North Yorkshire Centre for Independent Living
Fair Processing Notice
This notice applies to all data subjects whose data is processed by North Yorkshire Centre for Independent Living
The Data Protection Officer (“DPO”) is responsible for ensuring that all potential data subjects have sight of this notice prior to the collection and/or processing of their personal data by North Yorkshire Centre for Independent Living
All employees of North Yorkshire Centre for Independent Living who interact with data subjects are also required to ensure that this notice is brought to the attention of all data subjects, securing their consent for the processing of their personal data.
3. Fair Processing Notice
North Yorkshire Centre for Independent Living will use the personal data collected from you for the following purposes:
Internal record keeping.
We may use the information to improve our products and services.
We may periodically send promotional email about new products, services, special offers or other information which we think you may find interesting using the email address, address or phone number which you have provided.
From time to time, we may also use your information to contact you for market research purposes.
We may contact you by email, phone, fax or mail.
In order to provide our services.
To fulfil our contract with you
You hereby confirm that you are consenting to North Yorkshire Centre for Independent Living’s use of your personal data for the aforementioned purposes(s) and are granting North Yorkshire Centre for Independent Living permission to carry out those actions and/activities.
You may withdraw your consent at any time by reading our Right to Withdraw Consent Procedure 92017-I
4. What is Personal Data?
The EU’s General Data Protection Regulation (“GDPR”) defines “personal data” as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
The GDPR classifies certain data as belonging to “special categories”, as follows:
Membership to a trade-union;
Data concerning a natural person’s sex life;
Sexual orientation; and
The GDPR requires that consent is provided by the data subject for all types of personal data, including those pertaining to the special categories set out above and otherwise. Consent must be explicitly provided.
When North Yorkshire Centre for Independent Living requests sensitive data from data subjects, it is required to confirm why the information is required and how it will be used.
5. Why does North Yorkshire Centre for Independent Living need to collect and store personal data?
North Yorkshire Centre for Independent Living is committed to ensuring that all personal information collected and processed is appropriate for the stated purpose(s) and shall not constitute an invasion of your privacy. We may share your personal data with third party service providers who are contracted by us and we shall ensure that they will hold your personal data securely and shall use it only in order to fulfill the service for which they are contracted. When there is no longer a service need, or the contract comes to an end, the third party will dispose of all personal data according to our procedures. We will never share your personal data with third parties until we have received your consent, unless we are required to do so by law.
6. How North Yorkshire Centre for Independent Living uses your information
North Yorkshire Centre for Independent Living will process your data (i.e. collect, store and use) according to the requirements of the GDPR at all times and shall endeavor to keep your personal data up-to-date, ensuring its accuracy and will not keep it for longer than it is required. In some situations, there are set legal requirements for the length of time that North Yorkshire Centre for Independent Living will retain your personal data but usually North Yorkshire Centre for Independent Living will use its discretion, ensuring that personal data is not kept outside of our usual business requirements.
We shall never be intrusive or invasive of your personal privacy and shall not ask you to provide data that is irrelevant or unnecessary and we will enact strict measures and processes to ensure that the risk of unauthorised access or disclosure of your personal data is minimised as much as possible.
We will only use your personal data for the following purposes:
Keep you updated with information which may be of interest, including campaigns, appeals, promotions, events and newsletters
Seek your views or comments on the services we provide
Handle a donation that you have made
Provide you with information and support at any activities or fundraising events that you participate in.
Carry out our obligations arising from any contracts entered into by you and us
Deal with entries into a competition
Manage any referrals to our services
Let you know about any changes to our services
Contact you about the service you are receiving for example about an appointment.
Handle a job or volunteer application.
We will only ever use your information for the purpose we told you when you originally provided it. As a broad example, if you apply for a job vacancy, your details will only be used for recruitment purposes – it will not be used for marketing purposes.
The legal basis that we rely on for processing your information will depend on the circumstances in which it is being collected and used. However, in most cases, it will fall into one of the following categories:
Where you have provided your consent for us to use your data in the way that we have explained. For example, we will always ask consent before sending you e-mails or text messages about our work (i.e. the newsletter)
Where we need to process your information to carry out our legal obligations, such as processing gift aid, HMRC, Pensions
Where the processing is necessary to carry out the performance of a contract, such as processing a donation
Where we have a legitimate reason to process your information. This includes providing you with information that we feel would be of interest to you, would be reasonably expected, and not intrusive. We may, therefore, send this information to you by post, or contact you by telephone. You can ask us to stop providing you with this information at any time, and we have explained more about legitimate interests below.
Broadly speaking, legitimate interests means we may process your personal information where we have a genuine and legitimate reason and are not harming any of your rights or interests.
When we process your information for our legitimate interests, we will always consider and balance any potential impact on your rights. As such, we will never use your information for activities where our interests are overridden by the impact on you.
It is always your choice whether you want to receive information from us, and you can opt-out at any time by contacting us.
7. Document owner
The Data Controller is the owner of this policy document and must ensure that it is periodically reviewed according to the review requirements contained herein.
The latest version of this policy document dated 25/05/2018 is available to all employees of North Yorkshire Centre for Independent Living on the server.
This policy document was approved by North Yorkshire Centre for Independent Living’s Board of Trustees and is issued by the Manager on a version controlled basis.