The UK General Data Protection Regulation (UKGDPR) and the Data Protection Act 2018 (DPA 2018) became law on 25th May 2018, and 1st January 2021 when the UK exited the EU.
This policy applies to individuals whose personal data is processed by Elleray Community Association/Elleray Hall.
What is the purpose of this document?
Elleray Community Association is committed to protecting the privacy and security of your personal information. 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.
Our contact details are as follows:
Address: Elleray Community Association, Elleray Road, Teddington, TW11 OHG.
Telephone: 020 8977 0549.
This privacy notice describes how we collect and use personal information about you during and after your working 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, contractors, volunteers, supporters, and clients/members. Any questions you have relating to how we use and share your information should be directed to the Elleray Community Association, Head of Services (HoS) using the contact details listed.
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:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. 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. We may also collect, store and use “special categories” of more sensitive personal information, which are also detailed in this notice.
How is your personal information collected? We collect personal information about you through telephone email, post, or enquiry forms or, for our employees and volunteers, via the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check. We will collect additional personal information during job-related activities, or through the course of providing a service to you.
How we will use information about you? Examples of how we may use this information include:
• Process orders submitted by you;
• to carry out our obligations arising from any contracts entered by you and us;
• verify your identity;
• seek your views or comments on the services we provide;
• notify you of changes to our services;
• improve our services;
• for marketing purposes;
• send you communications which you have requested and that may be of interest to you;
• campaign and fundraise for the benefit of older people. 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 with you, or the service you have asked us to provider.
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 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. 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 will 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 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. If you have used our services, we may on occasion share basic demographic and service information with Richmond Age UK, the Community Independent Living Service (CILS) contract co-ordinator so they can help us monitor and ultimately improve the services we provide. The information we share will not include your name or your contact details, unless you give us your consent to do so for a specific purpose, such as sharing your story. When we do share this information, we do so under the lawful basis of legitimate interest.
Data security - 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. Details of these measures may be obtained from the HoS.
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.
Data retention - 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. 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 using the details above.
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 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 the HoS.
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 CEO using the details above. 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.
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.
Sometimes we may provide information about you in an anonymised form. Such information is used to provide data to our funder namely for the CILS Partnership – LBRuT. If we share information for these purposes, then none of the information will identify you as an individual and cannot be traced back to you.
Updated September 2023. Next review September 2024.