The Ringing World Ltd privacy policy

Introduction

The Ringing World Ltd is both a Limited Company (number 1722963) and a Registered Charity (number 287182). Our charitable objective is to promote and foster the art and science of bellringing to bellringers and the general public, in particular by publishing educational material and historical archives, facilitating communication, encouraging public interest and uniting the ringing community.

We publish a weekly newspaper, ‘The Ringing World’. We organise the Ringing World National Youth Contest (RWNYC) annually. We host several discussion mailing lists for bellringers through the bellringers.org domain, several of which we also administer. We operate several websites:

• The Ringing World company website: https://www.ringingworld.co.uk
• BellBoard: https://bb.ringingworld.co.uk/
• A peals database: https://www.peals.co.uk/
• The Ringing World National Youth Contest: https://rwnyc.ringingworld.co.uk/
• Little Ringing Books: https://littleringingbooks.co.uk/

Our office address is 35A High Street, Andover, Hampshire, SP10 1LJ. Our telephone number is 01264 366620. For general enquiries our email address is admin@ringingworld.co.uk. For editorial and most management matters our email address is editor@ringingworld.co.uk. The Board of Directors and Trustees can be reached through the Company Secretary: companysecretary@ringingworld.co.uk.

What information we collect

The Ringing World holds and processes the following data:

• Editorial information including articles for publication and other editorial correspondence
• Performance information on peals, quarter peals and other performances, including the names of participants, footnotes and photographs
• Subscriber / purchaser details comprising name, postal address, email address and phone number, and associated correspondence, for paper and online Ringing World subscribers and purchasers of notices and merchandise
• Bank account details for direct debit subscribers
• BellBoard logins (email address only) for BellBoard users
• Registered user information (name and email address only) for RW-hosted discussion lists (including ringing-theory, change-ringers and ringing-chat)
• Names, contact details and DBS clearance status (but not certificates) for RWNYC team leaders and other volunteers in relevant supervisory roles
• Names and contact details for other RWNYC volunteers
• Names and dates of birth for RWNYC participants, who are always less than 19 years of age
• Gift Aid information for donors comprising name, address and amount of donation
• Payroll information and HR records for employees
• Names, contact details, dates of birth and other HR information for job applicants and key volunteers including Board members and directors/trustees
• Administrative records such as supplier contact details, supplier bank account details (where supplied for electronic payment), accounting records, correspondence files and contact information for bellringers, trade suppliers and others.
• Server logs. Web logs typically include service/URL accessed, date-time information, IP address, and any username (not password). Email logs include the envelope sender/recipient and the result of any content screening.

According to the General Data Protection Regulation (GDPR), the only special category data held by the Ringing World is employee health and absence information. We also hold the DBS status of RWNYC team leaders and key volunteers, which we treat in the same way as special category data.

What we do with the information we hold

Our policy is to comply with all applicable provisions of the Data Protection Acts and the GDPR. We make all reasonable efforts to keep data secure and up-to-date.

Ringing World editorial activities are carried out in accordance with the IPSO Editors’ Code of Practice, available at https://www.ipso.co.uk/editors-code-of-practice/. Compliance with this code requires that we aim for accuracy and fairness in what we report, publish corrections when we make mistakes, and apply a public interest test before publishing sensitive information. Compliance also means we have a moral duty to protect confidential sources of information, and do not have to disclose or erase personal information even if requested to do so.

Information on bellringing performances (peals, quarters and other similar performances), including the names of participants, is published in The Ringing World and also online on the BellBoard and peals.co.uk websites. In line with our charitable objectives, we maintain historical and statistical records of performances. We endeavour to ensure the accuracy of the information and routinely act on and publish corrections. In order to maintain the historical record, we do not normally change or remove information unless it is incorrect.

The Ringing World hosts several mailing lists and websites. Only registered users can post to the lists directly administered by The Ringing World. Posts represent the submitter’s own views and are not endorsed by the Ringing World. The lists have administrators and moderators. The Ringing World hosts some private lists and other websites for the ringing community, for which the list or site administrators are the data controllers.

We use subscriber and purchaser information primarily in connection with delivering the products and services that have been purchased. BellBoard login information is used to enable access to BellBoard functionality, products, or services; to correspond about BellBoard data or specific company administrative or editorial tasks; and to configure user-specific settings. Discussion list logins are used solely to enable access to the corresponding list.

With your explicit consent, we may use your contact details, however obtained, to send you marketing communications about our products, services, events, or news that we believe may interest you. You can choose to opt in to marketing communications during registration or by updating your preferences with us. You may also withdraw your consent at any time, including by following the unsubscribe link in our communications or by contacting us directly. We may occasionally use our standard marketing channels (for example our email mailing list, BellBoard or our weekly journal) to deliver advertising material from third parties. We will not give these third parties your personal data and we will ensure that any such material is directly relevant to the bellringing community.

We do not carry out any bulk or automated processing of personal data. Our websites, although they carry advertising, do not target advertising at individuals or groups and we don’t do any automatic profiling. All data is processed manually or in ways specifically tailored to the purposes described in this policy, such as delivering services, corresponding with you, or managing your account settings. This ensures a high level of care and precision in how your information is handled.

How we disclose data

Subscriber bank account details used for direct debits are passed to the company (RSM2000) who handle direct debit collection on our behalf. We use Paypal and Square for credit and debit card payment processing. Card details are provided direct to Paypal or Square and not held or processed by the Ringing World. With the exception of bank account details for direct debits, no bank account data held by or processed by the Ringing World is passed to any third party, and it is all held and processed in the UK or EU.

All other personal data is held in the UK or EU, or is subject to the European Commission’s standard adequacy agreement contractual clauses with the data processor.

We may enter into a contract with a third party to process data which may include your personal data. In such a situation, the third party will be acting as the data processor under us as data controllers, and the data processor will be based in the UK or European Economic Area.

We will comply free of charge with reasonable requests for disclosure of personal data, except for editorial information.

Lawful bases and your rights

We process personal data in compliance with the UK GDPR and rely on the following lawful bases:

• Contract: To deliver the products and services you have purchased or registered for.
• Consent: For sending marketing communications about our products and services.
• Legitimate interest: For maintaining our historical records, corresponding about editorial or administrative tasks, and improving our services, provided these do not override your rights and freedoms.
• Legal obligation: For complying with our duties under tax, employment, and other laws.
• Public task (archiving in the public interest): For preserving bellringing performance records and historical data, subject to safeguards to protect individual rights.

Data subjects have rights under the Data Protection Legislation, which we will always work to uphold. These include the rights to be informed about our collection and use of your personal data, to access it, to have it rectified if inaccurate or incomplete, to object to us using it for a particular purpose or purposes, and to restrict (i.e., prevent) our processing of it.

You have the right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold. We may have an overriding legitimate interest to continue this processing.

If we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time; and if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

You also have rights relating to automated decision-making and profiling, but we do not use your personal data in this way.

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office (ICO) or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the ICO. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first.

Archiving in the public interest

The Ringing World considers some of its journalistic and database activities processing personal data to be ‘archiving in the public interest’. According to current legislation, this exempts us from the UK GDPR’s provisions on the right of access; the right to rectification; the right to restrict processing; the obligation to notify others regarding rectification, erasure or restriction; the right to data portability; and the right to object. The UK GDPR also provides exceptions from its provisions on the right to be informed (for indirectly collected data) and the right to erasure.

The exemption and the exceptions only apply:

• to the extent that complying with the provisions above would prevent or seriously impair the achievement of the purposes for processing;
• if the processing is subject to appropriate safeguards for individuals’ rights and freedoms
• if the processing is not likely to cause substantial damage or substantial distress to an individual; and
• if the processing is not used for measures or decisions about particular individuals, except for approved medical research.

Cookies

Some of our websites will attempt to place a cookie in your web browser when you access them. Cookies are not used for marketing, targeted advertising or collection of personal data on any website.

BellBoard only uses cookies if you log in to the site. The cookie is only used to identify the user account you are logged into, and when you logged in. Logging out of the site deletes the cookie.

The Ringing World mailing lists website only uses cookies if you log in to the site.  It is used to identify who you are, and is deleted automatically when you close your browser or log out.

The main Ringing World site sets a session cookie for all visitors which is deleted when you close your browser. The bellringers.org, littleringingbooks.co.uk / .com and rwrld.uk sites make no use of cookies.

Data retention

Our aim is to minimise unnecessary retention of data. We keep accounting and employee records for 11 years, in line with audit and HMRC guidelines, but all other data apart from editorial data is deleted when it is no longer required.

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

Approved by the Ringing World Board February 2025