GENERAL PRIVACY NOTICE
Homelink is committed to protecting and respecting your privacy. Wherever you share personal data with us we aim to be clear with you and not to do anything that you would not reasonably expect us to do. We will always endeavour to tell you when we are collecting data from you and in this document we describe how and why we collect personal data and what we use it for.
Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photograph, video, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the Data Protection Bill/Act 2017 the General Data Protection Regulation 2016/679 (the “GDPR”) and other legislation relating to personal data and rights such as the Human Rights Act 1998.
Who are we?
This Privacy Notice is provided to you by Homelink’s Board of Trustees who are the charity’s Data Controller. A description of what data is processed and for what purpose is set out in this Privacy Notice.
What data does the Data Controller listed above process?
We receive personal information from you when you ask about our activities, use our services as a client/carer, make a donation to us, receive our newsletter, fundraise on our behalf, work for us as a member of staff/volunteer/contractor or otherwise give us personal information. The type of personal information we collect therefore depends on the reason why you are engaging with us. It may include information such as:
- Names, titles, aliases, addresses, date of birth, email address, photographs and telephone numbers.
- For staff and volunteers we will also hold an emergency telephone number and name.
- For staff, financial identifiers such as bank account numbers and sort codes
- For staff, financial information such as salary, overtime recorded, bonus, recording of earning, tax benefits contribution code, tax and benefit contributions
- For clients and carers it will be appropriate for us to ask for information about your health, medication details, GP name and other personal circumstances/background information.
- Where they are relevant to our work, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, health/diagnosis data,
- Where you make donations or pay client fees or other services, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
- Other operations personal data created, obtained or otherwise processed in the course of carrying out our activities, including but not limited to, CCTV footage, IP addresses, recordings of telephone conversations and website visit histories, logs of visitors, and logs of accidents, injuries and insurance claims.
How do we process your personal data?
The Data Controller of Homelink will comply with legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all the following purposes (for example no financial information will be processed for volunteers):
- Record your involvement with us
- Deliver our respite care service, and to carry out any other voluntary or charitable activities for the benefit of clients and carers as provided for in our constitution and operating framework;
- Enable us to meet all legal and charitable obligations (as set out for example by the Charity Commission);
- Carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all vulnerable adults at risk are provided with safe environments;
- Administer the client, carer, staff, volunteers, trustee and supporter records;
- Provide any information you have requested from us;
- Manage our employees and volunteers;
- Maintain our own accounts and records;
- Process a grant or application for a role
- Administer any donation from you or support your fundraising efforts, including the claim of Gift Aid on your donation (as requested by HMRC);
- Seek your views or comments;
- Thank you;
- Notify you of changes to our service, events and role holders;
- Administer the 100 Club membership records;
- Send you communications about our work and how you can help us, for example information about fundraising activities, volunteering and campaigns;
- Process sensitive personal data including as appropriate recording staff and volunteer physical or mental health or condition in order to monitor sick leave and take decision about fitness for work;
- Process data for legal, personnel, administrative and management purposes and to enable us to meet our legal obligations with all Homelink role holders for example, for paid staff, monitor their performance. [Different role holders include volunteers, employees, contractors, agents, staff, clients, carers, temporary employees, trustees and others.]
- Record racial or ethnic origin or similar information to monitor compliance with equal opportunities legislation;
- Process data to comply with legal requirements and obligations to third parties.
- Processing also includes the use of CCTV systems for the prevention and prosecution of crime.
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party such as social services. An example of this would be our safeguarding work to protect adults at risk. We will always take into account your interests, rights and freedoms.
Some of our processing may be necessary for compliance with a legal obligation set out for example by the Charity Commission.
We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into contract with you.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Sharing your personal data
Your personal data will be treated as strictly confidential. We will not sell your details to any third parties.
It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. For example, when you indicate that you would like to receive information from us in the post or via email, we may provide your name and address or email address (if applicable) to a third party sub-contractor who will compile and send out the relevant mailings on our behalf. This third party will not use or process the information for any purpose other than compiling and sending out the relevant mailing. The information you receive will be information which you have agreed to receive from us and the third party will not contact you for any other purpose.
In addition, from time to time we may exchange your personal information with other organisations for the purposes of fraud and credit risk reduction. We may also share information with our financial and legal advisors for the purposes of obtaining advice and protecting legal rights.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
- The right to access information we hold on you
- At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
- There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
- The right to correct and update the information we hold on you
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us, and your data will be updated.
- The right to have your information erased
- If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
- When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your data
- You have the right to request that we stop processing your data. Upon receiving the request, we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
The Homelink website may include links to other sites, not owned or managed by us. We cannot be held responsible for the privacy of information collected by websites not managed by us.
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Changes to the Notice
We keep this Privacy Notice under regular review and we will place any updates on our website www.homelinkdaycare.co.uk. This Notice was last updated May 2018.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller, Board of Trustees, Homelink Day Respite Care Centre, Hospital Bridge Road, Whitton, Middlesex TW2 6DE (Registered Charity No 1047856)
Tel: 0208 255 1992 Email: firstname.lastname@example.org
You can contact the Information Commissioners Office on 0303 1231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF