We understand the importance of maintaining your privacy, keeping your personal information secure and complying with data protection laws.
We may collect information from you about other people, for example family members. If you give us information about another person, it is your responsibility to ensure and confirm that:
- you have permission from the individual to provide that personal information to us and for us to use it, as set out in this privacy notice.
Section 1: Why we need and how we use your personal information
We only collect and store your information where we have a lawful grounds and legitimate reasons to do so. We collect, use and store your personal information in order to allow you to access our services. We record basic information about who you are, where you live, why you are accessing a St Pauls Community Development Trust service and about the work we are doing with you.
The use of your data is essential for some of our services to enter into a contract and for it to operate, for example if you access any one of our nursery’s, out of school provision, or other services where a contract is required.
We may monitor emails and other communications with you and when you contact us, we will keep a record of that correspondence and any information provided to us in that or subsequent communications.
Under data protection laws, for each purpose we must be able to rely on a legal ground to justify why we are using your (non-sensitive) personal information. The legal grounds that we may rely on are:
|For Processing (non-sensitive) personal information|
|Consent of the individual||You have provided informed and unambiguous consent for specific data processing purposes|
|Performance of our contract with you||Processing is necessary for the performance of a contract that you are party to or in order to take steps at your request prior to entering into a contract|
|Compliance with a legal obligation||Processing is necessary for compliance with a legal obligation to which we are subject|
|To protect your vital interests or those of another person||Processing is necessary where we believe you or another person is at risk|
|For our legitimate interests where these do not cause you undue harm|
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information.
Our main legitimate interests for using your personal information are:
· to enable us to provide and deliver services
· to promote our work and services
· for the purposes of fundraising
When we use your sensitive personal information (for example, details about your health) we must be able to rely on an additional legal ground. The additional legal grounds that we may rely on in these instances are:
|For Processing sensitive personal information|
|Your explicit consent|
You have given your explicit consent to the processing of your sensitive personal information for one or specified purposes.
You may withdraw your consent at any time by contacting us. if you do so, you may not be able to receive the benefit of some of our services where in order to provide them, we rely on your explicit consent to process your sensitive personal information
|Necessary to protect the vital interests of the data subject or another person||Processing is necessary where we believe you or another person is at risk|
|Where it is necessary to consider your medical condition when providing services||It may be necessary to process sensitive data where we need understand more about your health in order to provide our services|
|For legal claims||Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity|
|You have made this information public||You have made your sensitive personal information manifestly public.|
Section 2: Nature of personal information
Personal information is any information that may identify a living individual. We collect personal information such as name, email addresses, date of birth, financial details, IP addresses, depending on the nature of the service we are providing.
We may collect, use and store sensitive personal information so called special categories of data such physical or mental conditions, racial or ethnic origins, (for example if we are required to collect this information as part of our recruiting process) and your religious beliefs as necessary in relation to providing our services to you. This information may be shared with other agencies and third party service providers. Where necessary we shall obtain your consent to the processing of such information.
We may collect information from:
- Present, past and prospective clients
- Employees from other agencies we work with when delivering services (for example referrals)
- Users of the St Pauls Community Development Trust website
We might collect your information if:
- you ask to be part of any fundraising or marketing campaign
- you register (or someone on your behalf registers you) to attend one our events or training courses
- you apply for an advertised employed role
- you approach St Pauls Community Development in relation to any of the services it offers
- you use our website (for more information please see section12 on Cookies)
Where you have registered for an event or training hosted by us we will use your personal information to:
- process bookings
- send you the relevant information relating to the event
- include your name on delegate lists and registers which are available to other delegates (unless you have indicated to us that you do not want your details to appear on such lists) and third parties such as event organisers
- to produce name badges
- for security, catering and to make other necessary purposes related to running of our events
Section 3: How we collect your personal information
We may collect your personal non-sensitive personal information and sensitive personal information:
- face to face (directly form you)
- by telephone
- by email
- via our website (including through cookies – please see section 12 on Cookies)
- via forms including payment and direct debits
- via our management information systems
- from partner and local authority agencies with whom we work.
Section 4: Sharing Information
- Specific organisations where we are in a partnership to deliver contracted services
- IT Service Providers
- Professionals who are engaged to facilitate the delivery of services
- Local Authorities
- Regulators and official bodies
We may also disclose your personal information to other third parties where:
- the disclosure is required by law or by a regulator who has authority over us or you, such as where there is a court order or statutory obligation.
Section 5: Fundraising and promoting our interests
We are committed to only sending you communications relating to fundraising and the promotion of our interests if you have expressed an interest in receiving. These may include:
- subscribing to our social media feeds (Twitter and Facebook)
- news of crowd funding campaigns
- annual impact reports
- communications from third party providers
- newsletters and updates
You may unsubscribe from any of these communications at any time by contacting us.
Section 6: How we protect your personal information
We are committed to keeping your personal information secure. We keep your personal information on secure servers and have appropriate measures in place at our physical facilities. Where we have contracted IT services out we make every effort to ensure that their systems and facilities confirm to the highest security standards and are able to provide the necessary documentation to show they are compliant with data protection law with regards to data security
Whilst we strive to protect your information, due to the nature of the internet we cannot guarantee the security of any information you transmit to us. With this in mind, any transmission is at your own risk and we urge you to take every precaution to protect your personal information while you are online.
Section 7: How long can we keep your personal information?
Section 8: Transfer of data outside the EEA
We will not transfer your data outside the UK and EEA as we are unable to guarantee that such transfers will be subject to same levels of protection for the data as within the EEA under data protection law.
Section 9 Your Rights:
The right to access your personal information
Subject to any relevant exemptions, you are entitled to see a copy of the personal information we hold about you and to request details of how we use your personal information including any disclosures made. To exercise your rights to access your personal information, please contact us. There will not usually be a charge for dealing with these requests.
Your personal information be provided to you in writing, or where you have made the request by electronic means, your personal information will be provided to you by electronics means, where possible.
The right to rectification
We take reasonable steps to ensure that the personal information we hold about your is reliable, accurate and as complete as necessary for its intended use; but you are entitled to ask us to update or amend any inaccuracies in the personal information that we hold about you. To request us to update or amend any personal information we hold about you, please contact us.
The right to object to marketing
As set out in section 5, you are entitled to object to receiving marketing material from us at any time. You can exercise this right by contacting us or click ‘unsubscribe’ at the bottom of any marketing email.
Under certain conditions, you may also have the right to require us to:
- delete any personal information where no longer have legal grounds to retain it
- where processing is based on consent, to withdraw your consent so that we can stop that particular processing
- object to any processing based on the legal ground of legitimate interest unless our reason for undertaking that processing outweighs any prejudice to your data protection rights
- restrict how we use your personal information whilst a complaint is being investigated.
If you contact us to exercise any of these rights we will confirm your right to do so and respond in most cases within 30 days.
Section 10: Your right to complain to the Information Commissioner’s Office
If you are not satisfied with our use of your personal information, with our response to any exercise of your rights set out in section 9 or if you believe us to be in breach of our data protection obligations, you have the right to complain to the Information Commissioners Office at:
The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 SAF. Telephone 0303 123 1113 (local rate) or 01625 545 745 (national rate number).
Section 11: Other websites
Our website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.
Section 12: Cookies
The cookies we make us of on the St. Paul’s Community Development Trust website are:
|https://analytics.google.com||Anonymised tracking data to Google Analytics.||14 Months|
|https://platform.twitter.com||Records interaction with Twitter||30 days|
|Facebook Cookies||Records interaction with Facebook||30 Days|
For further information please visit www.allaboutcookies.org
Section 13: How to contact us
You can contact us by email at firstname.lastname@example.org or by writing to us at St. Paul’s Community Development Trust, 73 Hertford St, Birmingham B12 8NJ.
We may update this policy from time to time to keep it up to date or comply with legal requirements. The latest version of this policy can be found at www.stpaulstrust.org.uk.