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This privacy notice sets out details of the information we collect about you, how we may use it, how we ensure it’s kept secure, who we share it with, and what rights you may have in respect of that information.
This Notice applies to all the entities within the Co-operative Group Limited (“we”, “us” and “The Co-op”) to the extent that they are controllers of your personal information.
We’re committed to respecting the information you trust us with and making sure that we keep it safe. The Co-op has a family of businesses including Food, Insurance, Legal Services, Funeralcare and Health.
Our main use of your information is where it’s necessary to supply you with our products and services, or where it's necessary as part of the management of our Membership programme.
For example, we’d need your name, address and payment details when you join as a Member so we can:
These are things we consider to be our legitimate interests, some of which are more relevant to certain Co-op Group businesses than others.
We may also need to process your personal data from time to time where necessary for:
If we're using your personal information in the above ways, we really understand that your data has a value and therefore we try to use it for everyone’s benefit. We also try really hard to ensure there will be little or no negative impact on you. This is part of our commitment to ensure that we consider all privacy concerns at the earliest possible opportunity.
We will only use your personal information where:
For example we might rely on your consent in order to send you direct marketing communications. Where we do, you can withdraw your consent at any time.
These interests are set out above (see 'Where we need your personal information to help us get better at everything we do'), and we will only use such data where those interests are not outweighed by your own interests or fundamental rights and freedoms.
Either when we're in a contract with you or to take steps as requested by you prior to entering into a contract.
For example if we needed to share your information with a health professional because you’d fallen ill.
Please note that where we require you to provide certain information in order to perform our contractual obligations and you decline to do so, this may delay our performance of the contract or prevent us from honouring our contractual obligations.
Almost all of the information we have is the information you've given to us. That might be when you request a product, service, offers or news from us via our website, emails, telephone conversations, and written and verbal communication.
Obviously the types of information you give us will vary depending on the service you’ve requested but typically could include:
As well as obtaining information from you, we may also collect it from:
It's also possible we might process other types of information that might be considered even more private, such as information relating to criminal offences and alleged offences. For example, if you wanted a quote for a Motor Insurance product we might need to ask about any criminal offences or health conditions. These are considered "special categories" of personal information and we're obliged to handle this information even more thoughtfully.
See a full list of special category information on the ICO's website.
When we share your information, we only do so in accordance with our legal, data protection and privacy obligations.
Your information may be disclosed to the following:
We only keep your information for as long as it's needed for each of the activities we’ve identified in this Notice, as well as for as long as required in connection with our legal or regulatory obligations.
As you might expect, that will vary but we're happy to share more specific retention schedules if you wish to contact us on the contact details below.
We may need to transfer your personal information outside of the EEA in order to provide you with the services and products you require or as necessary for our business. This will most likely occur when our third-party providers are based outside the EEA. Some of these countries may not have laws that protect privacy rights as extensively as in the EEA.
If we do transfer your personal information to other jurisdictions, we will take proper steps to ensure that your information is as equally protected as in the UK, such as entering into "standard data protection clauses" with the recipient. These are clauses that have been approved by the European Commission for such transfers.
Data protection laws provide you with a number of rights as set out below.
You may request confirmation that we hold personal data about you, as well as access to a copy of any such data.
You may ask us to rectify any inaccurate information we hold about you.
You may ask us to delete your personal information.
You may ask us to restrict the processing of your personal information in certain circumstances.
You may request the receipt or transfer to another organisation in a structured, commonly used and machine-readable form, the personal data that you have provided to us.
You may object to our processing of your personal information in certain circumstances.
Where our processing of your personal information is based on your consent, you may withdraw this consent at any time, although this won’t affect the lawfulness of any prior processing where we relied on your consent.
You may make a complaint about our processing of your personal data by contacting us via the contact details provided in this Notice. While we hope that we would be able to address any issues you have in respect of this processing, you may also make a complaint to the UK’s data protection regulation - visit the Information Commissioner’s Office.
If you would like to exercise any of your rights, please contact us using the contact details set out below.
Sometimes we use your personal information in automated processes to make decisions about you, or to create a profile of you. If you are a Member, we may also generate a profile ‘score’ for you, which is designed to provide benefits such as discounts on Co-op products and services. Our use of automated decision making, for example in respect of our insurance products, is to help ensure that decisions are made accurately, fairly and efficiently.
To find out what personal information we hold about you, print a subject access request form, fill it in and send it by post to:
Data Protection Team,
1 Angel Square,
Manchester M60 0AG
For other enquiries or to get a subject access request form by post, write to us at the address above or call 0800 0686 727.
The information we hold about you will depend on how you shop and interact with us, so the more information you can give about what it is you want you see, the quicker and more specific our response can be.
You also have the right to request we correct any inaccurate information we hold, as well as the right to object to profiling and the right to ask us to delete your information.
If you have any questions, concerns or objections about how we use your personal information please contact us using the details above.
If you have any concerns or complaints about how we handle your information you can complain to the Information Commissioner's Office, although we'd really like the chance to try and help with any issues first.
If we make significant changes to the notice we’ll contact you directly to let you know.
We encourage you to check back regularly.