INTRODUCTION
We have been providing practical support, education, advice and much more to those in poverty, in poor living conditions, benefit claimants, the unwaged, pensioners, families and those on low incomes and suffering social exclusion and poor wellbeing since 1981.
To provide these services, Brighton Unemployed Centre & Families Project (“BUCFP”) needs to collect personal information about the individuals who receive these services, and the people who help us provide them.
This Privacy Notice sets out how we record, store and process personal information, whilst confirming our commitment to handling all personal information responsibly and compliantly.
OUR PRIVACY COMMITMENT
Transparency – We will keep you informed of when and how we’ll use your information, using concise, easily accessible and easy to understand language.
Fairness – When processing your personal information, we will operate within your expectations and, where appropriate, ask you if we need to use your information in ways you wouldn’t anticipate.
Lawfulness - We will process all personal information entrusted to us in a compliant and lawful manner, and always in accordance with the applicable data protection laws.
RESPONSIBILITY FOR YOUR INFORMATION
In accordance with applicable data protection laws, BUCFP processes personal information as a “Data Controller”. This means we are responsible for your information at all times, and we decide why we need the information, how we’ll handle it and how to keep it safe.
BUCFP is a registered charity. Our registered charity number is 1069236 and we can be contacted by email, telephone or post.
Email: info@bucfp.org
Telephone: 01273 671 213 or 01273 601 211
Postal: BUCFP, 6 Tilbury Place Brighton, England, BN2 0GY, United Kingdom
WAYS WE WILL COLLECT OR RECEIVE YOUR INFORMATION
We collect personal information through several different methods. Most commonly, you will provide information directly to us when you register for services, apply as a volunteer or apply to work for us.
We also receive your information indirectly from other people or organisations. For example, we may receive information from members of your family, the organisations that we contact on your behalf or government agencies, such as the Department for Work and Pensions (DWP) and local authorities. We can also receive your information in relation to fundraising. This might be from our fundraising partner Virgin Money when you donate to our causes through their website, or through other fundraising activities.
If you choose to interact with us via our social media accounts (for example, Facebook and Twitter) we may receive some personal information about you, which is information typically included in your public profile.
REASONS FOR PROCESSING YOUR INFORMATION
There are many different reasons we need your personal information. These include the following, which are some of the most common reasons.
To provide you with the services you have registered for;
To contact you by telephone, post or email regarding the service you have registered for;
To share with other organisations on your behalf as part of the services we provide;
For the protection and safety of our other members, volunteers and staff;
To keep appropriate records of your visits to our premises and your ongoing relationship with us;
When assessing individual needs in respect of the services we can offer;
When assessing suitability to volunteer or work for our organisation;
For processing and administration of financial transaction such as employee salary and charitable donations.
THE TYPES OF INFORMATION WE PROCESS
Your contact information: Information that provides a way for us or a third party to contact you. For example, your email address, postal address, care of address or a telephone number.
Identifying information: Information that fully or partially identifies a specific person. For example, your name, a website login username, your government issued identification, such as a driving licence.
Your family information: Information about your family and relationships. For example, your family structure, any siblings, offspring, marriages, divorces or other important relationships
Medical and health information: Information that describes a person’s health, medical conditions or health care. For example, your current or historical physical and mental health, previous or existing narcotic dependencies, any disabilities, and details of your family or individual health history.
Demographic information: Information that describes a person’s characteristics that can be shared with other people. For example, age, race, ethnicity, gender, marital status, income, education, and employment.
Financial information: Information that relates to your financial status. For example, employment status, salary levels, amounts of personal debt, types and amounts of benefits being received.
Social Network information: Information about an individual’s use of social media platforms or their online social connections. For example, opinions posted on our social media pages, or friends, connections, associations and group memberships.
REASONS FOR SHARING YOUR INFORMATION
To provide the services you have requested, BUCFP may need to share your information with other organisations or agencies. For example, where members receive our Welfare Rights service, we will sometimes communicate directly with the DWP on their behalf, which will require the sharing of some personal information. In addition, we may share information with the local authorities, funding bodies, other charities and other voluntary agencies.
To enable BUCFP to meet our stated objectives of providing practical support, education, advice and much more to our members, we will sometimes rely upon trusted service providers. We only use carefully selected service providers that provide commitments in respect of their secure handling of your information. These organisations are not permitted to use your information for their own purposes.
We may also be required to share information about you and your interactions with BUCFP with law enforcement and other government agencies, if required to do so by law. It is important to understand that there are exemptions within our data protection laws that mean BUCFP can be under a legal obligation to share limited amounts of your personal information with these organisations. The most common exemption is when the sharing of information relates to the prevention and detection of crime or to prevent benefit fraud.
LAWFUL PROCESSING OF PERSONAL INFORMATION
The current data protection law is called the General Data Protection Regulation (“GDPR”). This law requires us to identify an appropriate “lawful ground” when we are processing your personal information.
Why is lawful ground important? Under GDPR the very first data protection principle requires organisations to process all personal information lawfully, fairly and in a transparent way. If there is no lawful basis applied, the processing will be unlawful and in breach of the GDPR.
We have considered all the appropriate lawful grounds and the following are relevant to BUCFP and the services we provide:
Consent: This is where you will have given us clear, free and informed consent (permission) for us to process your personal information for a specific purpose.
Contract: This is where the processing is necessary for a contract we have with the individual. Examples would be if you hired a room from BUCFP or where we process our employee’s personal information under the employment contract.
Legal obligation: This is for times when the processing is necessary for BUCFP to comply with a regulation or a law. For example, where we are required to disclose employee salary details to HMRC, or if we were required by the Charity Commission to share information.
Vital interests: This is for rare times when the processing of personal information is necessary to protect someone’s life.
Legitimate interests: This refers to processing that we have assessed to be necessary for our legitimate interests or the legitimate interests of another organisation. When using this basis, we check whether there are any important reasons where your interests might override our interests and we give careful consideration to whether what we are doing is within your reasonable expectations.
TRANSFERRING YOUR INFORMATION ABROAD
As part of the services we provide, including the service providers we engage on our behalf to support these services, the information that we process about you may be transferred to countries outside the United Kingdom and even beyond the European Economic Area (“EEA”).
It is important that you understand that countries beyond the EEA may not have as strong data protection laws to those in the UK. If we transfer your personal information outside of the EEA, we will take the appropriate steps to ensure that proper security measures are in place, which will ensure that your data protection rights continue to be protected as detailed within this Notice.
In all cases, should personal information be transferred abroad, we will take steps to ensure your personal information is only transferred once an adequate safeguard is put in place. This includes specialised contracts called “Model Clauses”, or other approved mechanisms or derogations under UK or EU law.
YOUR RIGHTS WHILE WE ARE PROCESSING YOUR INFORMATION
While BUCFP is processing your information, you will have rights. For example, these rights can enable you to see what information we hold and, in some circumstances, correct the information or request that BUCFP delete or destroy it. The following is a list of rights that you have. Please be aware that not all rights apply in all situations and in some cases, we may not be able to satisfy a rights request. If we are unable to satisfy a request you have made, we will notify you within one month of your request, explaining why we cannot complete it.
In all cases, we will endeavour to complete your request within one month of receiving it. In exceptional circumstances, for example if your request is particularly complex or if we are receiving unprecedented volumes of requests, we may require a two-month extension to complete the request. We will notify you within one month of your request that we need an extension, explaining why we cannot complete the original request within one month.
Right to be informed: BUCFP must provide important information explaining the relevant aspects of our information processing. This information, sometime referred to as ‘fair processing information’ is provided via this Privacy Notice.
Access to your information (receive copies): You are entitled to know whether we hold your personal information and if we do, receive a copy of your information.
Correction of your personal information: BUCFP uses all reasonable measures to ensure the accuracy of your personal information. You have a responsibility to ensure that you only submit factually accurate, true and complete information to us. If you believe we are holding inaccurate personal information, you have a right to ask us to correct any inaccuracies in your information.
Deletion of your personal information: In some limited circumstances, you will have the right to request that your personal information is deleted. The most common situation when deletion is possible is when the information is no longer necessary for the purposes it was collected.
Right to object: In some limited circumstances, you will have the right to object to how we are processing your information. This is typically available when an organisation is sending marketing messages and a recipient wants the messages to stop.
HOW LONG WE KEEP YOUR INFORMATION
BUCFP recognises that, in most cases, personal information cannot be kept indefinitely. Regardless of whether you are a member, volunteer, donor, or employee, we will only store your information for a limited amount of time.
The length of time we keep personal information will often be related to the reasons we are processing it. For example, HMRC requires employers to keep salary information for several years. For our members, volunteers, donors, and employees, we will keep your personal information for the duration of our relationship.
Once our relationship has ended, your personal information will be retained for different time lengths based upon the type of relationship you had with BUCFP and the services or opportunities you were registered for. Time lengths can be determined by the legal or regulatory requirements that the information falls under. If there are no legal or regulatory requirements, we will decide the length of time based upon our organisational needs.
Once the retention period has expired, we will take steps to securely dispose of, or permanently delete, your information.
YOUR QUESTIONS OR CONCERNS ABOUT OUR INFORMATION PROCESSING
As we have stated, our aim is to be transparent and clear with our members, volunteers and employees, but we recognise that sometimes individuals may have questions, concerns or even complaints. If you have any questions or concerns about how we use your personal information, or how we’ve satisfied any rights requests you’ve submitted, please let us know.
BUCFP is best placed to reply to your queries and, where required take any steps needed to ensure our practices are consistent with our privacy commitments and our regulatory obligations.
If you decide you are still not satisfied with the way we have used your personal information, or you believe we are not compliant with data protection laws, you have the right to lodge a complaint with a data protection authority. In the UK, the relevant supervisory authority is the Information Commissioner’s Office (ICO). You can contact the ICO via their website (https://ico.org.uk/make-a-complaint/) or call them on 0303 123 1113.
USE OF COOKIES ON THIS WEBSITE
A cookie is a small text file that is downloaded onto ‘terminal equipment’ (e.g. a computer, laptop, smartphone or tablet) when the visitor accesses a website. It allows the website to recognise that person’s device and store some information about the person’s preferences or past actions. They are widely used in order to make websites operate properly or work more efficiently. Sometimes they provide analytics or visitor-based information (e.g. number of site visitors and the pages they viewed) to the owners of the site. The list below explains the cookies we use and why.
Strictly necessary cookies
Name: crumb. Purpose: Security (Prevents cross-site request forgery (CSRF)). Duration: Session only (Expires when you close the browser).
Analytics and performance cookies:
Name: ss_cvr. Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site. Duration: 2 years.
Name: ss_cvt. Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site. Duration: 30 minutes.
Name: ss_ cpvisit. Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site. Duration: 2 years.
Name: ss_cvisit. Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site. Duration: 30 minutes.
Name: ss_ cid. Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site. Duration: 2 years.
Name: ss_ cookieAllowed. Purpose: Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies. Duration: 30 days.
HOW DO I CHANGE MY COOKIE SETTINGS?
Visitors to our website can change their cookie preferences at any time using browser controls. Most web browsers allow control of most cookies through the browser settings.
Find out how to manage cookies on the most popular browsers, click any of the following links. Please be aware that these are third party websites that we have no control over.
To gain a greater understanding of cookies, including how to find out what cookies have been set on your device, we recommend you visit either of these websites www.allaboutcookies.org or www.aboutcookies.org. Please be aware that these are third party websites that we have no control over.
CHANGES TO THIS NOTICE
We may, from time to time, make changes to this Notice. We will always have the latest version available here on our website. It we make any significant changes, we will add a message on our website or contact our members, volunteers, or employees directly to inform them of the relevant changes.
This policy was last updated on 25 November 2020.