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Age Uk East London Privacy Policy

 1. Introduction

 2. What is Personal Data?

 3. What are my rights?

 4. Who is responsible?

 5. What Personal Data do you collect and how?

 6. How do you use my Personal Data?

 7. How long will you keep my Personal Data?

 8. How and where do you store or transfer my Personal Data?

 9. Do you share my personal data? 

 10. How can I access my Personal Data?

 11. How do I contact you?

 12. Implementation and review

1. Introduction

  • This is a Policy of Age UK East London (“the Company”), registered in England as a private Limited Company by guarantee without share capital use of 'Limited' exemption under No. 07687015 and as Charity No. 1144535 (“the Company”).
  • This Policy is part of the Company's Data Security and Protection Policy Framework and should be interpreted in conjunction with the other policies in the Framework.
  • This document sets out sets out the Company’s policy relating to the privacy of your Personal Data and serves as a Notice to inform you, as Data Subjects, of your rights and how we process your Personal Data.
  • The Company understands that your privacy is important to you and that you care about how your Personal Data is used. We respect and value the privacy of all of our service users, employees, donors, volunteers, business partners and other Data Subjects
  • We will only collect and use Personal Data in ways that are described here, and in ways that are consistent with our obligations and your rights under the law.

2. What is Personal Data?

  • Personal Data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
  • Personal Data is, in simpler terms, any information about you that enables you to be identified. Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
  • The Personal Data that we use and how we use it is set out in the sections below.

3. What are my rights?

  • Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
    1. The right to be informed about our collection and use of your Personal Data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the contact details in Section 11.
    2. The right to access the Personal Data we hold about you. Section 10 has more details about Data Subject Access Requests.
      1. The right to have your Personal Data rectified if any of your Personal Data held by us is inaccurate or incomplete. Please contact us using the contact details in Section 11 to find out more.
      2. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your Personal Data that we hold. Please contact us using the contact details in Section 11 to find out more.
      3. The right to restrict (i.e. prevent) the processing of your Personal Data.
      4. The right to object to us using your Personal Data for a particular purpose or purposes.
      5. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your Personal Data, you are free to withdraw that consent at any time.
      6. The right to data portability. This means that, if you have provided Personal Data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that Personal Data to re-use with another service or business in many cases.
      7. Rights relating to automated decision-making and profiling. Note: We do not use your Personal Data in this way. 
      8. For more information about our use of your Personal Data or exercising your rights as outlined above, please contact us using the contact details provided in Section 11. 
      9. It is important that your Personal Data is kept accurate and up-to-date. If any of the Personal Data we hold about you changes, please keep us informed as long as we have that data. 
      10. Further information about your rights can also be obtained from the Information Commissioner’s Office (ICO website: https:/ico.org.uk) or your local Citizens Advice Bureau. 
      11. If you have any cause for complaint about our use of your Personal Data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the contact details in Section 11.

4. Who is responsible?

  • The Company’s Senior Information Risk Officer (SIRO) is responsible for:
    1. The implementation of this Policy and related policies.
  • The Company’s Caldicott Guardian is responsible for:
    1. making sure that the Personal Data of our Service Users is used legally, ethically and appropriately, and that confidentiality is maintained.
  • The Company’s Data Protection Officer (DPO) is responsible for:
    1. providing advice and guidance to the Company on the interpretation of this Policy, handling Data Subject Access and Rights requests and data security and protection in general.
    2. reviewing this Policy and related procedures regularly to ensure that they comply with current data protection legislation and best practice.
  • All the above can be contacted using the contact details in Section 11 below.

5. What Personal Data do you collect and how?

5.1 We may collect and hold some or all of the personal and non-personal data set out in the table below depending on our relationship with you.

 

Personal Data collected

How we collect the data

Identity data including name, title, date of birth, gender, National Insurance Number

From data subjects e.g. past, present and prospective employees and volunteers

Contact data including address, email address, telephone numbers, relative and carer contact details

From the data subjects, relatives and carers, business contacts, employees and volunteers etc.

Business data including business name, job title, profession, payments, text, audio and video recordings of meetings and calls[1]

From data subjects e.g. past, present and prospective suppliers, business partners and customers

Financial data including bank details, donations

From data subjects

Human Resources data including qualifications, right to work documents, recruitment details, references, employment records, attendance, sickness and disciplinary records, payroll records, tax records, occupational health records, medical records, passport, driving licence and insurance details, criminal convictions and next of kin details, bank details, photographs, text, audio and video recordings of meetings and calls[2]

From data subjects, former employers, referees, medical and occupational health providers

Profile data including your stated preferences and opinions on our products and services etc.

From data subjects

[1] As a matter of good practice and transparency, our staff will always inform you in advance of recording a meeting or session and explain what the recording will be used for.

[2] As a matter of good practice and transparency, our staff will always inform you in advance of recording a meeting or session and explain what it will be used for. However, recordings of meetings relating to the employment of an individual member of staff will not normally be made.

6. How do you use my Personal Data?

  • Under the Data Protection Legislation, we must always have a lawful basis for using Personal Data. The following table describes how we may use your Personal Data, and our lawful bases for doing so:

 

What we do

Type(s) of data we use

Our lawful basis/bases

Administering our organisation

Financial, Human Resources

Legal obligation, contractual necessity, legitimate interests, consent

Purchasing and supplying  products and/or services

Contact data, business data and financial data

Contractual necessity

Managing payments for our products and/or services

Contact data, business data and financial data

Contractual necessity

Personalising and tailoring our products and/or services

Contact data, business data,  financial data and profile data

Contractual necessity, consent

Communicating with you

Contact data

Contractual necessity, consent

Supplying you with information by email and/or post that you have opted-in-to (you may opt-out at any time)

Contact data, profile data

Consent

 

  • With your permission and/or where permitted by law, we may also use your Personal Data for marketing purposes
    1. This may include contacting you by email and/or telephone and/or text message and/or post with information, news, on our activities and fundraising.
    2. You will not be sent any unlawful marketing or spam.
    3. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
    4. You will always have the opportunity to opt-out.
    5. We will always obtain your express opt-in consent before sharing your Personal Data with third parties for marketing purposes and you will be able to opt-out at any time.
  • We will only use your Personal Data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your Personal Data for that purpose. If we do use your Personal Data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the contact details in Section 11.
  • If we need to use your Personal Data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
  • In some circumstances, where permitted or required by law, we may process your Personal Data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How long will you keep my Personal Data?

  • We will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Your Personal Data will therefore be kept for the periods shown in the table below, or, where there is no fixed period, we show the factors used to determine how long it will be kept:

 

Type of data

How long we keep it

Identity data

7 years after departure of the staff member

Contact data

Depending on the nature of the relationship with contact involved e.g. staff, business contact

Business data

6 years from last date of contact or transaction

Financial data

7 years from the date of the transaction

Human Resources data

7 years after departure of the staff member

Profile data

6 years from last date of contact or transaction

8. How and where do you store or transfer my Personal Data?

  • We normally store and transfer Personal Data only within the UK.
  • If we decide to transfer data abroad it will only be to countries that are deemed to provide an adequate level of protection for Personal Data such as those within the European Economic Area.
  • For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.

9. Do you share my personal data?

  • We will not share any of your Personal Data with any third parties for any purposes, subject to the following exceptions.
  • If we sell, transfer, or merge parts of our organisation or assets, your Personal Data may be transferred to a third party. Any new owner of our organisation may continue to use your Personal Data in the same way(s) that we have used them, as specified in this Privacy Policy.
  • In some limited circumstances, we may be legally required to share certain Personal Data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
  • We may sometimes contract with the following third parties to supply products and/or services and act as Processors of Personal Data on our behalf.
  •  

    Recipient

    Activity, service or product

    Sector

    Location

    Dizions Ltd

    (Processor)

    Cloud-based charity Customer Relationship Management System

    IT System Provider

    UK

    Advantage Services (Europe) Ltd.

    (Processor)

    Supplier of Finance, Payroll and Human Resources Systems.

    IT System Provider

    UK

    SafetyNet IT Ltd

    (Processor)

    Technical Support for our Information Technology and Communications infrastructure

    IT Support Service Provider

    UK

     

    • If any of your Personal Data is shared with a third party, as described above, we will take steps to ensure that your Personal Data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
    • If any Personal Data is transferred outside of the UK, we will take suitable steps in order to ensure that your Personal Data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation

10. How can I access my Personal Data?

  • If you want to know what Personal Data we have about you, you can ask us for details and for a copy of it (where any such Personal Data is held). This is known as a Subject Access Request.
  • All Subject Access Requests should be made in writing and sent to the email or postal addresses shown in Section 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
  • There is not normally any charge for a Subject Access Request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
  • We will respond to your Subject Access Request as soon as possible and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How do I contact you?

To contact us about anything to do with your Personal Data and data protection, including to make a Subject Access Request, please use the following contact details, marked for the attention of  Data protection at:

 

Telephone

020 89817124

Email

dataprotection@ageukeastlondon.org.uk

Post

Data Protection

82 Russia Lane

Bethnal Green

London

E2 9LU

12. Implementation and review

  • This Policy shall be deemed effective as of 30th June 2021. No part of this document shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
  • We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects Personal Data protection.
  • Details of any changes will be made available on our website at https://ageukesatlondon.org.uk or by contacting us.
  • This document will be reviewed regularly and normally at least annually.
  • This document will be updated as necessary to reflect current best practice, official guidance, and in line with current legislation.
  • The latest version of this document will be made readily available to all relevant parties.

Latest update: 30/06/2021

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