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Promoting employee ownership in the workplace


the eaga Trust Privacy Policy

Last updated: 5-Aug- 17

The eaga Trust (we) are committed to protecting and respecting your privacy.

This policy (together with our Terms of use and any other documents referred to on it) sets
out the basis on which any personal data we collect from you, or that you provide to us, will
be processed by us. Please read the following carefully to understand our views and
practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act), the eaga Trust comprises two
data controllers, namely the Eaga Partnership Trustee Limited (Company No. 03724739) and
Eaga Partnership Trustee Two Limited (Company No. 03729659), registered office of both
being 3rd floor, Citygate, St James Boulevard, Newcastle upon Tyne NE1 4JE and which
operate from 25 Main Street, Ponteland, Northumberland NE20 9NH.

Each data controller is registered with the Information Commissioner. Eaga Partnership
Trustee Limited’s registration number is Z303366X; Eaga Partnership Trustee Two Limited’s
registration number is Z3033869.

The privacy policy includes the following sections:

  1. Information we may collect from you or receive from others
  2. Special notice: Information about family members
  3. Information others may collect from you
  4. Cookies
  5. Where we store your personal data
  6. How long we store your personal data for
  7. Uses made of your information
  8. Disclosure of your information
  9. Your rights
  10. Other sites
  11. Access to your information
  12. Changes to our privacy policy
  13. Contact

1. Information we may collect from you or receive from others

We will collect and process the following data about you at registration:

  • Title
  • Full name
  • Date of birth (required by the provider of the Trust Health benefit, used by us and may be required by other providers)
  • Gender (M/F) (optional: if you select Prefer not to say please be aware that this may mean you are not eligible for certain benefits such as the Trust Health benefit)
  • National Insurance number (required by the Trust accountants to make the TrustShare discretionary payment(s) and to pay certain other benefits)
  • Business area while working for eaga
  • Proof of your employment by eaga, for example P45/P60/payslip and/or other documents (required for the purpose of verifying your entitlement to membership and (in part) to verify the entitlement of your family members)
  • Address, including postcode
  • Contact information including telephone or mobile and email address. (Please see the ‘Special notice’; below for information collected on family members.)
    If you apply for a Business Funding loan of over £10,000, we will collect information from
    you during the offline application process that is conducted after completion of the initial
    enquiry form on our site. This includes information about your need for the business
    funding loan and evidence of any funding contribution to be made. We do not conduct
    credit checks on your directors or other officers for the purpose of these loans.
    (Business funding start up loans of £10,000 or under are provided by our subsidiary. Our
    subsidiary will conduct credit checks and will provide details of this process to you
    separately. Please see the 'Disclosure of your information' section below for details of our


We may collect other information about you as follows:

  • Information about your use of the website and any emails, texts or letters you send to us or which is recorded by us as a result of calls from you
  • Information about your visit to our site, including but not limited to: your IP address, operating system, browser type and version, location, length of your visit, the pages you have visited, weblogs and other communication data. This information is held on our server logs and is used for system administration and for generating statistical information to help improve our service. We may use this information to investigate and take action against any misuse of the website.
  • If you are using the holiday home in Spain or Florida, you will need to supply a copy of your flight itinerary to us 2 weeks prior to your holiday. You will also need to email the management agent in Spain directly with your completed villa arrival form, which you will receive by email along with your welcome letter 6 weeks prior to your holiday.

Information from our surveys or research that you participate in. We may also receive information about you from third party providers of Trust benefits. For example, if you ask to be put in touch with The Prince’s Trust with a view to applying for one of their programmes, they will tell us whether you have been accepted onto the programme or not, and if you are, will tell us the course date and venue, provide us with quarterly reports and at the end of the programme, provide us with case studies and photographs.

2. Special notice: Information about family members
Trust Share benefit

We need to identify beneficiaries of the eaga Trust and to ensure the information we hold
on them is accurate and up to date. We also wish to know something about beneficiaires so
we can design benefits to suit them. Please see section 7. Uses made of your information
which explains how we use surveys.
We will therefore ask you to provide some information about certain of your family
members in the context of the TrustShare benefit, namely your spouse/civil partner and
children, including your step-children up to the age of 18. As discretionary payment(s) may
be made, and other benefits provided, to registered/approved beneficiaries of the eaga
Trust, we think it is in the interests of family members that the eaga Trust identifies them as
beneficiaries and registers their details.
Before providing us with details of your spouse/civil partner, please provide them with a
copy of this special notice and only provide us with their details if you have their express
consent to do so.
In the case of a child whom you consider to be capable of understanding this special notice,
please provide them with a copy, and explain it to them if they need help. If you provide
information about that child, we ask you to confirm that the child:

(a) has expressly agreed to his/her details being provided to us

(b) has been given a copy of this special notice (including our contact details at the end of
the special notice).

If your child is not capable of understanding this special notice, please only provide us with
your child’s details if you consider it would be in his/her best interests to do so. We will ask
you to confirm that you have parental responsibility for the child and give us your consent
to us processing his/her personal data for the purpose of identifying and, if applicable,
registering his/her details as registered/approved beneficiary. If the child is already a
member, we will use his/her personal data to check the accuracy of our records and update
them if necessary.The information we collect on family members is:

  • full name; relationship to you; whether the individual is already a member of the eaga Trust; date of birth; gender (M/F) and address
  • email address, telephone and mobile number (optional)
  • level of education; other qualifications (optional)
  • if the individual is 16 years or over, we will also ask for:
    • the National Insurance number or other unique identifier (depending on the country the individual lives in) (optional)
    • employment status (which includes student), and
    • if applicable, the employment level (e.g. owner or employee).

We may write to the child (at your address) once she/he is 16 years old to ask for the
National Insurance number, which the Trust accountants need to make any payment.
We may also ask you and/or your children to provide further information if they wish to
apply for other discretionary Trust benefits that may become available from time to time.
Skill-Builder Plus benefit and The Prince’s Trust programmes
The Skill-Builder Plus benefit and The Prince’s Trust ‘Get Into’ and ‘Explore Enterprise’
programmes are open to eligible children of members as well as the members themselves.

Children of members will need to register themselves. We ask for the child’s full name,
relationship to the member (child/step-child), date of birth, NI number/other unique
identifier for international members, address including postcode, email address, phone
number and occupation (please put ‘prefer not to say’ if you would rather not provide this)
as well as details of the Skill-builder Plus training course and an invoice for the course,
addressed to the eaga Trust but includes the child’s name. We will also need the child’s
original ‘Certified Copy of an Entry of Birth’ or other document confirming parenthood
(there is a list on the application form), and if the child is your step-child, your original
marriage or civil partnership certificate showing your relationship to the birth parent.

If a child has changed their surname by marriage or deed poll and it is different from the Certified Copy of an Entry of Birth, they will also need to supply the original marriage certificate or deed poll documents. The Skill-Builder Plus application form and our website set out these requirements and others in more detail. We will keep a copy of the documents
supplied, which will be stored securely.
If you have any questions about this special notice, please contact us by writing to the eaga
Trust, 25 Main Street, Ponteland, Northumberland NE20 9NH or by email to

3. Information others may collect from you

We may ask for bank details in order to make discretionary payments to
registered/approved beneficiaries of the eaga Trust or on their behalf. If we do, you will be
asked to provide those details direct to the Trust accountants (UNW LLP). We do not store
your bank details in our database. Likewise, the Trust accountants will occasionally need to
take your card details if you have to make a payment, for example an administration fee for
a holiday home where there has been a late cancellation. The Trust accountants also make
payments on your behalf, for example where a benefit such as Trust Skill-Builder or Skill-
Builder Plus is payable direct to a course provider. The Trust accountants are our data
processor and process your data on our behalf.
We use Sagepay to take payments through the website, which is the normal way that
payment of the administration fee for a holiday home is taken.
You may also provide your data direct to other eaga Trust members (registered users) and
third parties that provide benefits to members. For example, members may run sport and
social events; Health Shield Friendly Society Ltd provides the Trust Health benefit; The
Prince's Trust provides the Get Into and Explore Enterprise programmes; the Get Into
programme is provided in conjunction with The Prince's Trust's delivery partners who may
also collect data from you; various third party suppliers provide affinity deals, member
discounts and other benefits such as specific types of insurance. These members and third
parties are not our data processors but separate data controllers and this privacy policy
does not apply to their use of your personal data: please ask the third parties for their data
protection or privacy policy and also see the ‘Other Sites’ section below.
We use MailChimp to send out emails to members. MailChimp is the trading name of The
Rocket Science Group LLC, an email services provider based in the US. MailChimp will store
your first name, last name, email address, country and membership number in the US and may also track the emails we send you. Please see the ‘Cookies’ and ‘Where we store your
personal data’sections below.

4. Cookies

We may obtain information about your use of our site using cookies. Cookies contain
information that is transferred to your computer’s/device’s hard drive. They help us to
improve our site and to deliver a better and more personalised service.
The first type of cookie we use is an essential or strictly necessary cookie:
Cookie Name Purpose
Cookie laravel_session Login cookie, which allows access to restricted members-only


This cookie will expire after you close the browser or after a 2 hour period.
We also use performance cookies provided by Google Analytics. These web analytic cookies
are used to analyse the use of this website. Google Analytics generates statistical and other
information about website use by means of cookies, which are stored on users’ computers.
The information generated relating to our website is used to create reports about the use of
the website. Google will store this information: please see
http://www.google.co.uk/intl/en/privacy/privacy-policy.html for further details.
Cookie Name Purpose

_utma _utmb _utmc _utmt

Performance cookies, used to analyse the use of
this website.

These analytic cookies expire after 2 years.
You can refuse analytic cookies by following the instructions in the cookie banner which
appears at the bottom of the screen when you first visit our site. If you refuse analytic
cookies (click 'change your settings' or 'see details', untick the analytics box and choose
'save preference' or 'save for all sites'), a stop-cookie will be set as follows:
Cookie Name Purpose
Stop Cookie cc_analytics To block cookies using Silktide’s cookie consent tool (see


The content of the cookie will be set to one of four options:
Your choice of analytics or not Your choice of this site or all sites Cookie content

Yes – you leave the analytics box ticked: this site "yes"
all sites "always"
No – you untick the analytics box: this site "no"
all sites "never"
To opt out of Google analytics cookies across all websites using Google’s tool, please go to
https://tools.google.com/dlpage/gaoptout and install the opt-outs for your browser. As at
5-Aug- 17, opt-outs are available for Internet Explorer versions 11, Google Chrome, Mozilla
Firefox, Apple Safari and Opera.
Some content from our web pages will be automatically stored on your computer/device’s
storage media. Some 'local storage' and 'session storage' files may be set automatically by
your browser, but we do not use these. MailChimp (our email services provider – please see
'Information others may collect from you' above) may use cookies and web beacons to track
the emails we send out and report to us who has or hasn’t opened emails or clicked on links.
Please see MailChimp’s privacy policy (the cookies and web beacons sections) for further
details, which you can find at http://mailchimp.com/legal.
You may block cookies by activating the setting on your browser which allows you to refuse
the setting of all or some cookies: see http://www.allaboutcookies.org/ for information on
how to do this. However, if you use your browser settings to block all cookies (including
essential cookies) you may not be to access all or parts of our site.

5. Where we store your personal data

Our mailing list is stored in the US, with MailChimp (please see Information others may
collect from you above). Details of the security MailChimp applies to its customers’ lists
(including our list) are set out in its privacy policy which you can find at:
http://mailchimp.com/legal/privacy. When we ask for consent to use your email address to
send you emails and your phone number for texts, we will also ask you for express consent
to the transfer of your data to MailChimp. MailChimp is certified in the EU-US Privacy Shield
We will otherwise store the data that we collect from you in the UK and/or the Republic of
Ireland. However if you are resident in a country outside of Europe, you agree that we will
need to export your personal data to you. If you book one of our holiday homes in the US,
we will need to share your membership number, name, date of birth and
mobile/telephone/email contact details with the management company agent in the US:
please see the ‘Disclosure’ section below.

We will store any eligibility documentation you provide in a secured database. If you have
sent us original eligibility documentation, we will scan it, store the scanned image in the
secured database, and send you back the original securely. Access to the secured database
is restricted to those who need access (a) to process your application for membership, (b) to
verify the entitlement of a family member of yours or (c) for audit purposes.
If you apply for a Business Funding loan of over £10,000, we will store the information you
provide in a secure storage facility.
All other information you provide to us is stored on our secure server and is transferred to
us using SSL encryption. Once we have received your information, we will use strict
procedures and security features to try to prevent unauthorised access and keep your
information secure. Please note that sending information to us by unencrypted email is not
secure. You may prefer to encrypt a file and email that to us, with the password sent to us
separately by another means such as a telephone call or by secure post. If you post any
personal data to us, or bank details to the Trust accountants, please use a secure method of
posting. Please contact Royal Mail or your carrier about the secure options they provide.
6. How long we store your personal data for
We will retain your proof of employment for up to 13 years following expiry or earlier
termination of your membership or (if later) the expiry or earlier termination of any family
membership. That is because your proof of employment is used to verify your family
members' status as beneficiaries and therefore their entitlement to benefits or services. For
the same reason, if your child's application for a benefit is successful, we will retain any copy
of your child's birth certificate for the same period. If you provide a marriage or civil
partnership certificate to show that you are the step-parent of a child, we will destroy that
certificate once the step-child is 18 and no longer eligible for Trust benefits.
We will retain all other information about you for up to 13 years following expiry or earlier
termination of your membership.
7. Uses made of your information
We require your information to understand your needs and provide you with a better
service, and in particular for the following reasons:
 To verify your entitlement to membership, and to verify the entitlement of your family
 To provide you with access to all parts of our website and, where appropriate to assess,
approve or otherwise, and then to supply the services and benefits you have requested. It
will also enable us to contact you where necessary concerning your request for services or
 To carry out surveys, research, analytics and profiling, which is to improve the benefits we
offer (for example we collect occupation so that we can tailor future benefits). We or our
contractors may create derived data about you from combining our data with other data
sets and we or our contractors may create inferred data by using algorithms that analyse a
variety of data to create profiles.
 To ensure that content from our site is presented in the most effective manner for you and
for your computer/device.
 To carry out our obligations arising from any contracts entered into between you and us.
 To allow you to participate in interactive features of our service, when you choose to do so.
 If you agree, to email or text you to ask for your views on potential new benefits, notify you
of changes to benefits and send you service updates, announcements and news.
We use MailChimp to send out emails to members. Please see the ‘Information others may
collect from you’, ‘Cookies’ and ‘Where we store your personal data’ sections above for
further details of MailChimp.

8. Disclosure of your information

We may share your personal information with any member of our group, which means our
subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of
the UK Companies Act 2006. Business funding start up loans of £10,000 or under are
provided by our subsidiary eT Business Funding Limited, Company No. 08026173. eT
Business Funding Limited is a data controller and registered with the Information
Commissioner: registration number ZA024813.
We will also share your personal information with your Carillion/eaga employer or ex-
employer, Carillion plc (Company number 3782379) whose registered office is at 24 Birch
Street Wolverhampton WV1 4HY, or its group company which employs you or employed
you, so that we and they can keep our respective records accurate and up to date.
We may disclose your personal information to third parties:
 To provide benefits to you: for example we will share your details (including salutation, first
name, surname, address, contact number, email address, membership number, gender and
date of birth) with Health Shield Friendly Society Ltd for the Trust Health benefit and with The Prince’s Trust if you are interested in applying for one of their programmes. If you are
unfortunate enough to have an accident and submit a claim to ACE European Group Limited
(a Chubb group company), the provider of our Serious injury insurance benefit, ACE will
contact us to inform us you have enquired about making a claim and we will confirm your
membership and therefore inclusion within the programme. We will keep a record of our
correspondence with ACE. If you book one of our holiday homes, we will disclose your
membership number, name, date of birth and mobile/telephone/email contact details and
(other than for our US holiday homes) your expected date/time of arrival, to the
management company agent. Please note that in the case of booking our US holiday homes,
you acknowledge this will involve an export of your personal data to the US.
 In the event that we sell or buy any business or assets, in which case we may disclose your
personal data to the prospective seller or buyer of such business or assets.
 If any company in the eaga Trust or substantially all of its assets are acquired by a third
party, in which case personal data held by it about its members will be one of the
transferred assets.
 If we are under a duty to disclose or share your personal data in order to comply with any
legal obligation, or in order to enforce or apply our website Terms of use and other
agreements; or to protect the rights, property, or safety of the eaga Trust, our members, or
others. This includes disclosure to auditors.

9. Your rights

The eaga Trust does not advertise, market or sell goods or services but distributes benefits
to members. We communicate with our members by means of email newsletters. You may
opt-out of these email newsletters by using the unsubscribe option in the email and text
marketing by following the stop instructions in the text or by logging into the site and
changing your options in 'my profile'. You can still choose to keep up to date with what is
happening through our social media channels and our website. Please note that even if you
opt out of emails and texts, we will still use your email address and phone number to
contact you for administration purposes.
If you wish to withdraw consent to us sending your details to MailChimp in the US, please
follow the opt-out instructions for email above.
If you believe that any information we are holding on you is incorrect or incomplete, please
log into the site and change it in ‘my profile’ or write to or email us as soon as possible. We
will promptly correct any information found to be incorrect.

10. Other sites

Our site may, from time to time, contain links to and from other websites of interest or
which provide benefits. If you follow a link to any of these websites, please note that these
websites have their own privacy policies and that we do not accept any responsibility or
liability for these policies. Please check these policies before you submit any personal data
to these websites.
Our site contains links to our pages on social media. Please check the privacy policies on
those pages. The social media platform provider will collect data about you when you visit
our pages.

11. Access to your information

The Act gives you the right to access information held about you. Your right of access can be
exercised in accordance with the Act. Any access request may be subject to a statutory fee
of £10.

12. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page
and, where appropriate, notified to you by email or text.

13. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should
be addressed to the eaga Trust, 25 Main Street, Ponteland, Northumberland NE20 9NH or to