1. Introduction

HWBIDCO is the name of High Wycombe Business Improvement District Company, a company incorporated and registered in England and Wales under company number 08214693 whose registered office is at Little Market House, Church Square, High Wycombe, Buckinghamshire, HP11 2BN.

Telephone: 01494 452705. Email: info@hwbidco.co.uk.

The data controller is Susan Hynard.

HWBIDCO is a not-for-profit company which has been established by the business community to project manage improvements and services in the centre of High Wycombe. HWBIDCO is the data controller in connection with any personal information collected or received by it arising from a person’s use of any of the HWBIDCO services, websites and support services.

This notice describes the type of personal data HWBIDCO collects and how it may use and share that data. The term “personal data” means information about an identifiable individual which includes name, address, email, telephone number and other information relating specifically to an individual.

HWBIDCO processes personal data in accordance with the United Kingdom’s Data Protection Legislation. It maintains strict security standards and procedures to prevent unauthorised access to personal data. It uses leading technologies such as, but not limited to, data encryption, firewalls and server authentication to protect the security of personal data. For all HWBIDCO companies, all of its staff, and whenever it hires third parties to provide support services, it will require them to observe its privacy standards and to allow audit for compliance.

HWBIDCO’s lawful bases for storing and processing different sorts of personal data are:

• The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
• Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

HWBIDCO is registered with the Information Commissioner’s Office as a data controller (No. ZA012981).

HWBIDCO reserves the right to make changes to this Privacy Policy at any time. The continued use of HWBIDCO services and websites that are subject to this Policy will signify acceptance of any and all changes to this policy made by HWBIDCO from time to time.

2. What data HWBIDCO collects and how it is used

We use the information we collect in the following ways:

• For recruitment and staff employment records
• For recording details of companies based in the centre of High Wycombe, which may include the name and contact details of principal employees, records of interaction between the HWBIDCO and the company, and other pertinent information
• For monitoring persons committing, or suspected of committing, crimes and anti-social behaviour in the town centre
• For record keeping and correspondence with third parties who have an interest in the HWBIDCO or High Wycombe town centre
• For those providing services to HWBIDCO for the operation of the business or its events including bank details and payments
• To provide, operate, and maintain our website and services
• To improve, personalize, and expand our website and services
• To understand and analyze how you use our website and services
• To develop new products, services, features, and functionality
• To communicate with you to provide you with updates and other information relating to the website, and for customer service, marketing and promotional purposes
• To process transactions and manage your orders
• To send you emails
• To find and prevent fraud
• To comply with legal obligations

3. HWBIDCO Members

The information HWBIDCO collects and holds includes the name of the business entity, telephone number and the address of the property that is liable to pay the BID levy. This information has been either obtained from data held by Buckinghamshire Council or directly collected by the BID itself.

The personal information we gather only extends to the business representative’s mobile telephone number, job title, and email address as may be supplied directly by the business representative.

Given the nature of BIDs, it is important for HWBIDCO to demonstrate consultation and engagement with its business community in order to provide the services levy businesses have requested, and the services laid out in the HWBIDCO business plan. We will use data to:

• Identify levy payers who have contacted us in relation to HWBIDCO.
• Keep track of important direct communications we have with the business by storing emails held on an appropriately sourced database management system.
• Send email and postal communications to keep businesses up to date with relevant information, activities and services.
• Record the business’ interest in, or attendance at, an event.
• Review any promotional or advertising material on its websites or when preparing a destination guide.
• Where necessary, process personal data for compliance with regulatory and legal obligations, or in order to protect the vital interests of the data subject or another natural person.
• For statistical analysis.

If a business chooses not to provide HWBIDCO with personal data it may mean that business is not able to access some of the services offered such as newsletters, offers, promotions or receive invitations to events and workshops.

4. Use of images

HWBIDCO uses photos and videos to promote its work and events via social media, websites, e-newsletters and other communications. At times, it may share images for use by its partners to promote or advertise events, projects, services and initiatives. Where possible, it will try to gain prior consent for use of images. If a subject wishes HWBIDCO to cease to use a particular image the subject should contact HWBIDCO directly.

HWBIDCO does not credit or pay for use of images in its photographs or videos.

5. HWBIDCO Newsletter Subscribers

HWBIDCO sends a newsletter email to keep businesses updated on the latest news, footfall reports, training invitations, events, road closures and much more. It gathers statistics around email opening and clicks using industry standard technologies.

Its lawful basis for holding this personal information is through consenting to opt into receiving such correspondence. This consent can be withdrawn at any time by clicking the “unsubscribe” link contained in each newsletter or by contacting HWBIDCO directly.

6. HWBIDCO Customers

When a person or business purchases a product or service from HWBIDCO it will collect the personal information required to perform the service. This information includes the contact name, billing and business addresses, email address, phone number and payment method.

Its lawful basis for collecting this information is the legitimate interest to enable the provision of products and services.

7. HWBIDCO Employees

7.1 Recruitment

The information provided during the recruitment process will only be used for the purpose of progressing applications and will not be shared with any third parties. This information will be held securely whether the information is in electronic or physical format.

HWBIDCO will use the contact details provided to contact applicants through the recruitment process. During any interview the HWBIDCO will ask about previous experience, education, referees and for answers to questions relevant to the role applied for. This information will be used to assess candidates.

Details of unsuccessful candidates will be retained for up to a period of six months.

7.2 Employment

If a conditional offer of employment is made HWBIDCO will ask for information to allow pre-employment checks, such as to confirm the identity of applicants, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability. Successful applicants will be required to provide proof of identity and proof of qualifications. Referees will be contacted directly using details provided in the application. Once a final offer is made the successful applicant must provide the necessary information to allow the employment to be confirmed. If we make a final offer, we will also ask you for the following:

• Bank details to process salary payments
• National Insurance number and tax codes for use with HMRC
• Emergency contact details

During the term of employment HWBIDCO will collect and store information on each member of staff such as performance reviews and leave records.

7.3 Sharing of data

HWBIDCO shares employees’ personal information with its accountant for preparing payroll, with HMRC, and with its pensions provider.

8. Users of My Wycombe and High Wycombe Free WIFI

My Wycombe is delivered by HWBIDCO and funded by the businesses of High Wycombe town centre. My Wycombe provides information, deals and discounts which is promoted through the My Wycombe website (https://mywycombe.com).

High Wycombe Free WIFI is provided by HWBIDCO and is offered to those choosing to subscribe to the service. Users’ personal data is collected and the lawful basis for holding this personal information is through consent given at the time of subscription. This consent may be withdrawn at any time. The personal information held may be used to send newsletters or other information relating to the HWBIDCO’s activities. HWBIDCO gathers statistics around email opening and clicks using industry standard technologies.

My Wycombe Card

The My Wycombe card is a special card providing the bearer with a range of offers and deals that HWBIDCO members have provided. Any person purchasing a card must provide information on their name and email address.

HWBIDCO’s lawful basis for holding this personal information is that purchasers of the gift card have given consent for data to be held.

9. HWBIDCO website

9.1 Cookies

Cookies are small pieces of information sent to users’ computer or browsing device when accessing a website. Cookies can be disabled by changing browser settings but some areas of the HWBIDCO website may not function correctly without the use of cookies. By accessing the HWBIDCO website, users agree cookies can be placed on their device.

Like most websites, HWBIDCO uses third party companies, such as Google, to provide analytics software to monitor web visits. This information is completely anonymous and is only used to improve the website. Google’s information for privacy information relating to these cookies should be consulted if further information is needed.

9.2 Links to other websites

The HWBIDCO website may contain links to other websites that are outside its control and are not covered by this Privacy Policy. The operators of these sites may collect information from users that will be used by them in accordance with their privacy policy, which may differ from that of the HWBIDCO.

9.3 Making contact via our website

Persons may choose to raise a query with the HWBIDCO via the contact forms provided on its website or by emailing info@hwbidco.co.uk. Personal data on those using this facility will be collected and stored.

10. Personal Data Retention Periods

HWBIDCO will only retain personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, the HWBIDCO will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which personal data is processed and whether those purposes can be achieved through other means, and the applicable legal requirements.

Data relating to:

• Clients, customers and suppliers will be maintained for such periods as are laid down by the professional bodies responsible for the conduct of the Company and/or statutory and regulatory requirements.
• BID levy payers will be maintained for seven years after the delivery of the BID is completed.
• Project delivery will be retained for seven years after the end of the BID delivery is completed.
• Recruitment of staff: details of unsuccessful candidates will be retained for up to a period of six months.
• Information provided by staff during the application process will be retained for the duration of the employment plus an additional seven years following the end of that employment.

Where data has been collected from individuals who have undertaken the following activities with the HWBIDCO, the data will be deleted if the HWBIDCO is unsuccessful in renewing its mandate:

• Social media subscribers
• Subscribers to HWBIDCO or My Wycombe newsletters
• Exhibitors and sponsors of events (although financial records are kept for seven years)
• Entrants to our surveys

11. Disclosure of information to outside parties

HWBIDCO will release personal information if it believes release is appropriate to comply with the law, enforce policies or protect its rights, property and safety. It will disclose data as required by order of court, jurisdiction or any judicial, governmental or regulatory body as requested.

HWBIDCO does not circulate, exchange or sell personally identifiable data to outside parties. It uses a number of service providers to assist with the delivery of products and services and will share only necessary personal information with them for this. Details of such providers is available from the HWBIDCO. All service providers are required to maintain the confidentiality and security of personal data and to use it only in compliance with applicable privacy laws. These companies are not authorised to use personal data in any manner, other than in helping to provide products and services or as otherwise required by applicable law.

12. Protection of Personal Data

HWBIDCO maintains administrative, technical and physical safeguards to protect against loss, misuse or unauthorised access, disclosure, alteration or destruction of the personal data provided to it.

13. Your Rights

Under the UK GDPR, you have the following rights:

• The right to access: You have the right to request copies of your personal data.
• The right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The right to erasure: You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing

  Privacy Policy last updated February 2026.