Privacy Notice for Service Users
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our service users, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
This notice applies to current and former service users.
A) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of processing
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e) data is not kept for longer than is necessary for its given purpose
f) data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal data
B) TYPES OF DATA HELD
We keep several categories of personal data on our service users in order to carry out effective and efficient processes. We keep this data within our computer systems, for example, on our enquiries database.
Specifically, we hold the following types of data, as appropriate to your status:
a) personal details such as name, address, phone numbers
b) your photograph (if submitted, for example, to support campaigns or grant applications)
c) your gender, marital status, information of any disability you have or other medical information
d) information on your race and religion for equality monitoring purposes
e) for information gathered via the recruitment process, please see our Privacy Notice for Job Applicants.
C) COLLECTING YOUR DATA
You may provide data to us directly if you have an enquiry that you would like us to support you with.
Personal data is kept in files or within the Company’s IT systems.
D) LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively provide a service to you.
The information below categorises the types of data processing, appropriate to your status, we undertake and the lawful basis we rely on.
| Activity requiring your data
|
Lawful basis |
|
Carrying out the service that we have entered into with you e.g. using your name and |
Performance of the contract |
|
Making reasonable adjustments for disabled service users |
Legal obligation |
|
Maintaining comprehensive up to date records about you to ensure, amongst other things, |
Our legitimate interests |
|
Gaining expert medical opinion when making decisions about your eligibility for a |
Our legitimate interests |
|
Dealing with legal claims made against us |
Our legitimate interests |
| Preventing fraud
|
Our legitimate interests |
|
Ensuring our administrative and IT systems are secure and robust against unauthorised |
Our legitimate interests |
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to your:
a) health
b) sex life
c) sexual orientation
d) race
e) ethnic origin
f) political opinion
g) religion
h) trade union membership
i) genetic and biometric data.
We carry out processing activities using special category data:
a) for the purposes of equal opportunities monitoring
b) to determine reasonable adjustments
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
d) you have already made the data public.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for providing a service to you.
G) CRIMINAL CONVICTION DATA
We will only collect criminal conviction data where it is appropriate given the nature of your enquiry and where the law permits us. This data will usually be collected at the enquiry or application stage. We use criminal conviction data to determine your suitability, or your continued suitability for a role (for example, a volunteer position). We rely on the lawful basis of our legitimate interests to process this data.
H) WHO WE SHARE YOUR DATA WITH
Employees within our company who have responsibility for administration will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
We may share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
I) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
J) RETENTION PERIODS
We only keep your data for as long as we need it for, which will be at least for the provision of our service to you, though in some cases we will keep your data for a period after this service has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below:
Our retention periods are:
- VfL database: 7 years after file closure
- MailChimp email list: indefinitely/until self-unsubscription from email list
- Photographic/film consent forms: indefinitely
- Grant applications: 7 years after file closure
- Pen- and phone-pal applications: 2 years after removal from scheme listing
K) AUTOMATED DECISION MAKING
Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
L) SERVICE-USER RIGHTS
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you. More information on this can be found in our separate policy on Subject Access Requests;
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
More information can be found on each of these rights in our separate policy on service-user rights under GDPR.
M) CONSENT
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
N) MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
O) DATA PROTECTION COMPLIANCE
Our Data Protection Officer is: Amanda Woodvine. Click here to contact.