Westmill Solar Co-operative Privacy Policy 

Westmill Solar Co-operative Limited is committed to protecting your personal information and being transparent about how we use it, whether you are a member (or nominated representative), applying to be a member (or nominated representative) or you have registered your details so you can hear from us. 

This Privacy Policy aims to give you a clear explanation about how Westmill Solar Co-operative Limited collects personal information (or “personal data”), the types of personal information we collect, how we use it (or “process” it), and whether we share it with anyone else.  It also explains your legal rights and choices regarding the information you provide to us. 

If you are using any aspect of the Westmill Energy website, of which we are one of the partner organisations, please click here to read the Privacy Policy for visitors to the Westmill Energy website. 

Children’s privacy 

Our services are not aimed at children. 

Our contact details 

If you need to contact us about this Privacy Notice or have a question about your personal data, our contact details are: 

Westmill Solar Co-operative Limited
Unit 26, Trinity Enterprise Centre
Furness Business Park
Barrow-in-Furness
Cumbria
LA14 2PN 

info@westmillsolar.coop
01229 821028 

Who is responsible for your personal data? 

Westmill Solar Co-operative Limited is responsible for how and why your personal data is used. The legal phrase for this is Data Controller (or “Controller”).  Westmill Solar and Westmill Solar Co-operative are trading names of Westmill Solar Co-operative Limited. 

We are a Registered Society under the Co-operative and Community Benefit Societies Act 2014 with registration number 31265R. 

Our registered and business address is: 

Westmill Solar Co-operative Limited
The Old Music Hall
106-108 Cowley Road
Oxford
OX4 1JE

Your legal rights 

You have the following legal rights in relation to the processing of your personal information: 

• To be informed: You have the right to know what personal information we are processing about you, how and why. The information in this Privacy Notice is intended to provide you with this information. If you need more information, please ask us; 

• Access: You have the right to request a copy of your personal information that we hold about you together with other information relating to its use, subject to the application of any relevant legal exemptions; 

• Erasure: At your request, we will delete your personal information from our records providing we don’t have an overriding legitimate reason for holding on to it; 

• Rectification: We aim to keep your personal information accurate, current, and complete. We encourage you to contact us by emailing us at info@westmillsolar.coop.  Please let us know if any of your personal information is inaccurate or changes, so that we can keep it correct and up-to-date; 

• Objecting: In certain circumstances, you have the right to object to the processing of your personal information where we are: (i) processing your personal information on the legal basis of legitimate interests and we have no compelling reason we can demonstrate to continue with that processing, or (ii) using your personal information for direct marketing, or (iii) using your personal information for statistical purposes; 

• Right to restrict processing: You have the right to ask us to restrict the processing of your personal information whilst a disagreement is resolved about its accuracy or whether we can use it on the legal basis of “legitimate interests”; 

• Rights related to automated decision making: Where we take automated decisions in relation to your personal information with no human involvement (i.e. such as credit scoring) you have the right to ask us for human intervention or to challenge any such decision; 

• Right to withdraw consent: If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partly withdraw your consent; 

• Porting: You have the right to request that some of your personal information is provided to you, or to another information controller, in a commonly used, machine-readable format. 

How to exercise your legal rights 

You may exercise any of the above rights, at any time, by emailing us at info@westmillsolar.coop together with proof of your identity, i.e. a copy of your ID card, or passport, or any other valid identifying document. 

Complaints 

If you believe that your information protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts. The UK, supervisory body is the Information Commissioner’s Office (ICO). 

Information about other people 

If you provide information to us about any person other than yourself, such as your partner, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it. 

Personal Data we collect and how we use it 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:  

• Identity and Contact Data: including your first name, surname, title, email address, postal address, telephone number, mobile number, date of birth employer or organisations you are affiliated to, your role with your employer or the organisation you are affiliated to; 

• A record that you are an investor in one or more of our projects including the name of the project, amount of investment, number of shares, the reference number that we attribute to you when you become a member, the votes you cast; 

• Financial and Payment Data: including bank account name, bank account number, sort code and other data necessary for processing payments and fraud prevention; 

• Representatives details: Proof of any changes to the details that we hold about you including details of any representatives such as a Power of Attorney or Executor; 

• Third party publications/media source where you first heard about Westmill Solar Co-operative Limited; 

• Your preferences in receiving marketing information from us including mode of communication; 

• Images and video from attending one of our events 

In addition to the above, where you are a Westmill Energy website visitor, we may collect any of the following:  

• Profile and Usage Data: your preferences in receiving marketing information from us, your communication preferences and information about how you use our website including the services/pages you viewed or searched for, page response times, download errors, length of visits, referring website/page and page interaction information (such as scrolling, clicks, and mouse-overs); 

• Technical Data, including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform; 

• Any other information you give us: such as information provided in an online enquiry form or email or other correspondence. 

Special Categories of Personal Data 

Special Category Personal Data specifically means personal data relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. 

Westmill Solar Co-operative Limited does not expect to routinely collect or process special categories of personal data unless you give this information to us. 

Neither do we routinely collect any information about criminal convictions (including offences and alleged offences and any court proceedings or sentence) unless you give this sort of information to us. 

Source of your personal information 

Westmill Solar Co-operative Limited expects to collect your personal information directly from you and from third party sources. For example: 

• Directly from you: when you contact us via the Westmill Energy website or complete an online contact form or “Register Your Interest” form or share application form; 

• Indirectly from third parties: where information is provided by third parties such as any nominated representative or agent of yours; where you have provided data to our Bond Registrar; where you have contacted one of the entities in the Westmill Energy partnership and they need to transfer your data to us as the query pertains to Westmill Solar Co-operative; Indirectly via web-based services: for example, where analytical information is collected through electronic platforms made available to you in connection with services that we provide to you. 

 How will we use your personal information? 

We use your personal information (with the support of Energy4All, our main service provider) 

• to administer, process and manage your communications (including your online enquiry) and our relationship; 

• to manage your shareholding; 

• to manage your bondholding; 

• to keep our members register and bondholders register up-to-date and to comply with our various legal obligations; 

• to notify you of member-related information, including important information about dividend distributions, member resolutions, reports and meetings, including details of our Annual General Meeting; 

• to send you relevant information relating to Westmill Solar Co-operative Limited’s other community energy project/s such as investment opportunities; 

• To process payments, billings and collection of payments; 

• For promotional, and marketing purposes where you have consented to receive such information; 

Legal Basis for processing your personal data 

The UK General Data Protection Regulation (GDPR) requires us to provide you with information about the legal reason (or “legal basis”) for processing your personal data. 

Legal Obligation 

We may need to use your personal data in order to comply with our legal obligations. For example: 

• If you opt-out of receiving our marketing information, we will delete your personal information except for your basic contact information which will be transferred into a secure separate list known as a direct marketing suppression list, to ensure that we comply with your objection to direct marketing. The legal basis for retaining your basic contact details is that it is necessary to do so in order to comply with our legal obligation under data protection law. 

• To comply with our various statutory obligations and your rights as a member in accordance with our Articles of Association and any applicable laws including notifying you of meetings where you have a right to vote such as the Annual General Meeting. We will also process your personal data to notify you of any dividends or interest payments that are due to be paid to you. 

• To maintain a record of your investment so that we can comply with anti-money laundering and tax laws. 

 Contract 

If you enter into a contract with Westmill Solar Co-operative Limited, we will need to collect and process some personal information in order to administer that contract. Where this happens, our legal basis for processing your personal information is contractual. 

Legitimate Interests 

In most other cases, our use of your personal data will be on the legal basis that it is necessary for our legitimate interests, or those of a trusted third party such as Energy4All (Energy4All is our community energy partner), providing those interests are not overridden by your own interests or fundamental rights and freedoms. For example: 

• We will need to process your personal information in order to respond to and administer your enquiry or correspondence; 

• To keep you informed about important information, developments and updates; 

• We may process your personal information for security purposes or to develop our business generally; 

• to send you promotional and direct marketing material by post. 

 Consent 

Where you have provided your consent we may process your personal information in the following circumstances: 

• to send you marketing information by post, email and telephone; 

• to send you electronic direct marketing that you haven’t specifically requested; 

• to publish a testimonial, you have provided in conjunction with your name; 

• to publish an image or video of you where you are the main focus (or your image is accompanied by your name), on a third-party social networking platform such as LinkedIn, Facebook or Twitter; 

• to share your personal data with any third party for marketing purposes. For example, we may share your information with Energy4All but only with your specific consent. 

 Direct Marketing 

Westmill Solar Co-operative Limited processes personal data for the purposes of direct marketing and promoting our organisation. However, unless you consent, we will never sell or rent your personal information to a third party, for that third party’s marketing purposes. 

We rely on your specific opt-in consent to process your personal information to send you direct marketing that you haven’t specifically requested. For example, when we send you updates via email or post. 

You can stop receiving our marketing at any time by clicking on the “unsubscribe” option in our email communications or by emailing us at info@westmillsolar.coop or you can write to us. Our contact details can be found in the Contact Us section of this policy. 

Where we require your consent to send you direct marketing, you have the legal right to withdraw that consent at any time. 

Withdrawal of consent to receive marketing communications will not affect the processing of your personal data for the provision of our other services which do not rely upon your consent. For example, if you are an investor in any of our projects and withdraw your marketing consent, you will continue to be sent only communications which relate directly to the operation of the project(s) in which you invested. 

However, by withdrawing or not providing your consent to direct marketing, you may not receive information about Westmill Solar Co-operative Limited’s projects such as other share offers. 

Explicit Consent and Substantial Public Interests Based Upon Law 

Rarely, Westmill Solar Co-operative Limited need to process special categories of personal data such as health or medical information. For example, in order that we can cater for specific dietary needs or a hearing impairment at an event you are attending. We will only process this sort of information with your explicit consent or where it is necessary for reasons of substantial public interest that are based upon a law. 

Legal Claims 

Westmill Solar Co-operative Limited may process special category personal information where it is necessary to establish, exercise or defence legal claims or where a court is acting in a judicial capacity. 

How we share your personal data 

Normally, we wouldn’t expect to share your personal data with another organisation except in the following circumstances: 

• with trusted affiliates or undertakings for the purposes of providing you with our services as described in this Privacy Policy, for example, Energy4All and Ethex Investment Club Limited. 

• with the other organisations that constitute Westmill Energy if it is needed to do so in order to deliver a Joint Service. For example, if an enquiry relating to a Westmill Energy Joint Service is accidentally submitted to Westmill Solar Co-operative, we will re-direct to the Partnership to be handled on a joint basis 

• on a confidential basis with third parties for the purposes of collecting your feedback on our services, to help us measure our performance and to improve and promote our services; 

• with trusted service providers who we engage. For example, external software providers, payment providers who help us manage dividend and other payments to our shareholders and mailers. Where we do this, the service providers are contractually required by us to keep your personal data secure and to only process it strictly in accordance with our instructions and in accordance with data protection laws; 

• where you have consented, with third parties for their marketing purposes; 

• with third party data controllers where we have a legal obligation to do so including regulators who regulate how we operate such as HMRC, Companies House, Financial Conduct Authority and the Information Commissioner's Office; 

• with any individual or company to whom we propose to transfer our obligations and rights in relation to the administration of our share register; 

• with any third-party at your request or with your specific consent. For example, with your agent or other representative;  

• with any third-party where if the law requires or permits disclosure, or there is a duty to the public to share or disclose your personal information. For example, for the purpose of verifying shareholdings or contacting shareholders about matters relating to the company, their shareholding or a related exercise of rights; 

• Working with regulators and fraud prevention and detection agencies: 

• We may use your personal information to help us to detect and prevent fraud, fight financial crime and meet our regulatory responsibilities. This may involve checking public registers (e.g. the electoral roll or registers of county court judgments, bankruptcy orders or repossessions), conducting online searches from websites and other information sharing platforms and using databases managed by credit reference agencies and other reputable organisations. This will help us verify your identity and carry out tracing exercises. We may also share your information and undertake searches with third party organisations such as public bodies, credit reference agencies, fraud prevention agencies and our regulators (which include the FCA, and ICO). 

If you provide us with false or inaccurate information and we suspect fraud, we will record this to prevent further fraud and money laundering.  

Information we transfer outside the UK 

In delivering our services to you, it is sometimes necessary for us to share your personal data outside the UK. This might arise where, for example, we are facilitating a payment to your bank which is located overseas, or where our service providers are located/store data outside the UK (for example, we use Intuit Mailchimp when sending out membership communications who are based in the US). 

We have taken steps to implement appropriate safeguards to ensure that the personal data we process is protected in accordance with data protection law (including the UK GDPR) when transferred outside the UK. The safeguards we have taken include: 

• Checking whether there is an adequacy decision in place in respect of any countries outside the UK to which we transfer or receive your personal data; 

• Implementing the European Commission's Standard Contractual Clauses (which are recognised as a valid personal data transfer mechanism in the UK) for transfers of personal data, or another adequate transfer mechanism. 

Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data out of the UK. 

Security of your personal data 

Westmill Solar Co-operative Limited has put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

For example, your personal data is held in a secure password-protected database accessible only by those staff or IT service providers that need access. Where it is necessary to do so, some of your data may be downloaded and stored on paper at our office while we carry out analysis of data. Paper based data is securely shredded and disposed of at the end of any analysis work. 

If you would like more specific information about our security measures please contact us at info@westmillsolar.coop. 

How long we keep your personal data 

Westmill Solar Co-operative Limited will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for us to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. 

We do keep certain records, which may include personal data, for more extended periods, for example, after you have withdrawn your shareholding, if we need to do this to comply with our legal, regulatory, tax or accounting needs and obligations. 

For example: 

• If you unsubscribe from our marketing database your personal data will be deleted from our marketing database as soon as possible and at the latest within one month.  

• If you have contacted us with a general enquiry via our website, and you are not a member of the co-operative, we will reply to you using the contact details provided. Unless you have specifically consented to your personal data being added to our direct marketing database, your contact information will be stored for a period of up to one year in case any follow up is required. Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. 

If you want to learn more about our specific retention periods for your personal data established in our retention policy, you may contact us at Westmill Solar Co-operative. 

Automated decision making and profiling 

Westmill Solar Co-operative Limited does not use your personal information for automated decision making or profiling purposes. 

Automated decision-making is the process of making a decision which produces significant legal effects for that individual and that decision is made solely by automated means without a human being involved at all. 

Profiling means the analysis of certain characteristics of an individual’s personality, behaviour, interests and habits to find out more about their preferences or to make predictions about their behaviour and/ or to make decisions about them. 

Change of ownership 

If we were to sell or transfer Westmill Solar Co-operative Limited to another organisation, your records would also transfer to the new owner.  Limited information may also be shared, where required, with legal and other professional advisors involved in that transaction. 

The reason we would transfer your records is to minimise the disruption to the on-going operation of Westmill Solar Co-operative Limited and to ensure we and a new owner were able to comply with our legal obligations regarding the retention of such records, including the ongoing delivery of care and service to you and our associates. 

Changes to our Privacy Policy 

We will update and change this Privacy Policy from time to time to reflect any changes to the way in which we process your personal information or changing legal requirements. 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. Please check back frequently to see any updates or changes to our Privacy Policy. 

This version was last updated on 18th June 2025.