Privacy Notice Home-Start Mid & West Suffolk
At Home-Start Mid & West Suffolk, we are committed to protecting and respecting your privacy.
This Privacy Notice explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights and choices in relation to your information.
Any questions regarding this notice and our privacy practices should
be sent by email to office@homestartmidsuffolk.org.uk
or by writing to Angela Dennis, Business Manager, Home-Start Mid &
West Suffolk, 20 Broad Street, Eye IP23 7AF.
Alternatively, you can telephone 01379
678552
Who are we?
Home-Start Mid & West Suffolk is committed to protecting your personal information and to being transparent about what information we hold. Home-Start Mid & West Suffolk understands its obligations to you to help you understand how and why we process your personal data. We will only do so in accordance with all applicable UK data protection legislation, including the General Data Protection Regulation. In this notice "Home-Start", "we", "us" or "our" means:
Your Rights
Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that are likely to apply to you when we are processing your personal information we think apply:
Right of access
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply. If you want to access your information, please contact the address provided below, telephone or e-mail.
Right to have your inaccurate personal information corrected
You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us so we're working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email, telephone or post (see below).
Right to restrict use
You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we're not lawfully allowed to use it.
Right of erasure
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to by law. In many cases, we will anonymise that information, rather than delete it.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, for example, when you shop from our website, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object
You have the right to object to processing where we are using your personal information based on legitimate interests, (or for statistical/research purposes). In these circumstances we will consider your request against our legitimate reasons for continuing to process your information.
You have an absolute right to object to direct marketing. If you wish to opt-out of receiving marketing materials from us at any time, please contact the address below.
If you want to exercise any of the above rights, please contact us. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK's Information Commissioner's Office.
Keeping your information safe
When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it, such as Firewalls, anti-virus protection and encryption. Home-Start UK has developed a set of security policies that include device security, authentication requirements, acceptable usage of resources, data storage requirements. We undertake regular reviews of who has access to information that we hold to ensure that your info is only accessible by appropriately trained staff, volunteers and contractors.
Keeping your information up to date
We take reasonable steps to ensure your information is accurate and up to date. Where possible we use publicly available sources to identify deceased records or whether you have changed address. We really appreciate it if you let us know when your contact details change.
16 or Under
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under, please get your parent/guardian's permission beforehand whenever you provide us with personal information.
Vulnerable circumstances
We are committed to protecting vulnerable supporters, customers and volunteers, and appreciate that additional care may be needed when we use their personal information. In recognition of this, we observe good practice guidelines in our interactions with vulnerable people.
Changes to this notice
Any changes we may make to this notice in the future will be posted on this website so please check this page occasionally to ensure that you are happy with any changes. If we make any significant changes we will make this clear on this website.
Review of this Privacy notice
We keep this notice under regular review. This notice was last updated in July 2019.
For further information on each of these rights, including the circumstances in which they apply, visit the Information Commissioner's Office ("ICO") website at https://ico.org.uk/for-the-public
If you would like to exercise any of the rights, please email, call or write to us using the details in "How to contact us" below, let us have enough information to identify you, let us have proof of your identity and address, and let us know the information to which your request relates.
How to complain
Please report any complaint to the details set out in "How to contact us" below. We hope we can resolve any query or concern you raise about our use of your information. You also have the right to lodge a complaint with the ICO who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
How to contact us Please contact us if you have any questions about this Privacy Notice or the information we hold about you at Home-Start Mid & West Suffolk, 20 Broad Street, Eye IP23 7AF. Or email: office@homestartmidsuffolk.org.ukAlternatively, you can telephone 01379 678552
Our Data Protection Officer/Lead is: Carol Read, Chair of Trustees
APPENDICES
1. Human Resources (a) employees
How do we collect information from you?
The information we hold about you is primarily information you provided when applying for your job, supplemented by information generated in the course of your employment.
What type of information is collected from you?
Sensitive personal data held by Home-Start
We require to use some personal data that is considered under data protection law to be "special category data" for example, in relation to your health or ethnicity. We also use some other data which you may consider to be sensitive such as financial information. The information we hold is that which you provide to us (e.g. you may give us information when you applied for your role, or in response to staff surveys)
Records may contain:
How and why is your information used?
We are required to use your personal data for various legal and practical purposes for the administration of your contract of employment, without which we would be unable to employ you. Holding your personal data enables us to meet various administrative and legal obligations, (e.g. for tax purposes).
How long is your information kept for?
We will keep your personal data only as long as is necessary for the purpose(s) for which it was collected, and in accordance with our Data Protection Policy. Data will be securely destroyed when no longer required. Where you exercise your right to erasure, we will continue to maintain a core set of personal data (name, dates of employment K and date of birth) to ensure that we do not contact you or process your data again inadvertently in future, and to maintain your record for employment record purposes.
We reserve the right to judge what information we must continue to hold to be able to fulfil our contract with you.
Who has access to your information?
Personal data, including sensitive personal data, may be shared with members of staff, including trustees, who legitimately need the information to carry out their normal duties to support your time with us. We endeavour to ensure that special category personal data is only shared with colleagues with your explicit consent. However, circumstances may arise where this data is shared with colleagues without obtaining your consent. This will only occur in compliance with data protection law if it is necessary to protect your vital interests or the vital interests of another person, or for certain other reasons where it is not possible or appropriate to gain your consent such as disclosures to the police for prevention or detection of crime, or to meet statutory obligations. We may disclose certain personal data to third parties. These third parties, and the purpose for sharing the information, are set out below:Otherwise we do not share data with any third party, except as allowed for in other privacy notices or required by law. We do not sell your personal data to third parties under any circumstances or permit third parties to sell on the data we have shared with them.
Lawful Processing
The lawful basis for processing your personal data is necessary for the performance of your employment. There is a contractual requirement for you to provide much of the information detailed. Without this we are unable to fulfil our obligations which could result in termination of contract.
1. Human Resources (b) Trustees and volunteers
How do we collect information from you?
The information we hold about you is primarily information you provided when applying for a volunteer/trustee role. Further information may be recorded during your time with Home-Start
What type of information is collected from you?
Sensitive personal data held by HSUK
We require to use some personal data that is considered under data protection law to be "special category data" for example, in relation to your health or ethnicity. We also use some other data which you may consider to be sensitive such as financial information. The information we hold is that which you provide to us (e.g. you may give us information when you applied for your role, or in response to staff surveys)
Records may contain:
How and why is your information used?
We are required to use your personal data for various legal and practical purposes for the administration of your volunteering role.
How long is your information kept for?
We will keep your personal data only as long as is necessary for the purpose(s) for which it was collected, and in accordance with our Data Protection Policy. Data will be deleted when no longer required.
Who has access to your information?
Personal data, including sensitive personal data, may be shared with members of staff, including trustees, who legitimately need the information to carry out their normal duties to support your time with us. We endeavour to ensure that special category personal data is only shared with colleagues with your explicit consent. However, circumstances may arise where this data is shared with colleagues without obtaining your consent. This will only occur in compliance with data protection law if it is necessary to protect your vital interests or the vital interests of another person, or for certain other reasons where it is not possible or appropriate to gain your consent such as disclosures to the police for prevention or detection of crime, or to meet statutory obligations. We may disclose certain personal data to third parties. These third parties, and the purpose for sharing the information, are set out below:
Otherwise we do not share data with any third party, except as allowed for in other privacy notices or required by law. We do not sell your personal data to third parties under any circumstances or permit third parties to sell on the data we have shared with them.
Lawful Processing
The lawful basis for processing your personal data is necessary for the performance of your employment. There is a legal obligation for you to provide much of the information detailed. Without this we are unable to fulfil our obligations.
1. Human Resources (c) job candidates
How do we collect information from you?
As part of our candidate application and recruitment process we collect, process and store personal information about you. We process this information for a range of purposes relating to the recruitment process and this may include your application, assessment, pre-employment checks and your worker permissions.
What type of information is collected from you?
The following are some examples of the type of information we may process (there is a full list in the schedule at the end of this notice)
During the process we also capture some personal data that is considered under data protection law to be "special category data" about you, e.g., disability information. We do this in order to make reasonable adjustments to enable all candidates to apply for jobs with us, to be able to take online/telephone assessments or interviews, to attend interview/assessment centres and to ensure that we comply with regulatory obligations with regard to hiring.
How and why is your information used?
In order to manage your application, we need to process certain personal information about you. The purposes for this are set out below. We only process your information as necessary for the purposes of progressing your application or as required by law or regulatory requirements, so not all of the purposes set out below will apply to you all of the time.
How long is your information kept for?
For unsuccessful candidates personal information will be retained for 6 months following the recruitment process. For successful candidates all personal information collected as part of the recruitment process will be transferred to an employee personnel file and will be retained for six years following termination of employment
Who has access to your information?
The recruitment process will involve:
To enable these processes your personal information may be shared internally. The information shared is limited to what is required by each individual to perform their role in the recruitment process. Your personal information may be shared with the following:-
Our HR and recruitment systems are protected to ensure that unauthorised or unlawful processing of personal information, accidental loss or destruction of personal information does not occur. This is done in line with the Data Protection & Confidentiality policies.
Lawful Processing
Pre-employment checks
As part of the recruitment and selection process we will carry out pre-employment checks. These checks are only performed on candidates who have been selected for a role. Your consent will be requested before pre-employment checks are carried out.
Processing conditions
Our entitlement to process your personal information is governed under data protection law by a number of processing conditions. This means we may rely on more than one of these conditions in order to process elements of your personal information throughout the recruitment process.
Schedule 1 - Full list of information that we may process
*These categories of information might potentially include some special category personal information. Special category personal information is collected were we have a legal obligation to do so or if you choose to disclose this to us during the course of your relationship us.
1. Human Resources (d) referees
How do we collect information from you ?
Your personal details have been provided to us by another person (applicant) who has indicated you as a referee. We must have a legal basis for processing your personal data. We will only use your personal data in accordance with the terms of our privacy notice.
What type of information is collected from you?
How and why is your information used?
We will collect your personal data and process your personal data for the purpose of obtaining references for our applicant.
How long is your information kept for?
We will retain your personal data along with the applicant's data for as long as is necessary. Different laws require us to keep different data for different periods of time, which are detailed in Appendix below:
Where the applicant is unsuccessful
If the applicant is unsuccessful after you have provided a reference the data will be kept for 6 months. The electronic data will then be deleted and the paper data confidentially shredded.
Where the applicant is successful
If the applicant is successful the data will be transferred to their personnel file which will be kept for six years after the end of their employment. The electronic data will then be deleted and the paper data confidentially shredded.
Who has access to your information?
Where we need to share your personal data we require the recipients to treat your information as confidential and ensure the continued protection of your data whilst in their possession. We will process your personal data with the following recipients:-
- a) The hiring manager
- b) The line manager
- c) The HR manager
- d) Third party, where necessary, to protect the applicant's vital interest, e.g., emergency services
Lawful Processing
The legal basis we rely upon when processing your personal data are:-
Legitimate Interest
To fulfil our recruitment requirements which obtaining references is a vital part of in order to ensure we are recruiting the best and most reliable people for our organisation
2. Website visitors
We are committed to safeguarding the privacy of our website visitors and service users; in this notice we explain how we will handle your personal data. We will ask you to consent to our use of cookies in accordance with the terms of this notice when you first visit our website.In this section we have set out:
Usage Data
(NB: All these types of cookies can be different depending on the websites. It is likely that local Home-Starts will probably need to contact their website developer to find out which cookies are being used.)
We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
Account Data
We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Profile Data
We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and social media ids. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.
Service Data
We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include name, address, email address, details of donations made or items ordered. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Publication Data
We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
Enquiry Data
We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
Transaction Data
We may process information relating to transactions, including donations or purchases of goods and services that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
Notification Data
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
Correspondence Data
We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
Other
We may process any of your personal data identified in the other provisions of this notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, for example, anti -money laundering purposes or a court order. Please do not supply any other person's personal data to us, unless we prompt you to do so.
Who has access to your information?
We may disclose your personal data to any member of our group of charities in the Home-Start network insofar as reasonably necessary for the purposes set out in this notice.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
Financial transactions relating to our website and services are handled by our payment services providers, e.g. PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at:
Paypal (URL https://www.paypal.com/ie/webapps/mpp/ua/privacy-full)
Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the follow will apply:
- 1. Your data will be made available to our website provider
- 2. The data that may be available to them include any of the data we collect as described above.
- 3. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
- 4. They will store your data for a maximum of 7 years.
- 5. This processing does not affect your rights
In addition to the specific disclosures of personal data, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
How long is your information kept for?
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain and delete your personal data as follows:
(a) All personal data will be retained for a maximum of (seven years) following the date it was submitted, at the end of which period it will be deleted from our systems, unless requested by users.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Third party websites
Our website includes hyperlinks to, and details of, third party websites. This privacy notice only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them. If you use any link on our website we recommend you read the privacy notice of that website before sharing any personal or financial data
Social Media
We operate a number of social media pages including Facebook, Twitter, Instagram and You Tube. Although this notice covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy notice of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.
Personal data of children
Our website and services are targeted at persons over the age of 16. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
We use cookies for the following purposes:
- (a) authentication - we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: http cookies.
- (b) analysis - we use cookies to help us to analyse the use and performance of our website and services, cookies used for this purpose are : _utma, _utmb, _utmc, _utmt, _utmv, _utmx, _utmz.
Cookies used by our service providers
Our website service providers use cookies and those cookies may be stored on your computer when you visit our website.
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.
Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- (e) https://support.apple.com/kb/PH21411 (Safari); and
- (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website.
3. Our Supporters - Fundraising & Communications
How do we collect information from you?
We obtain information about you in the following ways:
Information you give us directly
For example, we may obtain information about you when you take part in one of our events, make a donation, apply to volunteer for us, purchase products and services or when you register to receive one of our weekly newsletters.
Information you give us indirectly
Your information may be shared with us by third parties, which might include:
What type of information is collected from you?
The personal information we collect, store and use might include:
Data protection laws recognise certain categories of personal information as "special category" and therefore requiring greater protection, for example information about your health, ethnicity and religion.
We do not usually collect special category data about you unless there is a clear and valid reason for doing so and data protection laws allow us to. For example, we may ask for your health information if you are taking part in one of our fundraising running events.
Where appropriate, we will make it clear why we are collecting this type of information and what it will be used for.
Public Information
We supplement information on our supporters with information from publicly available sources such as annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone's interests and support. For more information, please see the section on "Building Profiles" below.
How and why is your information used?
You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the vital work we do for families and the exciting products and services you can buy, then you can select your choices by ticking the relevant boxes situated on the form used to collect your information.
We may use your contact details to provide you with information about the vital work we do for families, our fundraising appeals and opportunities to support us, as well as the products and services you can buy, if we think it may be of interest to you.
Email/text/Phone/Post
We will only send you marketing and fundraising communications by email, text and telephone if you have explicitly provided your prior consent. You may opt out of our marketing communications at any time by clicking the unsubscribe link at the end of our marketing emails. We may send you marketing and fundraising communications by post unless you have told us that you would prefer not to hear from us.
How long is your information kept for?
We are committed to putting you in control of your data so you are free to change your marketing preferences (including to tell us that you don't want to be contacted for marketing purposes) at any time.
We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes like where we are processing a donation or thanking you for your participation in an event.
We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes). We review our retention periods on a regular basis.
Who has access to your information?
We do not sell or rent your information to third parties.
We do not share your information with third parties for marketing purposes.
However, we may disclose your information to third parties in order to achieve the other purposes set out in this notice. These third parties may include:
Third parties working on our behalf
We may pass your information to our third party service providers, suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you mailings). However, when we use these third parties, we disclose only the personal information that is necessary to deliver the services and we have a contract in place that requires them to keep your information secure and prevents them from using it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties unless we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime. We will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so..
Third Party Product Providers we work with
Our trusted third party product providers provide a range of quality and reliable products and services designed to meet the needs of families. When you enquire about or purchase one or more of these products, the relevant third party product provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. They will be acting as a joint controller of your information and therefore we advise you to read their Privacy Notice. These third party product providers will share your information with us which we will use in accordance with this notice.
Lawful Processing
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:
Specific Consent
Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.
Performance of a contract
Where we are entering into a contract with you or performing our obligations under it, like when you buy Home-Start named products and services.
Legal obligation
Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority like the Charity Commission or Fundraising Regulator for example, in relation to anti -money laundering purposes.
Vital interests
Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual at one of our events) or a safeguarding issue which requires us to share your information with the emergency services.
Legitimate interests
Where it is reasonably necessary to achieve our or others' legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).
We consider our legitimate interests to be running a charitable organisation in pursuit of our aims and ideals. For example to:
When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
When we use sensitive personal information, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law (for example, if we need to process it for employment, social security or social protection purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
We may also use your personal information to detect and reduce fraud and credit risk.
4. Measuring Evaluation System Home-Start (MESH)
We are joint data controllers with Home-Start UK. Home-Start UK host an internal monitoring system which manages and maintains a database of information collected from families.
How do we collect information from you?
We use MESH to track outcomes from work undertaken with families being supported
What type of information is collected from you?
In the course of their time a family being supported will have some of their personal details kept securely in electronic format on the MESH system. This information can include:
How and why is your information used?
Funders may request that we provide them with data to prove that we are doing what we said we would do to help support families. At no time are your personal details shared. All information given is in statistical format and on occasion, we may provide an anonymised case study of a family. No names or identifiable information is given, but this is an important way to show what a difference our support can make.
How long is your information kept for?
We will not keep the information for longer than necessary.
Who has access to your information?
We limit access to MESH data to those who have a genuine need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place 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.
Lawful Processing
MESH is used under the lawful basis that it is reasonably necessary to achieve our or others' legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).
5. FAMILIES USING OUR SERVICES
How do we collect information from you?
Information you give us directly
We collect information about you and family members when you register with us for any of our services and also when you start to receive our services. We collect information when you voluntarily complete service user surveys, provide feedback and participate in events.
Information from our staff
Our staff will create records about you while delivering services, for example by way of notes added to your case file
Information we receive from other sources
Your information may be received by us from third parties, which might include:
What type of information is collected and used about you?
The information we collect and use will include personal data and sensitive data (known as "special category data" in data protection law).
These records may include the following information relevant to you, your partner and the children you care for and anyone else who is part of your household:
Data protection laws recognise certain categories of sensitive personal information as "special category" and therefore requiring greater protection, for example information about your health, ethnicity and religion.
We may collect and use the following types of special category information:
How and why is your information used?
We will only collect and use the minimum necessary information needed for us to provide you with our services and for staff to deliver and provide appropriate support to meet your needs.
We use this information only to the extent necessary to provide the services to you that you have requested from us unless there are exceptional circumstances, such as when the health or safety of a child or others is at risk, or other situations where the law requires the disclosure of information.
If you do not provide us with information that we ask for and that we require, we may not be able to provide services to you. If you are uncomfortable about disclosing certain information to us or if you have any concerns or queries about why we require certain information, we are happy to discuss this in further detail with you.
In limited circumstances, we may ask for your consent to use your information (for example, for your experience with us to be used in Home-Start materials or on our website). In these circumstances, we will always ask for your explicit consent beforehand, and we will tell you how you can withdraw your consent if you change your mind (which you can do at any time).
Receiving communications from us by Email/text/Phone/Post
You have a choice about whether or not you wish to receive information from us. If you want to receive direct marketing communications from us about the vital work we do for families and the products and services available to you, then you can select your choices by ticking the relevant boxes situated on the form used to collect your information.
We will only send you marketing communications by email, text and telephone if you have explicitly provided your prior consent. You may opt out of our marketing communications at any time by clicking the unsubscribe link at the end of our marketing emails. We may send you marketing communications by post unless you have told us that you would prefer not to hear from us.
We're committed to putting you in control of your data so you're free to change your marketing preferences (including to tell us that you don't want to be contacted for marketing purposes) at any time using: office@homestartmidsuffolk.org.uk, or by telephone: 01379 678552, or post: Angela Dennis, Business Manager, Home-Start Mid & West Suffolk, 20 Broad Street, Eye IP23 7AF.
We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes like where we are notifying you of an office closure or a change to your appointment time.
Where is your information kept and long is it kept for?
Information is retained in secure electronic and paper records and access is restricted to only those who need to know. Our guiding principle is that we are holding your information in strict confidence and in accordance with the law.
We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for depends on our requirements to provide our services and run our business or to comply with the law. Case records are generally kept on our live system for up to 1 year, after which time they are anonymised so that any identifiable information is removed. In certain circumstances we may be required to keep records for a longer period, depending on the nature of the case and whether or not we are subject to separate legal obligations which require us to do this.
Who has access to your information?
In order to provide you with our services, we will share your information internally within Home-Start on a need to know basis, to ensure we are providing you with a good service. We may also share your personal information with some or all of the following parties, but we will always do this in compliance with data protection law:
We do not sell or rent any of your information to third parties.
We do not share any of your information with third parties for marketing purposes unless you have requested us to do so.
We will only share special category information with other organisations where that is necessary for legal reasons, or where there are other substantial public interest grounds.
Lawful Processing
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:
Legitimate interests Where it is reasonably necessary to achieve our or others' legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).
We consider our legitimate interests to be running Home-Start as a charitable organisation in pursuit of our aims and ideals. For example to:
Specific Consent
Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.
Legal obligation
Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority like the Charity Commission, or we are required to report a crime.
Vital interests
Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual) or a safeguarding issue which requires us to share your information with the emergency services.
Our lawful grounds for processing Special Category data
When we use special category (sensitive) personal information, we require an additional legal basis to do so under data protection law. Our basis for using such information is normally to provide our services of counselling, social care, and safeguarding children and individuals at risk of neglect or physical, mental or emotional harm and for protecting their economic well-being. Sometimes we may use another route available to us at law (for example, if we need to process it for social protection purposes, vital interests, or, in some cases, if it is in the public interest for us to do so).
Download the complete policy below