We’ve also taken steps to improve our other internal controls we provide to safeguard your data and protect your privacy.
1. What information will we use?
By coming to ACD and asking for assistance, help, to maintain your independence, we usually need to ask personal details about you so that we may tailor our advice to your circumstances.
2. How will your information be used?
ACD and other organisations with whom we work or partner from time to time (as described in more detail in the “Who will we share your information with?” section below), may use your information to:
- Operate the ACD Information & Advice and other services and report anonymised data to funders
- Analyse how the service is being used, client satisfaction and our marketing channels such as our website
- Assess the effectiveness of our marketing activities
- Better understand our clients such that we can continue to meet their needs.
3. We collect and use your information in the following situations:
- Where our use of your information is necessary for us to provide the assistance that you have requested from us
- Where we believe that it is necessary to use your information to comply with legal obligations to which we are subject; and
- Where we have your consent, we will rely on your consent to:
i. Collect technical information such as data;
ii. Use your information for fundraising and marketing to you by telephone, letter, email, and other methods of electronic communication from time to time in accordance with your data choices.
Where we rely on consent to use your information, you have the right to freely withdraw that consent at any time. Please see the “Your choices and rights” section of this policy for more details.
4. The period for which we will keep your data.
We will keep your information for as long as is necessary for us to fulfil the purpose that we describe in this policy. As a rule, however, we will keep:
- The information that you provide when you first, or subsequently, contact ACD together with any updates you make to that information, for the duration of the ACD Information & Advice and other ACD services;
- The information that we collect about you and your interaction with the services for the duration of your interaction with the services, or in some cases less time, based on the reason for holding such information and whether such information remains current.
If you do not contact or interact with ACD for a period of 36 months, ACD may deem you to be inactive. Your information will then be kept and securely stored anonymously for a further period of 24 months after which you are deemed to be inactive, following which we will endeavour to ensure that your personal data is no longer retained.
5. Who will we share your information with?
We may share your information within the Age Cymru or Age UK partnerships and with statutory and appropriate third sector organisations supporting the ACD Information & Advice Service and the other products and services it provides. We may also share your information with:
- Other organisations and service providers that we work with or partner from time to time.
- Our professional advisors.
- Any law enforcement agency, court, regulator, Government authority or other third party where we believe this is necessary to comply with or regulatory obligations or otherwise to protect our rights or the rights of any third party; and
- Any third party to which we transfer all or substantially all our assets and business. Should such a transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your information uses it in a manner that is consistent with this policy.
We promise that we will never share your details with anyone else.
6. Transferring your information internationally.
In normal circumstances your information will not be transferred internationally. However, should we, for operational purposes, decide to utilise overseas contact centres, or out source some of our IT services overseas the countries to which we transfer information should be party to the Privacy Shield Framework.
We will also put in place appropriate safeguards to protect your information, or otherwise ensure that we can transfer your information in a way that complies with data protection law. In some circumstances we might ask for your complicit consent to make the transfer of your information.
Where we put in place appropriate safeguards to protect information which we transfer, the safeguards may include additional legal agreements to protect your information.
7. Your choices and rights
You have several rights in relation to your information and can make a number of choices about how we collect and use it. For example, you can decide not to receive fundraising and marketing material from us and to object to some of the ways that we use your information.
Note that some of the choices or changes you make may impact our ability to maintain our assistance or provide you with tailored advice and your client record may need to be deleted. We will notify you if any such action is necessary.
You can contact us using the details below to:
- Freely request access to your information – which will be provided within one-month subject to verifying your identity.
- Ask that we update, complete or correct your information.
- Ask that we erase or restrict our use of your information?
- Request that we provide your information to you in a commonly used electronic format and to have that information transmitted directly to another organisation (this is known as the right to ‘data portability’); and/or
- Object to our, or other organisation supporting the service, using your information in certain circumstances.
8. Information Security
ACD works hard to keep your data safe. We use an appropriate combination of technical and organisational measures to ensure, as far as reasonably possible, the confidentiality, integrity and availability of your information at all times. If you have a security-related concern, please contact us using the contact details shown below.
We work hard to ensure that your personal information is treated safely and securely. If you are concerned about how your information is used, please contact us at:
Age Cymru Dyfed
27 Pier Street
Alternatively, you have a right to complain to the Information Commissioner’s Office.
11. Who we are
We are Age Cymru Dyfed a registered charity (Number 1155813). Our registered office is as shown in section 7 above. Get in touch by contacting the Data Protection Officer in writing at the above address to raise any questions or concerns.
We protect your information; our charity depends on it.
Effective 25 May 2018