Privacy Policy for Harbourgate Community CIC Ltd

Effective date: 20 July 2026

1. Introduction and company information

This Privacy Policy explains how Harbourgate Community CIC Ltd collects, uses, stores, shares, and protects personal data when you interact with us, use our services, visit our premises, contact us, or otherwise engage with our community activities.

Harbourgate Community CIC Ltd is the data controller responsible for your personal data under this Privacy Policy.

Company details:
Harbourgate Community CIC Ltd
Harbourgate Community Hub, 18 Trinity Road, Swansea, SA1 2AL, United Kingdom
Email: [email protected]
Phone: +44 1792 846 275

As a community organisation, we may provide services, activities, support, events, volunteering opportunities, communications, and related community-based initiatives. This Privacy Policy applies to personal data relating to participants, visitors, volunteers, supporters, donors, service users, contractors, suppliers, and other individuals who interact with us.

2. Data collection and processing

We may collect and process the following categories of personal data, depending on your relationship with us and how you interact with us:

  • Identity information: name, title, date of birth, and similar identifiers.
  • Contact information: address, email address, telephone number, and emergency contact details where applicable.
  • Communication data: messages, enquiries, feedback, complaints, and correspondence.
  • Service and participation data: records relating to attendance, event registration, participation in community activities, membership or support arrangements, and volunteer involvement.
  • Financial data: payment records, donation details, invoicing data, and transaction information where relevant.
  • Technical data: IP address, device information, browser type, and usage data from our website or digital services.
  • Safeguarding and support information: information required to provide community support, including accessibility needs, welfare-related information, or incident records where necessary.
  • Special category data: where necessary and lawful, we may process information revealing health, ethnicity, disability, religion, or other sensitive information, for example to support inclusion, accessibility, safeguarding, or equality monitoring.

We collect data directly from you, from your authorised representatives, from third parties where permitted, and through our website, email, phone, forms, booking systems, and in-person interactions. We may also generate data internally through our operations, such as attendance logs and safeguarding records.

3. Purpose of data processing

We use personal data for the following purposes:

  • to provide, manage, and improve our community services, activities, and support;
  • to register and administer events, programmes, memberships, volunteering, and participation;
  • to communicate with you, respond to enquiries, and manage feedback or complaints;
  • to maintain records, manage operations, and administer our organisation;
  • to process donations, payments, reimbursements, and related financial matters;
  • to comply with legal, regulatory, safeguarding, accounting, and reporting obligations;
  • to ensure the safety and security of our staff, volunteers, visitors, and premises;
  • to deliver inclusive services and make reasonable adjustments where needed;
  • to send updates, newsletters, and information about our activities where permitted;
  • to monitor and improve our website, services, and communications; and
  • to establish, exercise, or defend legal claims where necessary.

4. Legal basis for processing

We will only process personal data where we have a lawful basis to do so. Depending on the activity, our legal bases may include:

  • Consent: where you have given clear consent for us to process your personal data for a specific purpose, such as receiving certain communications.
  • Contract: where processing is necessary to enter into or perform a contract with you.
  • Legal obligation: where processing is required for compliance with legal duties.
  • Vital interests: where processing is necessary to protect someone’s life or in an emergency situation.
  • Public task / substantial public interest: where applicable to our community work and lawful obligations.
  • Legitimate interests: where processing is necessary for our legitimate interests or those of a third party, provided your rights and interests do not override those interests.

For special category data, we will also rely on an additional condition permitted by applicable law, such as explicit consent, employment and social protection obligations, safeguarding, or substantial public interest grounds where relevant.

5. Data sharing and third parties

We may share personal data with trusted third parties only where necessary and appropriate for the purposes described in this policy. These may include:

  • IT and website hosting providers;
  • email, communications, and cloud storage providers;
  • payment processors and banking partners;
  • professional advisers, auditors, insurers, and legal counsel;
  • event, booking, and volunteer management platforms;
  • public authorities, regulators, law enforcement, or courts where required by law;
  • partners, funders, referral organisations, or service providers involved in delivering community support, where appropriate and lawful.

We require third parties who process personal data on our behalf to protect it and to use it only in accordance with our instructions and applicable law.

6. Data transfer to third countries

Some of our service providers may store or process personal data outside the United Kingdom or the European Economic Area. Where such transfers occur, we will take steps to ensure that appropriate safeguards are in place, such as:

  • adequacy regulations or decisions where available;
  • standard contractual clauses or equivalent transfer mechanisms;
  • additional technical and organisational measures where required.

If you would like more information about international transfers and the safeguards used, please contact us using the details below.

7. Storage duration

We retain personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, accounting, reporting, and safeguarding requirements.

  • contact and enquiry records are generally retained for as long as needed to manage the enquiry and any follow-up;
  • service, participation, and volunteer records are retained for the duration of the relationship and for a reasonable period afterwards;
  • financial and accounting records are retained in line with legal and tax obligations;
  • safeguarding, incident, or complaint records are retained for as long as necessary for protection, audit, or legal purposes;
  • marketing consent records are retained until you unsubscribe or withdraw consent, plus a reasonable record of your preference.

When personal data is no longer required, we will securely delete, anonymise, or archive it in accordance with our retention practices.

8. User rights

Subject to applicable law, you have the following rights in relation to your personal data:

  • Access: to request a copy of the personal data we hold about you.
  • Rectification: to request correction of inaccurate or incomplete data.
  • Erasure: to request deletion of your personal data in certain circumstances.
  • Restriction: to request that we limit the processing of your personal data in certain circumstances.
  • Data portability: to request that we provide certain data in a structured, commonly used, machine-readable format, where applicable.
  • Objection: to object to processing based on legitimate interests and to object to direct marketing at any time.

To exercise any of these rights, please contact us using the details in Section 12. We may need to verify your identity before responding. We will respond within the time period required by applicable law.

9. Withdrawal of consent

Where we rely on your consent to process personal data, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

You can withdraw consent by contacting us at [email protected] or by using any unsubscribe or preference-management option we provide. If you withdraw consent, we may still process your data where another lawful basis applies.

10. Right to complain

If you have concerns about how we handle your personal data, please contact us first so that we can try to resolve the issue.

You also have the right to lodge a complaint with the relevant data protection supervisory authority in the United Kingdom. If you are based in the UK, this is generally the Information Commissioner’s Office (ICO). We encourage you to contact us first, but you are entitled to contact the ICO at any time.

11. Data security

We take the security of personal data seriously and use appropriate technical and organisational measures to help protect it from unauthorised access, loss, misuse, alteration, or disclosure. These measures may include:

  • access controls and password protection;
  • role-based permissions and confidentiality obligations;
  • secure storage and backup procedures;
  • data minimisation and retention controls;
  • staff and volunteer awareness about privacy and confidentiality;
  • physical security measures at our premises where applicable.

While we take reasonable steps to protect personal data, no method of transmission or storage is completely secure. If we become aware of a personal data breach that affects your rights and freedoms, we will act in accordance with applicable legal requirements.

12. Contact information

If you have questions about this Privacy Policy, wish to exercise your rights, or need further information about how Harbourgate Community CIC Ltd handles personal data, please contact us:

Harbourgate Community CIC Ltd
Harbourgate Community Hub, 18 Trinity Road, Swansea, SA1 2AL, United Kingdom
Email: [email protected]
Phone: +44 1792 846 275

13. Changes to privacy policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any updated version will be posted on our website or otherwise made available to you, and the effective date will be amended accordingly.

We encourage you to review this Privacy Policy periodically to stay informed about how Harbourgate Community CIC Ltd protects your personal data.

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