Privacy

In general, you may visit this Site without telling us who you are or revealing any personally identifiable information about yourself. Our servers collect the domain names, operating system in use (e.g., Macintosh, Windows) and browser (e.g. Safari, Internet Explorer). This information is aggregated to measure the number of visits, average time spent on the Site, pages viewed etc. We use this information to measure the use of our Site and to improve its content.

This is the privacy policy of States of Guernsey site www.digitalgreenhouse.gg, which shall include, without limitation, the home page, splash page, and all other pages under the same top level domain name, and all content thereon (the "Site") as provided by States of Guernsey, ("Guernsey" or "we").

Fair Processing Notice

The Digital Greenhouse (‘the Controller’) operates under the Economic Development Committee and is responsible for providing a coworking space, events and meeting room hire, as well as business support services. Data processing activity is therefore in relation to provision of these services. 

The address of the Cadastre office is Digital Greenhouse, Rectory House, 2 Market Street, St Peter Port, Guernsey, GY1 1HB 

1. The Data Protection Law 

The Controller acknowledges its obligations as per the Data Protection (Bailiwick of Guernsey) Law, 2017 (‘the Law’), which provides a number of requirements in terms of processing activities involving personal data. The controller further acknowledges the general principles of processing as well as the rights of a data subject. For further information regarding these principles and how you can exercise your rights as a data subject, please visit www.gov.gg/dp.  

1. The Principles of Processing 

1. Lawfulness, fairness and transparency 

Personal data must be processed lawfully, fairly and in a transparent manner.  

The processing activities undertaken within the Digital Greenhouse are for the purpose of providing membership services, access to the premises, bookings and events, and accessing support services. Digital Greenhouse has only one sharing agreement in place with the States of Guernsey to allow for the invoicing and billing of Memberships and Room hire. 

Data is collected from the data subject or their representative. Digital Greenhouse may collect, use, store and transfer different kinds of personal data as detailed below:   

 

Processing Activity (Purpose)	Personal Data Processed	Lawful Basis for Processing
To facilitate Digital Greenhouse Membership (provision of services and payment collection)	Basic personal data: Full name, date of birth, address, telephone number, email address, financial data for payment processing	Contract - We process your personal data to meet our contractual obligations to you; to collect payments and so we can provide the services you’ve requested
Delivery of newsletters/marketing (Mailchimp)	Basic personal data: First name, surname, email address	Consent - We send you marketing communications only if you’ve provided consent to receive them. You can withdraw your consent at any time by clicking the unsubscribe link within all communications or by emailing info@digitalgreenhouse.gg.
Event Hosting	Basic personal data: First name, surname, email address, payment details    Special category data: Allergy information may be collected where specific catered events are planned	Basic personal data: Legitimate Interests - We request this information in order to manage attendance, confirm registrations, send joining instructions or updates.    Special category data: Explicit Consent – You may choose to provide us with dietary requirements or allergy information where specific catered events are organised.
Room Bookings	Basic personal data: First name, last name, address, email address, telephone number	Contract - We process your personal data to meet our contractual obligations to you; to collect payments and so we can provide the services you’ve requested
WhatsApp Group - Service specific and member community communications	Basic personal data: Display name, telephone number, profile picture	Consent – You may choose to join the Digital Greenhouse WhatsApp group. You can withdraw your consent at any time by exiting the group, or by emailing info@digitalgreenhouse.gg     Legitimate Interests – Message history will be retained for 90 days before automatic deletion
Support services and Programmes	Basic personal data: First name, last name, address, email address, telephone number    Special category data: You may choose to provide details of learning difficulties/additional needs in order for programme material and delivery to be tailored to your needs	Basic personal data: Legitimate Interests - We request this information in order to manage attendance, programme schedules, appointments, and to send joining instructions or updates.    Special category data: Explicit Consent – You may choose to provide us with details of any learning difficulties or additional needs which enables us to adjust programme material and delivery to suit your needs.
CCTV - For safety and security of the premises, staff, and visitors)	Basic personal data: Images captured through CCTV cameras running 24/7	Legitimate Interests – CCTV is utilised for the security of the premises and personal belongings, and safety of staff/visitors at the Digital Greenhouse.

 

Data Sharing 

In some circumstances, personal data held by the  Controller  may be transferred to another  Controller within the States of Guernsey or associated third party (i.e financial data for payment collections). Sharing may also occur between the Controller and other entities (such as law enforcement) when required by law. The Controller will share only the minimum amount of data necessary and when there is a lawful basis to do so.  

When you choose to subscribe to our newsletter/marketing mailing list, your name, email address and communication preferences are shared with Mailchimp who we utilise as a processor for this service. The privacy notice for Mailchimp can be found at www.intuit.com/privacy/statement. You may unsubscribe from this service at any time by clicking the unsubscribe link found within all email communications, or by emailing info@digitalgreenhouse.gg. 

1. Purpose limitation 

Personal data must not be collected except for a specific, explicit and legitimate purpose and, once collected, must not be further processed in a manner incompatible with the purpose for which it was collected.  

The controller acknowledges its responsibility with regards to this data protection principle and therefore the controller maintains that it will not further process that personal data in a way which is incompatible to its original reason for processing as specified in section 2a, unless the controller is required to do so by law.   

1. Minimisation 

Personal data processed must be adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed.  

The controller maintains that it will only process the personal data which is detailed in section 2a, and will not process any further personal data that is not necessary in relation to the original reason for processing personal data as specified in section 2a, unless the controller is required to do so by law.

1. Accuracy 

Personal data processed must be accurate, kept up-to-date (where applicable) and reasonable steps must be taken to ensure that personal data that is inaccurate is erased or corrected without delay.  

The controller will ensure that all personal data that it holds is accurate and kept up-to-date, and any personal data that is inaccurate will be erased or corrected without delay.  

1. Storage limitation 

Personal data must not be kept in a form that permits identification of a data subject for any longer than is necessary for the purpose for which it is processed. 

The Digital Greenhouse will retain personal data as follows:  

• Data regarding memberships will be kept for as long as the membership is active and a further 12 months after membership is cancelled. 

• Room booking data is retained for 1 year from the day of booking. 

• Programme and will be retained for a period of 6 years following conclusion of the programme. 
• Events data will be retained for 2 years following the conclusion of any events.

• Financial data will be retained only for as long as necessary to complete an individual’s payment liabilities, as well as any period required under law. 

• If you have consented to the receiving of marketing communications, data will be retained for as long as you are subscribed to these channels. 

• If you have chosen to join the WhatsApp group, the message history is kept for a period of 90 days, after which it is automatically deleted. Should you choose to leave the WhatsApp group, your contact details are removed immediately. 

• CCTV footage is overwritten every 30 days, unless a specific incident requires additional retention, in which case that specific footage will be isolated and securely retained for as long as necessary for any investigation. 

1. Integrity and confidentiality

Personal data must be processed in a manner that ensures its appropriate security, including protecting it against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.  

Information Access - access to electronic records is tightly controlled. Employees are vetted in a manner commensurate with the role that they are expected to undertake. Protocols are followed to ensure that employees only have access to areas and documents as required to undertake their role. Access is monitored and effectively managed.  

Information Security - Digital Greenhouse adopt the information security standards of the States of Guernsey.

1. Accountability 

The controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.  

1. Contact Details 

The contact details for the controller are as follows:  

Digital Greenhouse, Rectory House, 2 Market Street, St Peter Port, Guernsey, GY1 1HB 

Tel: +441481 701010 

Email: info@digitalgreenhouse.gg 

The contact details for the Data Protection Officer are as follows: 

Data Protection Officer, the Committee for  Economic Development 

Tel: 01481 220012 

Email: data.protection@gov.gg