We are committed to protecting your personal information and being transparent about what we do with it, no matter how you interact with us. That’s whether you want to work, volunteer or advocate for us, donate, buy goods or use our services, want information, training or want to learn more about what we do.
We are committed to using your personal information in accordance with our responsibilities. We are required to provide you with the information in this Privacy Notice under applicable law which includes:
The European Union General Data Protection Regulation (Regulation (EU) 2016/679) (‘GDPR’) and the Data Protection Act 2018 (‘DPA’) referred to as the ‘data protection legislation’
the Privacy and Electronic Communications Regulation (2003)
We won’t do anything with your information you wouldn’t reasonably expect.
We are a data controller. This means we are responsible for deciding how we hold and use personal information about you. This notice explains to you what decisions we have taken in relation to that information.
This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).
We encourage you to read this notice carefully, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. It applies to all employees, workers and contractors, volunteers, supporters and clients/members.
Our appointed Information Security Lead is the Chief Executive and any queries in relation to how we hold and use your personal information should be directed to the CEO.
As a data controller, we are responsible for deciding how we hold and use personal information about you. This notice explains to you what decisions we have taken in relation to that information.
Data protection principles
In collecting and processing your personal information, we will comply with the data protection law in force at the time. This requires that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
We will collect, store, and use a variety of categories of personal information about you. Those categories are detailed in the Information Schedule attached to this notice.
We may also collect, store and use “special categories” of more sensitive personal information, which are also detailed in the Information Schedule attached to this notice.
How is your personal information collected?
We collect personal information about our employees, workers and contractors, volunteers and clients through the application and recruitment process, requests for services/assistance and telephone enquiries, either directly from an individual or sometimes from a third party organisation, employment agency or background check provider. These will be listed in the relevant Information Schedules.
We will collect additional personal information in the course of job-related or service provision activities throughout the period of you working/volunteering/accessing our services with us.
How we will use information about you
We will only use your personal information when the law allows us to and as detailed in the Information Schedule attached to this notice.
Situations in which we will use your personal information
There are a variety of situations in which we will use the information we collect about you and these are detailed in the Information Schedule attached to this notice. The information in the Schedule includes the use we make of particularly sensitive personal information, such as information about your physical or mental health and criminal records information.
Where we use your personal information to pursue the legitimate interests of the business, we will only do so provided your interests and fundamental rights do not override those interests.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers, volunteers and clients).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Do we need your consent to use particularly sensitive information?
We do not need your consent if we use your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment/care law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Why might you share my personal information with third parties?
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
All our third-party service providers [and other entities in the group] are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Any third parties with whom we might share your personal information and the basis on which we do so are detailed in the Information Schedule attached to this notice.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are set out in the Information Schedule attached to this notice.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, the law grants you specific rights. These are summarised below. Please note that your rights may be limited and subject to restrictions in certain situations:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact, in writing, the Information Security Lead – CEO, Age UK Enfield, John Jackson Library, 35 Agricola Place, Bush Hill Park, EN1 1DW or email email@example.com.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In any circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Information Security Lead– CEO, Age UK Enfield John Jackson Library, 35 Agricola Place, Bush Hill Park, EN1 1DW or email firstname.lastname@example.org
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Complaints to the ICO
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Call ICO on 0303 123 1113
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the CEO, Age UK Enfield, John Jackson Library, 35 Agricola Place, Bush Hill Park, EN1 1DW or email email@example.com