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Hi,
I run a "club" for oil central heating users. Basically we group our orders so the we all get a lower price on our heating oil. I don't charge a fee or get money back from the oil companies. How do I convince the ICO that I am exempt for registration? ICO chat line says just because I don't charge any fees or take commission does not mean I'm a not-for-profit (and yes I agree that is stupid, if it walks like a duck.....).
I should perhaps explain I run this from a website. Users register and put on their name, address, phone number and any special instructions for the oil supplier (like oil tank is behind the blue door). These details are only visible to the user and me, not the public. When a group buy is in progress users can place an order for oil. When the window closes the web site totals the amount needed and asks all the local oil companies, who have opted in, to quote (i.e. X litres for Y drops). The cheapest gets the order. I email the chosen supplier a list of all those who ordered oil, name, address, phone number, special instructions and amount of oil wanted. Obviously this data has to be shared in order for the oil to be delivered and paid for. I do not take payment, the oil supplier does that direct with the user.
The web site has pages for T&Cs, Disclaimer, and Privacy. The states name, address etc. is used to check member is local and for sharing with oil supplier. Placing an order for oil is agreeing for this to be shared (I don't have a tick box, "I agree to my data being shared", on the oil order form, do I need one?). Users can opt out and have their data, their account, deleted.
Anything else I need on the web site? And primary question how do I show I am not for profit if not charging a fee does not seem to be enough?
Thanks.
I run a "club" for oil central heating users. Basically we group our orders so the we all get a lower price on our heating oil. I don't charge a fee or get money back from the oil companies. How do I convince the ICO that I am exempt for registration? ICO chat line says just because I don't charge any fees or take commission does not mean I'm a not-for-profit (and yes I agree that is stupid, if it walks like a duck.....).
I should perhaps explain I run this from a website. Users register and put on their name, address, phone number and any special instructions for the oil supplier (like oil tank is behind the blue door). These details are only visible to the user and me, not the public. When a group buy is in progress users can place an order for oil. When the window closes the web site totals the amount needed and asks all the local oil companies, who have opted in, to quote (i.e. X litres for Y drops). The cheapest gets the order. I email the chosen supplier a list of all those who ordered oil, name, address, phone number, special instructions and amount of oil wanted. Obviously this data has to be shared in order for the oil to be delivered and paid for. I do not take payment, the oil supplier does that direct with the user.
The web site has pages for T&Cs, Disclaimer, and Privacy. The states name, address etc. is used to check member is local and for sharing with oil supplier. Placing an order for oil is agreeing for this to be shared (I don't have a tick box, "I agree to my data being shared", on the oil order form, do I need one?). Users can opt out and have their data, their account, deleted.
Anything else I need on the web site? And primary question how do I show I am not for profit if not charging a fee does not seem to be enough?
Thanks.
