3SG Privacy and Cookie Policy
Author: Becky Brooks
Approved by: Board of Trustees
Last Updated: July 2025
Next Review Due: July 2026
1. Purpose of this Policy
This Privacy and Cookie Policy explains how 3SG (Bath and North East Somerset Third Sector Group CIO) collects, uses, stores, and shares personal data. It also outlines your rights and how to exercise them.
We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).
2. Who We Are
3SG is a registered charity (No. 1181029) supporting the Third Sector in Bath and North East
Somerset. Our registered office is:
The Archway Office, 4-5 Chapel Court, Bath BA1 1SQ
You can contact us at: contact@3sg.org.uk
3. Scope
This policy applies to:
- Visitors to our website (www.3sg.org.uk)
- Individuals and organisations who use our services
- People who attend our events or training
- Subscribers to our newsletters
- Partners and collaborators
4. What Personal Data We Collect
We may collect the following types of personal data:
| Type | Examples |
|---|---|
| Contact details | Name, email, phone number, postal address |
| Organisational info | Organisation name, role, sector |
| Communications | Emails, feedback, event registrations |
| Media | Photos or videos taken at events (with notice) |
| Technical data | IP address, browser type, device info (via cookies) |
| Special category data | Health, ethnicity, religious beliefs, political opinions, or other sensitive data (only with explicit consent) |
We do not knowingly collect data from children under 16.
- Directly from you (e.g. forms, emails, event sign-ups)
- Automatically via cookies and analytics tools
- From third parties (e.g. partners, funders, social media)
6. Lawful Basis for Processing
We only process your data when we have a lawful basis to do so. These include:
| Lawful Basis | When We Use It |
|---|---|
| Consent | For newsletters, photos, special category data |
| Contract | When providing services or event bookings, including Wellbeing Courses commissioned by Bath & North East Somerset Council |
| Legal obligation | For safeguarding or regulatory compliance |
| Legitimate interests | To improve services, monitor impact, or communicate with members (where your rights are not overridden) |
You can withdraw consent at any time.
7. How We Use Your Data
We use your data to:
- Provide services, support, and information
- Manage events and training
- Send newsletters and updates (with consent)
- Monitor and evaluate our impact
- Improve our website and services
- Comply with legal obligations
8. Data Sharing
We may share your personal data with:
- Community Wellbeing Hub partners – 3SG is a member of the Community Wellbeing Hub and has a formal Data Sharing Agreement in place with other members, including Bath & North East Somerset Council, HCRG Care Group and Everyone Health. Data is only shared where necessary to deliver joined-up support and in line with agreed protocols.
- Commissioning bodies – Where we deliver services under contract (e.g. Wellbeing Courses commissioned by Bath & North East Somerset Council), we may share relevant data with the commissioning body for monitoring, evaluation, or safeguarding purposes. This data can be anonymised if requested.
- Service providers – such as Google (for email and cloud storage), who are only permitted to process data on our instructions and under strict confidentiality agreements.
- Legal or safeguarding obligations – where required by law or to protect someone’s vital interests.
- With your consent – to connect you with other organisations or services.
We never sell your data.
9. International Data Transfers
If any personal data is stored or processed outside the UK (e.g. via cloud services like Google Workspace), we ensure appropriate safeguards are in place. These may include:
- UK adequacy regulations
- Standard Contractual Clauses (SCCs)
- Binding corporate rules or equivalent protections
10. Cookies and Tracking
We use cookies to:
- Make our website work properly
- Understand how visitors use our site (via Google Analytics)
- Improve your experience
We use a cookie consent banner to allow you to accept or reject non-essential cookies in line with PECR and ICO guidance.
You can also manage your cookie preferences via your browser. For more info, visit http://www.allaboutcookies.org.
11. Automated Decision-Making
We do not currently use automated decision-making or profiling that has legal or similarly significant effects. If this changes, we will update this policy and explain:
- The logic involved
- The significance and consequences for you
- Your right to request human intervention
12. Data Security
We take appropriate technical and organisational measures to protect your data, including:
- Secure cloud storage (Google Workspace)
- Access controls for staff and contractors
- Regular data protection training
13. Data Retention
We keep your data for no longer than necessary. Typically:
- General contact data: 36 months after last interaction
- Event records: 3 years
- Contractual data: up to 7 years (for audit purposes)
We may retain anonymised data for research and reporting.
14. Children’s Data
Our services are not intended for individuals under 16. If we become aware that we have collected personal data from a child under 16 without parental consent, we will delete it as soon as reasonably practicable.
15. Your Rights
You have the right to:
- Access your data
- Correct inaccurate data
- Erase your data (“right to be forgotten”)
- Object to processing
- Restrict processing
- Data portability (move your data)
- Withdraw consent at any time
To exercise your rights, contact us at: contact@3sg.org.uk
We may need to verify your identity and will respond within 30 days.
16. Complaints
If you’re unhappy with how we handle your data, please contact us first. If we can’t resolve your concern, you can contact the Information Commissioner’s Office (ICO): https://www.ico.org.uk
17. Changes to This Policy
We may update this policy from time to time. The latest version will always be available on our website.