Age Cymru understands that your privacy is important, and we care about how personal data is used. We respect and value the privacy of everyone who comes into contact with Age Cymru and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and the rights of all individuals' rights under the law.
This policy applies to individuals whose personal data is processed by Age Cymru, including those who use our website, use our services or volunteer with us. This policy does not apply to employees of Age Cymru and the personal data that we collect and use in the course of an employees employment. If you are an employee of Age Cymru please refer to the Intranet for the relevant privacy information.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Age Cymru, a registered charity in England and Wales and a company limited by guarantee. For more information on Age Cymru please see section 2 below.|
|Our data protection officer||Amanda O’Shea. Amanda’s email address is firstname.lastname@example.org|
|Personal data||Any information relating to an identified or identifiable individual.|
|Special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, sex life or sexual orientation.|
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, sex life or sexual orientation.
Age Cymru is the national charity for older people in Wales. We are a registered charity and a company limited by guarantee.
Registered Office: Ground Floor, Mariners House, Trident Court, East Moors Road, Cardiff CF24 5TD.
Charity Number: 1128436
Company Number: 0683728
We collect data from those individuals who use our website, who use our services, who volunteer with us or who provide services or goods to us. This includes:
We request individuals aged 16 or under‚ obtain the permission of their parent/guardian's whenever providing us with personal information.
The personal data we collect about you depends on the reason that you are interacting with us. We will typically collect and use the following personal data about you:
When you use our services:
Where you volunteer with us, or are one of our Trustees (or apply to be a volunteer or Trustee):
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you or otherwise being able to develop your relationship with Age Cymru.
We collect most of this personal data directly from you—in person, by telephone, text or email, surveys or forms you complete and/or via our website.
However, we may also collect information:
Under data protection law, we can only use your personal data if we have a proper reason, eg:
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
What we use your personal data for
Providing our services to you
Keeping you up to date with information about our services, including notifying you of changes to planned services
Depending on the nature of the services we are providing, our lawful grounds for using your personal data will be:
- To perform our contract with you or to take steps at your request before entering into a contract – this applies where we have entered into a contract with you in respect of the services;
- In our legitimate interests of carrying out charitable activities and providing services as a charity - this will apply where we have not entered into a contract with you.
|Process donations you make to us or funds you raise for us||In our legitimate interests of carrying out charitable activities and providing services as a charity.|
|Sharing information with emergency services where it is necessary to protect life or health or preventing and detecting/reporting safeguarding issues and making necessary reports||
- Where is it necessary to protect life or health or to take steps in respect of safeguarding issue which requires us to share the personal data;
- To comply with a statutory obligation that we are subject to.
|Conducting checks to identify our Volunteers (including Trustees) and verify their identity||Depending on the circumstances.|
|Other activities necessary to comply with legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by the Charity Commission||- to comply with our legal and regulatory obligations;
- for our legitimate interests of running a charity.
|Gathering and providing information required by or relating to audits or enquiries and to comply with the information requirement of those who provide us with Grant Funding||To comply with our legal and regulatory obligations.|
|Ensuring business policies are adhered to, eg policies covering security and internet use||For our legitimate interests - to make sure we are following our own internal procedures so we can deliver the best service to you.|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests - to be as efficient as we can so we can deliver the best service to you at the best price.|
|Statistical analysis to help us manage our business, eg in relation to financial management, understanding those who are using our services and the reach of the charity||For our legitimate interests or providing charitable services to older people in Wales.|
|Preventing unauthorised access and modifications to systems||
Depending on the circumstances:
|Protecting the security of systems and data used to provide our services||
To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
|Statutory returns||To comply with our legal and regulatory obligations.|
|Ensuring safe working practices||
Depending on the circumstances:
|Marketing our services and those of selected third parties to:
—existing and former customers;
—individuals who have previously expressed an interest in our services.
|For our legitimate interests, ie to promote our business to existing and former customers.|
|External audits and quality checks, eg for ISO or Investors in People accreditation, Investing in Volunteers, Advocacy Quality Mark, Charity Quality Standard and IAQP and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above.||
Depending on the circumstances:
- for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards;
As set out in section 4 above, we may sometimes collect data from you that is special category data to which additional protections apply under data protection law. Where we process special category data, we will also ensure we are permitted to do so under data protection laws, meaning that we will either:
We may on occasion share basic demographic and service information with Age UK the national charity so they can help us monitor and ultimately improve the services we provide. The information we share will not include your name or your contact details, unless you give us your consent to do so for a specific purpose, such as sharing your story. When we do share this information, we do so under the lawful basis of legitimate interest.
Personal data may be held at our offices and those of our service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. Further details on this are available in our Data Retention Policy.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|Erasure (also known as the right to be forgotten)||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
|The right to withdraw consents||
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time.
You may withdraw consents by contacting.
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you'd like to exercise any of those rights, please:
Write to us at: Age Cymru, Mariners House, Trident Court, East Moors Road, Cardiff CF24 5TD; or
Email us: email@example.com
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Postal address: Age Cymru, Mariners House, Trident Court, East Moors Road, Cardiff CF24 5TD
Email address: firstname.lastname@example.org
Our Data Protection Officer: email@example.com