BID website

Like many websites, The Marble Arch Partnership website uses ‘cookies’ to help us make our website – and the way you use them – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields.

In addition, the type of device you’re using to access our websites or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using and your device settings. Your device manufacturer or operating system provider will have more details about what information your device makes available to us. We use Google Analytics to track visits to our websites (mainly which pages are visited the most, how visitors arrive at our website and routes users take through our website), but this is not linked with personal information held in ACT, Mailchimp or Eventbrite.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites, and such sites are not governed by this Privacy Policy.

How we use personal data

The Marble Arch Partnership takes your privacy seriously and we will only use the personal information you provide us to send you information about Marble Arch London BID’s projects and services.

Our newsletter and invitations

The Marble Arch Partnership only has access to the personal information that you voluntarily provide when you sign up to receive our newsletter or invitations and we only collect the information we require in order to distribute the electronic newsletter, security alerts and invitations.

If your company or organisation has not previously subscribed to the newsletter, attended training or events or engaged with projects run by us, and/or is a new member to the Marble Arch London BID, we may email you separately to welcome you and offer our services.

When we email our subscribers, we track who opens the emails and clicks through the links. This allows us to measure the performance of our email campaigns.

Please note, The Marble Arch Partnership uses MailChimp and Eventbrite as our marketing automation platforms. The personal information you provide will be transferred to MailChimp for the monthly newsletter and Eventbrite for training and event invitations for processing in accordance with their Privacy Policy and Terms & Conditions.

You may also opt out of receiving newsletter and invitation communications from us at any time by following the unsubscribe link at the bottom of each newsletter and invitation or by emailing getinvolved@marble-arch.london.

Day to day operations

We regularly reach out to individuals in businesses or organisations about a project from which that company will benefit, or to seek your views and input on a potential project. We use contact information from our ACT database for this, and all emails from our staff team to contacts on our database are recorded. We may also make a record on ACT of important meetings held with voters, and – during a BID ballot or renewal ballot – the voting intention and status per voter.

The Marble Arch Street Team

Marble Arch London BID deploys a Street Team to tackle anti-social behaviour, improve the environment and to support businesses, their staff, guests and customers. The Street Team’s activities are tracked using a system called SecuriGo, a bespoke platform operated by our contractors SecuriGroup. SecuriGo is fully compatible with GDPR in the UK. Only our staff team and SecuriGroup have access to this platform, which is protected by two factor authentication. .

The Street Team records business interactions on SecuriGo at the input level. These only include the name and address of the business premises, not personal data. If your business calls the Street Team for urgent assistance, only the name of the business and the address of your premises is recorded. No personal information is transferred from SecuriGo to our ACT database, nor to our newsletter and invitation mailing lists, unless a business or their representative explicitly requests that we add an individual’s details

The Street Team wear overt body cameras on their jackets. These film serious incidents and record images of individuals for crime prevention purposes only. They also take photographs using hand held mobile devices. These images are held on SecuriGo and only passed to the Metropolitan Police if a crime has been committed or Westminster City Council where a Criminal Behaviour Order is sought, and the information is required for evidential purposes.

Participating in volunteering

Employees of BID levy paying companies may access volunteering opportunities with local schools, charities and community groups via Marble Arch BID’s Community Programme. On occasion, employees from companies just outside the BID area or from companies occupying properties below the threshold to pay BID levy may enquire about or participate in volunteering activities. If you contact us to enquire about a volunteering role or team challenge event or participate in a volunteering activity through The Marble Arch Partnership, personal data will be collected.

If you make an enquiry we will keep a record of your name and contact details and the types of volunteering you are interested in for a maximum of five years, so that we can notify you in the future if similar roles become available. The lawful reason for doing this is legitimate interest. If you do not wish to receive follow up information about volunteering opportunities, you can ask for your personal data to be removed at any time by contacting us (our contact details can be found at the end of this Privacy Policy).

If you participate in a voluntary activity we will keep a register of volunteer names and contact details to keep you safe whilst participating (for fire evacuation purposes etc). For individual and team volunteering events we will ask for your consent when you volunteer to take photographs and only photograph you if you have given specific permission. At larger events such as the Great British Spring Clean where volunteers from multiple companies are participating, and particularly where we are employing a professional photographer, it will be made clear both during written briefing documents and in verbal briefings at the event that photographs are being taken. It is then the responsibility of individual volunteers to notify Marble Arch Partnership staff that they do not want to be photographed and to opt out. We will then ensure that you are not captured in photographs. The photographs and any film footage captured will be used on our website, social media and in marketing collateral; and copies will be shared with all volunteer teams including, if present, volunteers from other companies participating in the event. A selection of photographs will also be shared with our charity partners, particularly if they contain the charity partner’s service users or clients.

The Marble Arch Partnership may keep copies of photographs and film taken at volunteer events indefinitely. This is in order to keep an accurate record of events and activities delivered by The Marble Arch Partnership and to enable us to continue to document the development history of Marble Arch and recognise the people who played a part in its evolution. One of the Partnership’s objectives is to reflect, report on and celebrate the story of Marble Arch and photographs and film footage are essential to maintaining this historical record.

Once photographs are saved on The Marble Arch Partnership’s secure drive they will be deleted from Marble Arch Partnership employees’ phones/cameras.  Photographs and videos will be taken on Marble Arch Partnership employees’ work phones as opposed to personal devices.

We will request that any photographs or film shared with charity partners or schools are deleted five years after the volunteering event has taken place. Charity partners and schools will be reminded of this each time we share photographs and film with them. Please note that photographs and film shared with charity partners and schools may remain on their social media pages, website and in printed literature beyond this.

We will notify you in advance if we need to share your contact details with the charitable organisation you are volunteering for and will be very clear when you register for a voluntary activity what will happen to your data.

We will keep a record of your participation in volunteering so that we can include your contribution in our annual reporting on the impact of the Community Programme. The lawful reason for doing this is performance of contract. We will record details of the organisation you supported and the nature of the voluntary activity undertaken. This helps us to understand which opportunities may be of interest to you in the future.  We will scan registration sheets following your volunteering activity and store a soft copy electronically for five years in a password protected folder, at which point the record will be destroyed. Hard copies of registration sheets will be destroyed immediately after volunteer events in document shredders or confidential waste.

You may be asked to complete an anonymous feedback form at the time of your volunteering, or subsequently via an electronic platform e.g. Survey Monkey. The information you provide in this form helps us to ensure we deliver high quality, meaningful volunteering and contributes to our annual impact reporting. Feedback forms are kept for a maximum of five years, before being destroyed.

As a matter of course we do not collect or store sensitive data (e.g. allergies and medical information), however there are some situations where this will occur, including:

  • If you are participating in a volunteering event and have declared a medical condition in advance
  • If the nature of the volunteering you are participating in requires that this information is known – e.g., if you are working in a kitchen environment we would need to know if you had any food allergies
  • If an accident or incident occurs at a volunteering event an accident form will be completed at the site of the volunteering by the charity partner and a separate record will be kept by The Marble Arch Partnership. This helps us to monitor and review all volunteering activities and ensure activities remain safe for all participants. A copy of the accident report completed by The Marble Arch Partnership will be sent electronically to the volunteer(s) involved. All accident records are kept for five years at which point they are destroyed in confidential waste / electronic copies are deleted.
  • For some practical activities such as taking part in events on the canal or undertaking physical gardening tasks, we may ask volunteers for details of an emergency contact. This person will only be contacted in the event of an emergency and their personal details will be deleted immediately after the activity for which they were collected.

If we are going to collect this data we will communicate with you about the reasons for collecting and storing the data and how we will store it to ensure your privacy is maintained and gain your consent and permission to do this.

Some skilled volunteering may require greater information to be collected about a volunteer. For example, a copy of your CV may be requested prior to participation in a mentoring programme, to help match you to a mentee. In these instances the data we hold on you will be held only for the length of your involvement in the specific project, in password protected electronic folders. If the data is to be shared with a charity partner you will be informed in advance and the Community Programme Manager will ensure material is destroyed by the charity partner at the end of the project.

The Marble Arch Partnership does not undertake DBS or List 99 (safeguarding) checks on behalf of organisations it sends volunteers to and does not have access to the personal data you provide on these forms. The schools and charities we work with that require volunteers to complete DBS checks all have their own privacy policies and measures in place to keep your personal information safe. Occasionally we support volunteers by scanning copies of ID (passports, driving licence etc.) to help with completing DBS forms. In these instances all scanned ID is destroyed immediately once the DBS check is completed and stored in password protected folders whilst held by us.  If you have any questions about the process of completing a DBS check and who will have access to the information you provide, please contact us (our contact details can be found at the end of this Privacy Policy). If a DBS check were to flag a safeguarding concern, The Marble Arch Partnership and the charity partner would keep this information confidential; unless the volunteer’s paid employment involves them working with vulnerable people. It is the employer’s responsibility to carry out appropriate due diligence checks on employees.

Charities and schools promoting a volunteering activity

If you are an organisation looking to promote a volunteering role via The Marble Arch Partnership, we will collect your contact details so that we can keep in touch with you about potential volunteers. We will hold this information for a maximum of five years. If you no longer wish to recruit volunteers and do not want us to contact you, you can ask for your contact details to be removed at any time. Our contact details can be found at the end of this privacy policy.

With your consent, and that of the participating volunteers, photographs (and occasionally film) will be taken at volunteer events. These photos and film will be used on our website, social media accounts and in marketing collateral. A selection of photographs taken at volunteer events will be shared with the charity partner, including all of those which include service users / clients. We will always follow the photography policy of a charity partner. We may keep photographs and film taken at volunteer events indefinitely. This is to enable us to accurately document the development history of Marble Arch and recognise the people who played a part in its evolution. We would ask that charity partners delete any photographs or film we share with them after five years, although are aware that images may remain on social media pages, website and in printed literature.

Some volunteering activities may require personal data about your clients, service users or students to be shared with The Paddington Partnership and our volunteers. For example, if volunteers are delivering a mentoring programme or conducting mock interviews, they may be given copies of CVs. In these instances we request that CVs do not contain full names or personal contact information (address, email etc). The CVs will be destroyed by us at the end of the volunteering project.

Virtual volunteering

Marble Arch Partnership sometimes delivers virtual volunteering alongside its in-person activity. This volunteering is also covered by our privacy policy. To protect volunteers and charity partners and their service users, we:

  • Host telephone discussion groups using the teleconferencing package Flip Connect. This means volunteers and participants are dialled into the call and do not share contact details. All calls are hosted by a Marble Arch Partnership colleague for safeguarding and to ensure their smooth running.
  • Volunteers and service users participating in virtual events on Zoom or Microsoft Teams e.g. quizzes or book club, are contacted separately with log in details so that email addresses are not shared. All virtual events are hosted by a Marble Arch Partnership colleague for safeguarding and to ensure their smooth running.
  • All virtual talks involving young people (e.g. career talks and assemblies) are recorded by the participating school or college for safeguarding. These videos are stored by the school or college in line with their privacy policies. A member of school staff will always be present at virtual sessions for safeguarding and to oversee their smooth running.
  • Where mentoring programmes are delivered virtually, participating volunteers may be required to complete a DBS check in advance, if they are working one-to-one with students under the age of 16. Students will all participate in mentoring sessions in the same classroom via school computers / school devices and a teacher will be present throughout to monitor activity and for safeguarding. No personal contact details for students will be shared with volunteers.
  • With the consent of participating volunteers and service users, screen shots may be taken at volunteer events to provide a record of volunteering activity. These images will be shared with participants and, where appropriate, charity partners. They will be used on social media and the Marble Arch Partnership website to raise the profile of virtual volunteering. Like other photographs taken by Marble Arch BID these may be stored by us indefinitely, to enable us to continue to accurately record and report on the development of Marble Arch.

The lawful bases for collection and use of personal information

The lawful bases for processing your data are legal obligation (The Business Improvement Districts (England) Regulations 2004), consent, performance of contract and/or legitimate interest.

The Marble Arch Partnership will not communicate, spread, publish, sell, rent or otherwise give your personal information to anyone.

Accessing information stored about you

You may opt out of receiving newsletter communications from us at any time by following the unsubscribe link at the bottom of each newsletter or invitation or by emailing getinvolved@marble-arch.london.

Please contact us on the email address above or in writing to the address below to request to:

  • See what data we hold about you
  • Update or correct any data we hold about you
  • Request for the data we hold on you to be deleted
  • Express any concerns you have about our use of your data

The Marble Arch Partnership may require a copy of appropriate evidence such as a passport, driving licence, recent bank statement or utility bill prior to responding to a subject access request, in order to verify your identity. The Marble Arch Partnership will respond to all requests related to your personal information within one month of receipt.

The Marble Arch Partnership, 7 Praed Street, London, W2 1NJ.

Security of personal information

The Marble Arch Partnership has measures in place to protect personal information.

Only employees who need information to perform a specific job (e.g. distributing the newsletter or communicating with BID levy payers) have access to your personal information.

The computers and servers on which your personal information is stored are password protected with firewall controls and kept in a secure environment.

Any personal information stored on paper is locked away when not in use and disposed of after use securely using document shredders or confidential waste.

Any personal information you send to us in writing or by email may be insecure during transit and The Marble Arch Partnership cannot guarantee its delivery.

Updates to the Privacy Policy

Any updates made to The Marble Arch Partnership Privacy Policy will be shown on this page and communicated to you via the monthly newsletters.

Our contact details

The Marble Arch Partnership is registered in England under company number 8164848.

The registered office of this company is The Marble Arch Partnership, 7 Praed Street, London W2 1NJ.

If you have any concerns or questions about this Privacy Policy, please contact us by calling the main office on 020 3145 1210 or by emailing getinvolved@marble-arch.london.

 

Last updated 25 February 2022