Privacy Notice

Policy Summary

This is The Southern Co-operative Limited’s (“Southern Co-op”) privacy notice. We respect your privacy and are committed to protecting your personal data in accordance with data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This privacy notice tells
you how we look after your personal data when you visit our website (regardless of where you visit it from), about your privacy rights generally in relation to the information we hold about you as a member, customer or otherwise and how the law protects you.

Please refer to the Glossary at paragraph 10 to understand the meaning of some of the terms used in this privacy notice.

Policy Detail

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Southern Co-op collects and processes your personal data through your use of this website, your membership of Southern Co-op, when you purchase a product or service, when entering into a contract with Southern Co-op, taking part in a competition or otherwise where we hold data relating to you.

Although we do accept children from the age of 14 as members, we do not use their data other than in relation to their status as members. We have a policy of not sending any marketing information to under 18s, even if they have ticked to receive such information. Under 16s are not permitted to vote or attend member meetings, so they will not receive communications about these matters. Under 18s will receive other communications about governance matters. Our website is not intended for children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

The Southern Co-operative Limited is the data controller in most cases, for example, in respect of data collected through your use of this website, data collected in relation to your status as a member which includes information we obtain through use of your membership card in store or in funeral homes, data is also collected through our relationship with suppliers, contractors, landlords, tenants or where you apply for funding through our community support programmes. Southern Co-op is also responsible for this website.

Southern Co-op owns a number of different legal entities that may also process personal data and with whom we may share personal data:

• Southern Co-operative Funerals Limited, Mutual Services (Portsmouth) Limited, South of England Funeral Partners Limited, East Devon Crematorium Limited, Sussex Woodlands Limited and Natural Burial Grounds Limited – these companies offer End of Life services including funeral services, pre-need funeral plans, burials, crematoria and masonry. Personal data will be collected from clients and users of our services via third party funeral directors.
• Co-operative Independent Living Limited – this company owns the Co-op Mobility brand, the business of which was operated under contract by a third party, Complete Care Network Limited. Personal data was collected via Complete Care Network Limited in relation to customers to monitor brand standards, provide customer support and services and deal with dispute resolution until the business closed in 2019.
• Co-operative Franchising Limited – this company manages the franchise relationship for businesses operated in partnership with Southern Co-op under both “The Co-operative Food‟” and ”Welcome” brands. Personal data will be collected in relation to franchisees and their employees, where services are provided on their behalf.
• Mutual Associates Limited, Southern Co-operative Retailers Limited and Southern Co-operative Properties Limited – these companies are property holding companies. Personal data will be collected in relation to landlords and tenants.
• Cobra Coffee Limited and Cobra Coffee South West Limited – these companies operate our Starbucks franchise business as licensees of the Starbucks brand. Personal data will be collected in relation to employees and customers.

This privacy notice is issued on behalf of the whole group of Southern Co-op owned entities so when we mention Southern Co-op, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Southern Co-op Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us, or through the relationship we hold with you.

Data collected as a result of our relationship as an employer is detailed in our Colleague Privacy Notice. This is available internally.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, our use of your data or anything relating to the data we hold about you, please contact the DPO using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: The Southern Co-operative Limited (Registered number: 1591R)
DPO: [email protected]
Postal address: 1000 Lakeside, Western Road, Portsmouth, P06 3FE

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 30 November 2023. Historic versions may be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of other websites.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified, or is identifiable. It does not include data where the identity has been removed (anonymised data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data a includes first name, last name, username or similar identifier, title, date of birth and gender and your image.
• Contact Data includes postal address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us whether through the use of your membership card or otherwise.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 website Usage Data to calculate the percentage of users accessing a specific website feature or anonymised customer data may be shared with a partner to validate market profiles designed to identify potential new store locations. 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.

We also collect Special Categories of Personal Data (which includes information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life and sexual orientation) and Criminal Convictions Data (personal data relating to criminal convictions and offences, including personal data relating to criminal allegations and proceedings) but only in limited and targeted circumstances. Our Appropriate Policy Document sets out why we process this data and how we protect it. A copy can be provided upon request by contacting [email protected].

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 membership, goods or services). In this case, we may not be able to provide you with a membership account or may have to cancel a product or service, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Usage and Financial Data by visiting our stores and funeral homes, filling in forms or by corresponding with us by post, phone, email or otherwise, or through meetings with our employees. This includes personal data you provide when you:
  • purchase our products or services which could include food and retail products and services, funeral products or services, bereavement and counselling services, community engagement services through our Love Your Neighbourhood programme, become a supplier or contractor, or become a tenant in one of our residential or commercial properties;
  • become a member, vote, ask a candidate or a director a question, stand as a candidate in our directors’ elections or attend a members’ meeting or other member event such as a member’s trip or listening group;
  • contact our Member Support and Customer Services team;
  • request marketing to be sent to you or when you join our All Yours marketing programme;
  • enter a competition, prize draw, promotion or survey;
  • ask a question or give us some feedback; or
  • enter our stores and have your image captured on CCTV or other image capture technology, where applicable. Please see our CCTV and Image Technology Use Policy for more details.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as independent funeral directors who are arranging for us to provide services to you on their behalf, or from review sites such as Google, Facebook, Trustpilot etc. when you carry out a review of our business or services or when you request another service provided by an External Third Party on our behalf or receive a service from an External Third Party providing it on our behalf. Examples are set out in the Glossary at the end of this privacy notice. Such services may also be subject to that External Third Party provider’s own privacy policy.

4. HOW WE USE 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 such as when you join as a member or purchase products or services.
• 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 such as where we analyse data in order to improve our products and services.
• Where we need to comply with a legal or regulatory obligation for example in relation to reducing or tackling criminal activity.
• Where you have given us consent to do so.

If you are a member of Southern Co-op, we are required to communicate with you in relation to governance matters as you are a part owner of our Society. This includes information about members meetings (such as our AGM), directors’ elections and Share of the Profits. This means we will process your personal data in order to send you these communications.

We will only send you marketing information in accordance with your preferences. To change these please visit our website membership page or contact Member Support on [email protected] or on 0800 652 0124. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of the main ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

CCTV

We use CCTV and other image capture technology in our stores and funeral homes to protect our business, colleagues and customers. Our CCTV and Image Capture Technology Use Policy CCTV and Image Capture Technology Use Policy covers the use of these technologies.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage, Marketing and Communications and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is known as profiling and is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us only if you have requested this sort of information from us.

We will only tell you about the products and services offered by entities outside the Southern Co-op group of companies, such as our charity partners or other trusted third parties, if you have asked us to do so by consenting to this form of marketing communication when telling us about your preferences. We will not pass your personal data to these third parties.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt- out or unsubscribe links on any marketing message sent to you or by contacting Member Support at [email protected] or on 0800 652 0124 at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of becoming a member or a product/service purchase and we will continue to be permitted to contact you in relation to these matters provided we have a lawful basis to do so.

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 our website may become inaccessible or not function properly. Please see our Cookie Policy for further details.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact [email protected]

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with third parties for the purposes set out in the table in paragraph 4 above. These may be Internal or External Third Parties as defined in the Glossary. For example, we may use mailing houses to process and distribute the Share of the Profits to our members, use specialist election services providers to administer our directors’ elections or engage a marketing agency to run a specific promotion or a competition on our behalf. We may pass your details to funeral service professionals such as ministers so that the funeral you require can be provided or to facilities management companies in relation to providing services to you as a tenant.

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.

In certain circumstances, third parties may collect personal data from you as a result of your relationship with us or because of the way you interact with us. For example, you may comment via social media on an aspect of our service or leave us some feedback in which case you will be subject to that third party’s privacy policy. Alternatively, we may offer member benefits through a third party with whom you establish a direct relationship with that provider or other entities you connect to via that provider.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA), however, systems held to hold personal data may be accessed by system providers, or be hosted, outside of the European Economic Area. Where this is the case we require our system providers and host to secure your personal data in a manner consistent with the requirements of UK law.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or other reporting requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policies which where applicable youcan request from us by contacting our Data Protection Officer on [email protected].

In some circumstances you can ask us to delete your data. See request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact: [email protected]

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you including ID to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting [email protected]

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means processing your personal data where we have your specific consent to do so. You have a legal right to remove or amend this consent by contacting [email protected].

INTERNAL THIRD PARTIES

Other companies in the Southern Co-op group acting as controllers or processors and who are based in the UK and who provide products and services:

EXTERNAL THIRD PARTIES

These are third parties outside the Southern Co-op group which provide services where we do not have the expertise or resources to provide them in house or to whom we are required to pass on your data in order to fulfil the relationship we have with you or for other legal reasons. Examples of these entities are:

• Service providers acting as processors who provide IT and system administration services, CCTV services, image capture technology providers, digital, videoing, broadcast, streaming and photographic service providers and email deployment providers.
• Professional advisers acting as processors or joint controllers including lawyers, accountants, bankers, auditors and insurers who provide legal, accounting, banking, auditing, insurance and consultancy services.
• HM Revenue & Customs, Financial Conduct Authority, National Association of Funeral Directors, Association of Natural Burial Grounds and other regulators or authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances or otherwise where we are required to share information with such entities.
• Police and other enforcement agencies where we are required to do so or in response to a legal requirement or obligation or where we are permitted to share information.
• Service providers such as market researchers, advertising agencies, marketing agencies, specialist member services and benefits providers, estate agencies, property services agencies, local authorities, utility providers, property facilities management companies and other contractors, debt collection services providers, mailing house fulfilment, funeral service providers (embalmers, cemeteries, gravediggers, monumental masons, ministers etc.), election services providers, companies who administer competitions on our behalf, online and physical meeting and conferencing service providers, security and loss prevention consultants and business crime reduction organisations etc.
• Individuals (or their representatives) who are exercising their rights in respect of data relating to them which includes data relating to others. We will only share the information relating to others if we are required to do so and where it does not override the rights of the other individuals who are included in that data.