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Data Policy for Farmers

This policy may be updated from time to time to reflect emerging best practice. Farm businesses will be notified of this occurrence and a new version with any material impact will be shared.

Introduction

3Keel Group Ltd is the registered proprietor of the Landscape Enterprise Networks (LENs). LENs is a well-established  approach to creating integrated, place-based marketplaces for ecosystem services. LENs creates local trading  networks where multiple buyers with a common interest in nature-based solutions are linked up and matched  with groups of land managers (farmers) who can deliver measurable ecosystem outcomes through the implementation of regenerative agriculture practices (called “measures”).

LENs is committed to respecting your personal data and privacy, protecting your farm business data  and to being transparent about what data it holds about you and why. Any personal information held by LENs will be used fairly and securely, and in accordance with the UK and EU GDPR and established responsible data principles – meaning that your data will be used fairly, lawfully and transparently, only necessary data will be collected, it will only be retained for as long as it is needed, it will only be used for the purposes described, and it will be kept accurate, up to date and secure.

This policy describes what data LENs hold and why, and how it is stored, used and deleted, and sets out your rights.

Who is the data controller

The data controller is 3Keel Group Ltd with registered office 7 Fenlock Court, Blenheim Business Park, Long Hanborough, Oxfordshire, OX29 8LN.

The types of data that LENs collects about you

LENs currently collects and processes the following information:

Personal Data

  • Personal identifiers and contact details of farmers (for example, name, telephone number, email address, etc.);
  • Socio-demographic data of farmers, such as date of birth, gender and education;

Farm Data

  • Farm business name, farm business/property address, business registration details, land tenure arrangements, land ownership arrangements.
  • Farm-level data relating to the size, location and use of land, and to farming practices in use;
  • Information pertaining to field locations (shapefiles of farm boundaries and geo-referenced information) for your farm business;
  • Information pertaining to your proposed LENs measures and any other relevant agri-environmental schemes for a given year;
  • Information pertaining to the verification of the implementation of LENs measures, for example invoices, receipts, photographs;
  • Farm-level data relating to the environmental outcomes on your farm.

How and why LENs obtains your data

Most of the data that LENs collects and processes is provided directly by you, or via your representative, for the purposes of creating and executing LENs agreements.

LENs also receives data indirectly, from the following sources in the following scenarios:

  • Other LENs delivery partners (those parties that are signatories in the project agreement)- for example, Supply Aggregators and Regional Operators- for the purposes of creating and executing a LENs agreement;
  • Third-party MRV service and Data Platform providers for the purposes of accepting applications for LENs funding, being able to confirm the implementation of LENs measures and reporting the outcomes of those measures. Such service providers should have their own data policies, to which you will be asked to agree separately. LENs will review these external data policies annually to ensure they are consistent with this LENs policy.

Where necessary, we may share this information with LENs partners or third-party MRV service and data platform providers, as follows:

  • LENs delivery partners, for the purposes of creating and executing LENs agreements;
  • Funders, for the purposes of reporting outcomes, issuing project agreements and managing payments. Farm businesses environmental outcomes will be combined with those of other participating farms in LENs when reported to funders as standard practice. However, in some instances (for example when funders are public bodies or have accessed public sources of funding) we are required to report individual farm-level data, for example shapefiles of where measures are implemented. If identifiable business data is required by funders, LENs will inform farm businesses of the requirements in advance.
  • Third-party MRV service providers, so they know who to contact and which farms to visit for the purposes of their inputs;
  • Data Platform providers, so they can create farm LENs accounts, and MRV providers can input and update information relating to LENs measure implementation;
  • Online carbon calculators for the purpose of calculating carbon outcomes related to implemented LENs and other sustainability measures;
  • Organisations/universities/research institutes whose interests are aligned with LENs mission. For example, organisations which analyse climate risks for specific crops- LENs data can contribute towards a global knowledge base with data gathered from LENs farms.
  • Annually, LENs will produce a programme wide Impact Report which reports on progress of the programme and its environmental impact. Data contained within the report will be aggregated, like funder reports, but we may ask farmers for individual quotes, case studies and photographs. Any case study, quote or photograph which identifies a farm/farmer will require permission from the farmer/farm business.

Under the EU and UK General Data Protection Regulation (EU GDPR and UK GDPR), the lawful bases LENs relies on for processing this information are:

  • LENs has a contractual obligation;
  • LENs has a legal obligation;
  • LENs has a legitimate interest.

How your data will be used

  • Your personal information will be used for the purposes of issuing and executing LENs agreements and for contacting you regarding the implementation of those agreements. This will include sharing your contact information with MRV providers for the purposes of MRV data collection and with LENs staff and delivery partners to process this information.Legal basis for processing (contractual and legitimate interest): i.e. performance of contract including the basic service fulfilment of the contract obligations to farm businesses and funders, and to be able to conduct MRV data collection and reporting
  • Data relating to your LENs contract will be used for the purposes of tracking and verifying implementation. This includes photographs of your farm, including photographs that are submitted as part of the verification of the implementation of measures.Legal basis for processing (contractual and legitimate interests): to confirm to funders that implementation of contract agreements has been conducted as expected, and to approve funding disbursements to farmers.
  • Data relating to the outcomes achieved on your farm as a result of measures funded by LENs and if applicable other agri-environmental schemes. Your outcomes will be reported annually and will be combined with those of other participating farms in LENs and reported to funders in such a way that they cannot be traced back to individual farm businesses, with the exception of some publicly funded measures (see details above).Legal basis for processing (contractual, legal and legitimate interests): to fulfil contractual obligations to funders to report sustainability outcomes pertaining to LENs measures.

Under the terms of LENs agreements, you grant to the Funders the ability to account for and report on any Outcomes measured through the LENs MRV process, namely quantified emissions reductions, carbon removals, assessment of regenerative agriculture practices, water and biodiversity assessments.

You will be notified of any changes to the purpose for which the data is used.

The use in external publicity materials or reports provided to funders of photographs of you or your farm and of feedback you have given about LENs is not covered by this policy and will be agreed with you separately as required.

How your data will not be used

For the avoidance of doubt, LENs will never sell your personal information or data. No personal information will be transferred to organisations that are not part of LENs and that do not require the information solely for the purposes of implementing LENs.

In addition, your data will not, and cannot, be used to generate carbon credits. Carbon credits are not part of LENs. If farmers wish to trade carbon in future, they are free to do so, but this would have to be separate from their LENs agreement and any LENs funded measures that they implement.

How long your data is retained

For audit purposes, LENs is required to retain the personal information of LENs partners for a minimum of seven years after the end of the agreement to which the information pertains. After this time, it will then be deleted from LENs systems, provided the information does not relate to a later agreement that is either still ongoing or has been over for fewer than seven years. Farm businesses should review the privacy policies of third parties pertaining to data retention. Third party providers are not permitted to store LENs data past the end dated agreement with 3Keel Group Limited unless otherwise agreed with a farm business’ consent.

How LENs stores your data

LENs data, including your personal information, is stored by 3Keel and/or other LENs delivery partners as referenced in your project agreements in secure, cloud-based servers that are only accessible to LENs staff and LENs delivery partners.

LENs data, including your personal information, may also be stored by third party providers. Where this is the case, you will be asked to agree separately to the third party’s privacy policy.

Your data protection rights

Under UK and European data protection laws, you have rights including:

  • Your right to be informed about how your personal data is used – you have the right to know how your data is being used, for what purpose and by whom;
  • Your right of access – you have the right to ask for copies of your personal information that is held by LENs;
  • Your right to rectification – you have the right to ask LENs to correct personal information you think is inaccurate or incomplete;
  • Your right to erasure – in certain circumstances you have the right to ask LENs to erase the personal information that it holds about you;
  • Your right to restriction of processing – in certain circumstances you have the right to ask LENs to restrict the processing of your personal information;
  • Your right to object to processing – in certain circumstances you have the right to object to the processing of your personal information by LENs;
  • Your right to data portability – in certain circumstances you have the right to ask

LENs to transfer the personal information you provided to another organisation, or to you.

You are not required to pay any charge for exercising your data protection rights. If you make a request, LENs has one month to respond to you.

Please contact LENs at mrv@3keel.com if you wish to make a request regarding your data.

How to make a complaint

If you have any concerns about how LENs uses your personal information, please contact mrv@3keel.com

We take any concerns raised seriously and will investigate and respond to concerns raised.  Please allow up to 30 days for our team to review and respond.

If you are unhappy with how LENs has used your data, you also have the right to register a complaint with the UK Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

or in the EU, the European Data Protection Board (EDPB), European Commission, and Member State data protection authorities:

Postal address: Rue Wiertz 60, B-1047, Brussels
Office address: Rue Montoyer 30, B-1000, Brussels
EDPB website: https://www.edpb.europa.eu/edpb_en