Introduction
The General Data Protection Regulation (EU) 2016/679 (‘the GDPR’) sets rules for processing personal information, which may be held on paper, electronically or otherwise. Legislation contains the statutory measures which control the collection, usage and storage of data by public and private sector bodies, including the voluntary sector and give rights of access to individuals to their own personal information.
Provisions of the legislation cover; the inclusion of manual records, the principles which apply to all data controllers, the processing conditions, sensitive personal data rules, transfer of data to countries outside the European Economic Area and further individual rights.
This policy affirms Western Isles Community Care Forum (hereafter referred to as WICCF) commitment to the data protection principles that are set out in the legislation, and specifies the procedures and good practice that will be followed.
Our Principles
WICCF promises to respect and protect the personal information (or data) you or your family have provided us with or that we get from other organisations and to keep it safe. We will manage this data effectively and securely so that we can deliver better services to and for you.
We ensure that we use your information in accordance with all applicable laws concerning the protection of personal information. This policy will outline what kinds of data we collect, why we collect it, how we will use, share, and store it, what your rights are, and how you can contact us to manage, edit or delete this information.
If you need to contact us, regarding your personal data or information, or for any other issue, please contact:
Western Isles Community Care Forum, Room 14, Council Offices, Tarbert, Isle of Harris HS3 3BG
Telephone: 01859 502588 or email: info@wiccf.co.uk
What kinds of information do we collect?
WICCF may collect different types of personal data directly from or about you depending on the activities or services we are offering and that you are taking part in or using. This can include your name, address, telephone number, email, date of birth, data relating to your personal and caring situations, medical data (if pertinent to the activities or services), and some financial data if you are giving us a donation or receiving a financial grant from us. You may provide us with any or all of this data online, on paper, at an event, or over the telephone.
If you are accessing our web pages we may also receive some analytical data from our Internet and webpage service providers. This is anonymous data such as IP addresses, pages visited and time spent on the website. If you are using WICCF secure online donation pages you are routed through to our online donations service provider and the data you give (such as your credit card, bank and/or contact details) is supplied so that the transaction can take place.
We may also receive some information about you from other organisations, for example a referral from another Third Sector Organisation, Health Dept. or Social Care. It might also include data from social media and messaging sources (e.g. Facebook) depending on your settings, the source’s own privacy policies, or the permissions you have granted us to access the data available through your account or publicly available comments.
Why do we collect this information and how will we use it?
We collect this data so that we can carry out our work and develop a better understanding of the people we support and who support us. It allows us to make better decisions and to provide better communications about matters that may be of interest to you, including about our work, current and future activities, local events and fundraising campaigns.
Data collected from feedback regarding services you have participated in helps us to improve our services, provides evidence to funders. Unless you have given us clear permission otherwise, this will presented as anonymous or collective data to third parties. Some types of information or data are considered ‘sensitive’ under data protection regulations. This includes information like health/medical data, race religious beliefs and political opinions. We will not normally collect this data unless it is necessary for the activity or service you are taking part in or using and you give us your permission to hold this data in our databases and records.
We will use the data you provide to us to process your donations or to respond to your information requests. We may use data that we hold about you, gathered through our relationship with you, to contact you with communications by post, phone or email about events, awareness and fundraising campaigns. It may be used to personalise our contact with you or the activities or services you are taking part in. It will also be used to administer our records.
Legal grounds and Legitimate Interest
When we collect and use your personal information, we will make sure this is only done in accordance with at least one of the legal grounds available to us under Data Protection law.
One of these is where we have obtained your consent to use your information for a previously notified purpose, such as to send you em ail, newsletters, letters or to provide you with a service or information at your request.
Another is where we have a legal obligation to use or disclose information about you – for instance, where we are ordered by a court or regulatory authority or we are legally required to hold donor transaction details for Gift Aid or accounting/tax purposes.
It could also be where we have an obligation to hold data for the obligation to funders/contracts or for the purpose of fulfilling our responsibilities in relation to staff and volunteers.
In all cases, we balance our legitimate interests against your rights as an individual and make sure we only use personal information in a way or for a purpose that you would reasonably expect in accordance with this Policy and that does not intrude on your privacy or previously expressed preferences.
Where we process sensitive personal data (as mentioned above), we will make sure that we only do so in accordance with one of the additional lawful grounds for processing such as where we have your explicit consent or you have made that information manifestly public. When we do this, we will tell you what sensitive personal data we are collecting and why.
Storage and Disposal of Data
WICCF takes appropriate actions to make sure that t he data we hold about you, whether that is on paper, electronically in a computer file or database, is stored securely. We will only hold this data for as long as it is necessary (7 years after service has been discontinued) for the purposes for which it is provided to us. We will dispose of unnecessary personal data using secure deletion methods (electronic) or shredding. We will contact you periodically to confirm that the data we hold about you is accurate and up-to-date and that we may continue to contact you. We will then update our records accordingly.
How you can manage or delete information we store about you?
Your rights regarding the data we hold and collect about you are outlined in the data protection policies and legislation of the United Kingdom and, from 25 May 2018, the European Union. These include: the right to access , edit and update, request the deletion of, and restrict the processing of your personal information, the right to object to the collection of your personal data and the right to lodge a complaint with a supervisory authority about your personal information.
If you would like to find out what personal information/data we hold about you, delete any of this data, or update your communication preferences please contact us on 01859 502588 or email info@wiccf.co.uk.
If you have any questions or comments about this Privacy Policy please contact our office directly at:
Western Isles Community Care Forum
Room 14, Council Offices, Tarbert, Isle of Harris HS3 3BG
Telephone: 01859 502588 Email: info@wiccf.co.uk
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to the Information Commissioner’s Office (ICO). You can contact the I CO on 0303 123 1113, at registration@ico.org.uk or at:
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Privacy and young and/or vulnerable people
This privacy policy applies to everyone, including those who are vulnerable, young people and children. To take part in an activity or service (including fundraising events) or provide any personal data to us, young people under the age of 13 must have permission or consent of a parent or guardian.
WICCF will seek such consent where necessary. WICCF will proactively work to ensure vulnerable people also understand their data rights and any of their data we collect is managed appropriately according to data protection regulations.
What information do we share and with whom?
We will never sell your data to other organisations. If we have your consent we may share your data with partners who can provide the best service for you. This could include sharing data with a Statutory Partner (Health, GPs and Social Care) and/or a Third Sector Organistion who may be able to provide you with further support.
We may also share your data in the following circumstances:
- Where we must comply with laws such as those for national security, taxation, or criminal investigations.
- Where we must undertake due diligence, to be sure we are not being used as a channel for criminal activities.
Links to external websites that are made available through the WICCF website or in any of our publications are for the purpose of convenience or citation. WICCF is not responsible for the content or privacy policies of these other pages. We encourage visitors to review each site’s privacy policy before disclosing any personally identifiable information.
Changes in our Privacy Policy
We will notify you through a notice on our website, or in some cases directly by your preferred form of communication, of any significant changes to this Privacy Policy. The effective date of each update will be displayed on the policy.
This Privacy Policy will be reviewed annually and WICCF reserves the right to modify this statement at any time.
Scottish Charity No SC023918
Data Protection Policy for Service Users
Reviewed May 2018