Privacy Policy

The Devonshire Group Privacy Policy

Contents of privacy policy

Introduction
About the Devonshire Group
Explaining the legal bases we rely on
When do we collect your personal data?
What sort of personal data do we collect?
How and why do we use your personal data?
Combining your data for personalised direct marketing
How we protect your personal data
How long will we keep your personal data?
Who do we share your personal data with?
Where your personal data may be processed
What are your rights over your personal data?
How can you stop the use of your personal data for direct marketing?
Contacting the regulator
If you live outside the UK
Any questions?

Introduction

This privacy notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there is a lot of information here, but we want you to be fully informed about your rights, and how the Devonshire Group uses your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this privacy policy from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

About the Devonshire Group

The Devonshire Group is made up of a number of related businesses:

The Chatsworth Settlement – the entity that owns and runs our estates in Derbyshire, Yorkshire and Eastbourne.
Chatsworth House Trust (CHT) – the charity responsible for the house, garden and farmyard
Chatsworth House Enterprises Ltd (CHEL) – the organisation that runs events including the horse trials and country fair
Chatsworth Estate Trading Ltd (CETL) – the organisation that manages the shops and restaurants on the Chatsworth Estate
Devonshire Hotels and Restaurants Group Limited and the Peacock Hotel (Baslow) Limited – the organisations that run our hotels and holiday cottages business.
The Lismore Estate and Lismore Castle & Gardens – our estate and hospitality business in Ireland
The Devonshire Educational Trust (DET)
The Duke of Devonshire’s Charitable Trust (DDCT)
The Devonshire Maintenance Fund.

For simplicity throughout this notice, ‘we’ and ‘us’ refers to the organisations listed above.

Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent. Eg. When you tick a box to receive email newsletters

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations. Eg. If you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and we may pass them to our courier.

Legal compliance

If the law requires us to, we may need to collect and process your data. Eg. We can pass on details of people involved in fraud or other criminal activity affecting the Devonshire Group to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. Eg. We may use your purchase history or specified interests to send you or make available personalised offers, or may also use your email address to send you direct marketing information, telling you about products and services that we think might interest you

When do we collect your personal data?

When you create an account with us
When you visit our websites, and use your account to buy tickets, redeem vouchers, or book rooms, cottages or tables in our restaurants
When you purchase a product or service, in person or by phone, but don’t have (or don’t use) an account
When you supply us with a product or service
When you purchase membership from us – including, but not limited to, Bolton Abbey Season Tickets, Friends of Chatsworth membership, Chatsworth Health & Fitness Club membership, Chatsworth Fishery membership and Bolton Abbey Season Rods
When you enter into a tenancy on one of our estates
When you buy livestock from, or sell livestock to, one of our farms
When you engage with us on social media
When you contact us by any means with queries, complaints etc.
When you enter prize draws or competitions
When you choose to complete any surveys we send you
When you comment on or review us
When you’ve given a third party permission to share with us the information they hold about you
We may collect data from publicly available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law
When you visit our establishments or use our car parks, which usually have CCTV systems operated for the security of both visitors and employees. These systems may record your image during your visit
When you sign up to use our public wifi
When you ask us to send you e-newsletters

What sort of personal data do we collect?

If you have a web account with us; your name, billing/delivery address, orders, email and telephone number. For your security, we may also keep an encrypted record of your login password.
Details of your interactions with us online, on the phone or on the estate. Eg. We may collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items, web pages you visit and how and when you contact us
Details of your interests and visiting habits. Eg. Which tickets you purchase, and when you visit us and/or details of your activities when you stay with us
Details of your visits to our website and which site you came from to ours
Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies (see below for more information about our cookie policy)
Personal details that help us to recommend items of interest. Eg. If you live close to Chatsworth, we may send you details about Friends memberships. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your experience with us. Of course, it’s always your choice whether you share such details with us
Payment information
Your comments and product reviews
Your image may be recorded on CCTV when you visit our establishments or use our car parks
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Learn more about how we use cookies and similar technologies (see below for more information about our cookie policy)
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback
We use a third party provider to share our email newsletters. We collect statistics, including email opens and clicks, using industry standard technologies, such as clear gifs (also known as pixels), to help us improve our newsletter content, making it more interesting and relevant.

How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We may then use this to offer you promotions and products that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Here’s how we may use your personal data and why:

To process any orders that you make by using our website, on the phone or on site. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. Eg. Your details may need to be passed to a third party to supply or deliver the product that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities. This may include using your personal data to maintain, update and safeguard your account. We may also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. Learn more about how we use cookies and similar technologies (see below for more information about our cookie policy)
To protect our visitors, premises, assets and employees from crime, we operate CCTV systems across the Devonshire Group, which record images for security. We do this because of our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this because of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
With your consent, we may use your personal data, preferences and details of your transactions to keep you informed by email, web, text and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time by contacting us.
We may use the information collected from you to communicate about and administer participation in surveys and market research.
To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time by contacting us.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Policy, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our websites, we may use data we hold about where you live, your interests and so on. We do so on the basis of your consent for our website to place cookies or similar technology on your device. Eg. We might show you an advert for an event or ticket you have previously shown an interest in. Learn more about how we use cookies and similar technologies (see below for more information about our cookie policy)
To administer any of our prize draws or competitions that you enter, based on your consent given at the time of entering.
To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. Eg. We may record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having. Learn more about how we use cookies and similar technologies (see below for more information about our cookie policy)
To comply with our contractual or legal obligations to share data with law enforcement Government health departments.
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time by contacting us.
To build a rich picture of who you are and what you like, and to inform our business decisions, we may combine data captured from across the Devonshire Group, third parties and data from publicly available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest. Eg. by combining this data, this will help us personalise your experience and decide which content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide our advertising plans
To process your order (for example if you order a hamper for home delivery). Sometimes, we may need to share your details with a third party who is providing a service (such as delivery couriers). Without sharing your personal data, we’d be unable to fulfil your request.

Combining your data for personalised direct marketing

We want to bring you information, offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we may combine your personal data gathered across the Devonshire Group as described above. For this purpose we may also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry mentioned above.

How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all areas of our website using ‘https’ technology.

Access to your personal data is password-protected.

We regularly monitor our system for possible vulnerabilities and attacks.

How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

An example of a customer data retention period is when you make a purchase from us. When you make a purchase, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.

Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. Eg. Delivery couriers, the organisations set out in section 2 ‘About the Devonshire Group’.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

Ticket fulfilment/processing companies, such as See Tickets
IT companies who support our website and other business systems
Operational companies such as delivery couriers
Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. Learn more about how we use cookies and similar technologies (see below for more information about our cookie policy)

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

For jewellery orders created on our online shop, shop.chatsworth.org, we share your order details with the jewellery manufacturer, C W Sellors, in order to fulfil your order. Billing information is never shared.
For fraud management, we may share information about fraudulent or potentially fraudulent activity on our premises or systems. This may include sharing data about individuals with law enforcement bodies.
For health emergencies we may provide details to Government health departments, both Nationally and locally.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government bodies, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis, and take the privacy of our customers into consideration.

Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. Eg. Some third parties we use to store your data, such as those we use to send e-newsletters, may be based outside the EEA.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, we only work with organisations who have robust and trusted data protection policies, that meet the standards required within the EEA. If you wish for more information about these companies, please contact us.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Policy.

What are your rights over your personal data?

An overview of your different rights

You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete. Eg. when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a Friends membership).
That we stop using your personal data for direct marketing (through either specific, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.

You have the right to request a copy of any information about you that the Devonshire Group holds at any time, and to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection, The Information Technology Department, The Devonshire Group, The Estate Office, Bakewell, Derbyshire, DE45 1PJ, or email dataprotection@devonshiregroup.co.uk. To ask for your information to be amended, please update your online account, or contact our Customer Services team.

If we choose not to action your request, we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data because of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular organisation. Please note that if you are subscribed to communications from more than one of the organisations listed in section 2 ‘About the Devonshire Group’, we will only stop communications from the specific organisation that you unsubscribe from.
Email dataprotection@devonshiregroup.co.uk
Write to Data Protection, The Information Technology Department, The Devonshire Group, The Estate Office, Bakewell, Derbyshire, DE45 1PJ

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

Contacting the regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

If you live outside the UK

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your personal data between countries to enable us to supply the services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK, or elsewhere.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK, or elsewhere.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this privacy policy. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

Any questions

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact us:

Email us at dataprotection@devonshiregroup.co.uk
Or write to us at Data Protection, The Information Technology Department, The Devonshire Group, The Estate Office, Bakewell, Derbyshire, DE45 1PJ, The Estate Office, Bakewell, Derbyshire, DE45 1PJ

This notice was last updated on 29.06.2020.

Devonshire Group Privacy Notice – Recruitment

Data controller: The Devonshire Group (referred to as ‘we’ below)

The Estate Office
Bakewell
Derbyshire
DE45 1PJ

As part of any recruitment process, we collect and process personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

What information do we collect?

We collect a range of information about you. This includes:

– Your name, address and contact details, including email address and telephone number

– Details of your qualifications, skills, experience and employment history

– Information about your current level of remuneration, including benefit entitlements

– Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process

– Information about your entitlement to work in the UK

– Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief (this information is held and processed anonymously).

We collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, or collected through online applications, interviews or other forms of assessment.

We will also collect personal data about you from third parties. This could be from recruitment agencies to which you have submitted an application and given permission to pass on to us. Or it could be references supplied by former employers and information from criminal records checks – we will seek this information only once a job offer to you has been made and will inform you that we are doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why do we process personal data?

We need to process data to fulfil the requirements of the recruitment process. We also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of employees or workers and have concluded that they are not.

We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.

We will not use your data for any purpose other than the recruitment exercise for which you have applied.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you and the Disclosure and Barring Service to obtain necessary criminal records checks, if that is a requirement of the role.

We will not transfer your data outside the European Economic Area

How do we protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Details of these policies and controls are outlined in the employee handbook or are available from the HR department at the address above or HR@chatsworth.org.

For how long do we keep data?

If your application for employment is unsuccessful, we will hold your data on file for no longer than twelve months after the end of the relevant recruitment process. At the end of that period your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held are available in our data retention policy.

Your rights

As a data subject, you have a number of rights. You can:

– Access and obtain a copy of your data on request

– Require us to change incorrect or incomplete data

– Require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing

– Object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing

– Ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact the HR department at the address above or HR@chatsworth.org. You can make a subject access request by completing the relevant form (available from HR department).

If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

Updated May 2018.

Cookies

The Devonshire Hotels website may use cookies to store information on your local computer. Cookies can monitor how and when a site is used and help to provide you with information tailored to your individual needs. These cookies do not contain any personal data and will not identify you personally.

Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, track information about the visit, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

Users must opt in to allow cookies to be set in order to comply with the EU cookie law. If they choose not to do so, note that some parts of the website may not function properly.

You can find more information about cookies at www.allaboutcookies.org.

Persistent cookies

These cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session Cookies

These cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

Strictly necessary cookies

These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. By using the website, you agree that we can place these types of cookies on your device.

These cookies are essential for the website to function. They are used for features such as e-commerce baskets, site log-in and user tracking to ensure users can navigate the site effectively. These cookies are not available to third-party sites and are not used to track behaviour to place personalised adverts or any other content.

PHPSESSID*	General purpose session cookies, essential for the site to function.
TAOS_TRACK_SESSION*	Required for login and other features to work.
TAOS_PAGE_NO*	Remembers how many pages have been viewed.
TAOS_LAST_NODE*	Remembers the last page viewed.

Functionality cookies

These cookies remember choices you make to improve your experience.

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.

These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.