Privacy & Cookies Policy – updated 14/05/2018
We are committed to safeguarding the privacy of personal data provided to us via our website visitors; service users; volunteers and staff, in this policy we explain how we collect, store and use your personal data. This policy sets out our commitment to you, in compliance with and beyond the General Data Protection Regulation (commonly known as GDPR).
- How we use your personal data
1.1 In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
1.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
1.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
1.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
1.5 We may process your personal data that is provided in the course of the use of our services (“service data”). The source of the service data is you. The service data may be processed for the purposes of operating our website, providing you with any services you may request from us, operating our website, maintaining back-ups of our databases and communicating with you about the services requested. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
1.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent.
1.7 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
1.8 We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis is the performance of a contract (the transaction) between you and us.
1.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
1.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
1.11 In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Disclosure of your information
We may share your personal data with other agencies in order to run our organisation and also provide the requested service support to you. This may include other Data Processors who may provide support to you on our behalf:
- Staff – Payroll, Pension Providers, Tax Authorities, HR Advisors, DBS (England & Wales) other payroll related providers that you may have opted into.
- Volunteers – DBS (England & Wales), Health providers in the case of medical checks.
- Clients/Service Users – Care Agency providers, Other wellbeing providers, Therapists.
- Donors – Financial platform providers who process transactions on our behalf.
- Trustees – DBS (England & Wales) and the appropriate Governance regulators such as Charity Commission and Companies House.
We provide this information to them in order to allow them to follow up with you and offer to provide their services. We recommend you review information about the providers’ privacy policies and practices.
2.1 Job applications and recruitment relating to our website is handled by our Recruitment platform provider listed below. We recommend you review information about the providers’ privacy policies and practices at [URLs].
2.2 Financial transactions relating to our website and services are handled by the Payment services providers (listed below). We will share transaction data with these payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. We recommend you review information about these payment services providers’ privacy policies and practices at [URLs].
– Stripe (URL https://stripe.com/gb/privacy)
– GoCardless (URL https://gocardless.com/legal/privacy/)
2.3 Your data may also be available to our website provider to enable us and them to carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:
- Your data will be made available to our website provider
- The data that may be available to them include any of the data we collect as described in section 1 above.
- Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
- They will store your data for a maximum of 7 years.
2.4 In addition to the specific disclosures of personal data set out in this Section, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Storage, Retaining and deleting personal data
3.1 Storage of Personal Data may be held on paper files and/or in electronic records. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
The destruction and deletion of personal data is in line with our organisations Retention Policy. The duration for which we retain your personal data will differ depending on the type and the reason why it was collected, this can be varied for each of our different service activities (ie: Children & Young People, Families, Adults)
3.2 Notwithstanding 3.1, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.3 Where we use third party processors (to process personal data on our behalf) we carry out due diligence to ensure they have appropriate organisational and technical measures in place to safeguard personal data, furthermore within their Contractual Agreements with us they adopt our Data Protection Policy, Confidentiality practices and Retention Policy.
3.4 Where we use Host Cloud Platform Providers (such as Cloud Database Software providers) we carry out due diligence to ensure they have appropriate organisational and technical measures in place to safeguard personal data. Where possible we try to choose providers that have data centres located within the European Economic Area (EEA).
- Amendments to this policy
We may update this policy from time to time by publishing a new version on our website. You should check this page to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email.
- Your rights
(a) the right to access; You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
(b) the right to rectification; You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. Please let us know if the personal information that we hold about you needs to be corrected or updated.
(c) the right to erasure; In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
(d) the right to restrict processing; In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
(e) the right to object to processing; You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
(f) the right to data portability; To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
(g) the right to complain to a supervisory authority; and if you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
(h) the right to withdraw consent; To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section by emailing [email protected]
- Third party websites
- Personal data of children
7.1 Our website and services are targeted at all ages.
7.2 If we have reason to believe that we have received personal data of a person under the age of 13 years via our website activities, we will delete that personal data. For all of our services that support children, Consent from a Parent/Guardian will be obtained if the child is under the age of 13 years.
- About cookies & IP Addresses
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies used by our service providers
9.2 The search facility on our website is created and hosted by our website platform provider Raising IT. https://www.raisingit.com/privacy-and-cookies-policy
- Managing cookies
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
- Data protection registration
11.1 We are registered as a data controller with the UK Information Commissioner’s Office, Registration Number: Z1197200. We have not appointed a Data Protection Officer as we are not required to do so however our Information Governance Lead has overall responsibility for data protection compliance in our organisation.
- Questions about this policy
12.1 If you have any queries or complaint you can contact our Information Governance Lead: Manjula Patel (as below)
(a) by post; Murray Hall Community Trust, The Bridge, St Marks Road, Tipton, West Midlands, DY4 0SL.
(b) using our website contact form.
(c) by telephone 01902 826513 via PA to Information Governance Lead who is: Lesley Smith
(d) by email firstname.lastname@example.org
If you have a complaint about us, or the treatment of your data, you can contact the Information Commissioners Office (ICO). The ICO are the UK’s independent authority set up to uphold information rights in the public interest, promoting openness and data privacy for individuals. You can contact them at www.ico.org.uk