Privacy Policy

Updated: 5th June 2025

 

1. Introduction

The Heritage Circle CIC is committed to protecting the privacy and personal data of everyone we engage with. This Privacy Policy explains how we collect, use, store, and share your personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

By interacting with us—whether online, in person, or via email or phone—you agree to the practices described in this policy.

 

2. Who we are

The Heritage Circle CIC is a Community Interest Company registered in Northern Ireland (Company Number NI725758), with a registered address at:

 

6 Indiana Avenue, Belfast, Northern Ireland, BT15 5BZ

We design and deliver projects that involve, inspire, educate, and train communities to celebrate, maintain, and protect heritage.

 

For the purposes of data protection law, The Heritage Circle CIC is the data controller.

 

3. How We Collect Personal Data

We collect personal data when you:

• Visit our website or social media pages

• Participate in our projects, training, or events

• Contact us by email, phone, or post

• Sign up for newsletters or updates

• Volunteer or apply for a role

• Donate or fundraise for us

• Complete surveys or provide feedback

We may also receive information from trusted partners or funders where appropriate, and we collect limited technical data (such as IP addresses or cookies) when you use our website.

 

4. What Personal Data We Collect

Depending on your relationship with us, we may collect:

• Name and contact details (address, phone, email)

• Date of birth (where appropriate)

• Communication preferences

• Payment or donation information (processed securely)

• Information about your participation in our events or projects

• Equal opportunities data (if you choose to provide it)

• Photos or video (with your consent)

• CCTV images if visiting premises with surveillance

Most information is provided directly by you. We only collect information that is necessary for our activities and retain it only as long as required.

 

5. Legal Bases for Processing

We process personal data under the following lawful bases:

• Consent – e.g., newsletter sign‑ups or use of photos.

• Contract – to deliver services, projects, or training.

• Legal Obligation – e.g., financial or audit requirements.

• Legitimate Interests – where processing is necessary for our operations and has minimal impact on your privacy (e.g., project monitoring, evaluation, or communication with participants).

• Vital Interests – in rare cases, to protect someone’s life.

Where we process special category data (e.g., equal opportunities information), we rely on your explicit consent or substantial public interest where appropriate.

 

6. How We Use Your Personal Data

We may use your information to:

• Communicate with you about our work, services, and events.

• Administer your participation in projects, volunteering, or training.

• Deliver services, manage bookings, and process payments.

• Conduct consultations, research, and evaluation.

• Gather feedback and measure the impact of our work.

• Promote our projects, training, and events (with your consent).

• Meet legal, financial, and audit requirements.

We do not use your data for automated decision‑making or profiling.

 

7. Children’s Data

We may collect limited personal data from children when they participate in our projects or events. Where this occurs, we:

• Obtain consent from a parent or guardian where required.

• Use the data only for the purpose of delivering the activity.

• Apply additional safeguards to protect children’s privacy.

We do not knowingly collect data from children under 13 without appropriate consent.

 

8. Sharing Your Information

We may share your information with:

• Trusted service providers acting on our behalf (e.g., email or payment processors).

• Partner organisations where necessary for project delivery.

• Statutory bodies, regulators, or law enforcement when legally required

We never sell or trade your personal data.

All third‑party processors are required to handle your data securely and in line with UK GDPR.

 

9. International Data Transfers

We do not typically transfer personal data outside the UK or EEA.
If this is ever necessary (e.g., where a service provider is based overseas), we ensure appropriate safeguards are in place, such as standard contractual clauses.

 

10. Data Security

We take appropriate technical and organisational measures to protect your personal data from loss, misuse, or unauthorised access.

Access to personal data is restricted to staff and trusted third parties who need it to fulfil partnership arrangements.

 

11. Data Retention

We keep personal data only as long as necessary for the purposes it was collected and in line with legal, financial, and operational requirements.

Typical retention periods include:

 

• Project participation data: up to 3 years after project completion.

• Financial records: 6 years (legal requirement).

• Volunteer or staff records: up to 6 years after involvement ends.

• Mailing list data: until you withdraw consent.

 

When data is no longer required, it is securely deleted or anonymised.

 

12. Your Rights

You have rights over your personal data, including:

• Access to the information we hold about you.

• Correction of inaccurate data.

• Erasure (in certain circumstances).

• Restriction or objection to processing.

• Data portability.

• Withdrawal of consent (where applicable).

• The right to complain to the Information Commissioner’s Office (ICO).

 

To exercise any of your rights, please contact us using the details below.

 

13. Cookies and Online Tracking

Our website uses cookies to improve your experience and help us understand how our site is used.
Non‑essential cookies are only used with your consent.

For more information, please see our Cookie Policy (available on our website).

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14. Contact Us

If you have any questions about this policy or your personal data, please contact:

 

Nikki McVeigh Data Protection Officer

The Heritage Circle CIC
6 Indiana Avenue
Belfast
Northern Ireland
BT15 5BZ

Email: info@heritagecircle.org.uk

 

15. Updates to This Policy

We may revise this policy from time to time. Updates will be posted on our website, and significant changes will be communicated directly where possible.

 

Last updated: 5th June 2025