AIMS AND SCOPE OF THIS NOTICE
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we will store and handle that data, and keep it safe.
We believe that as part of our charitable mission we have a responsibility to keep you and the wider community fully informed of your rights.
This Notice is comprehensive and covers all of Southmead Development Trust’s activities and services. The type of data that we process about you will depend on how you interact with us. All processes and procedures detailed in this Notice are conducted in accordance with our Data Protection Policy, which is reviewed annually.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
Contents of this Notice
- An overview of your different rights.
- What types of personal data do we use?
- When do we collect your personal data?
- How do we use your personal data?
- Who do we share your personal data with?
- Cookies and our website.
- How do we secure your data?
- How long will we retain your data for?
- What we ask of you.
- Contacting the Regulator.
- Questions and Contact.
1. An overview of your different rights
You have key rights in the following areas:
To withdraw consent – whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest – in cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Checking your identity – to protect the confidentiality of your information we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
You also have the right to request:
- The correction of your personal data when incorrect, out of date or incomplete.
- That we stop using your personal data for direct marketing (newsletters and bulletins), either by one communication method specifically, or completely.
- That we stop any consent-based processing of your personal data after you withdraw that consent (where applicable).
- That any decision made based solely on computerised, automatic processing of your data is reviewed by a human (where applicable).
- Access to the personal data we hold about you.
2. What types of personal data do we use?
Southmead Development Trust is a diverse organisation providing a range of goods and services to Southmead and the wider community. The type of information we hold about you might be very different to another person, and could be anonymous.
The type of information could be any of the following:
- Personally identifiable and contact information (e.g. names, addresses, age/date of birth, telephone numbers).
- Information relating to your digital identity (e.g. email address and social media username, as well as gathered from Cookies).
- Sensitive data, including racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, trade union membership, physical or mental health or condition, sexual orientation, criminal record.
- Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Financial information. Cardholder data is processed by our third-party supplier Payment Sense for the purpose of facilitating transactions. Southmead development Trust does not handle or store any cardholder data on our own servers as a result of this relationship.
- Your image and/or car number plate may be recorded by our CCTV.
- Your comments and reviews.
3. When do we collect your personal data?
Depending on how you interact with Southmead Development Trust, we will collect specific information about you.
- When you complete a form to use or contact us about any of our facilities or services.
- When you purchase a product or service or make a donation.
- When you engage with us on social media or visit our website (please see our Cookies Policy).
- When you contact us by any means with queries, complaints etc. (these can be made anonymously)
- When you contact us regarding a job vacancy or volunteer opportunity, or join our staff and volunteer team.
- When we survey the local community, customers and other groups for the purposes of public benefit, monitoring, and the attainment of our charitable objectives.
- If you provide a service to us.
- When you become a tenant/licensee or work for an organisation that is one of our tenants/licensees.
- When you’ve given a third-party permission to share with us the information they hold about you.
- We collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law.
- When you use our car parks and buildings which have CCTV systems operating for the security of all site users. These systems may record your image during your visit. Please note, we only retain CCTV for 31 days (external cameras) and 14 days (internal cameras), unless we have a lawful reason in exceptional circumstances (e.g. assisting the police) to retain the images for longer.
4. How do we use your personal data?
- In the provision of goods and services.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide.
- To send you communications you have consented to receiving.
- In the event of emergencies when an individual’s vital interests are of a reasonable risk of being affected or in incident reporting.
- To comply with our contractual or legal obligations to share data with law enforcement.
- For the purposes of monitoring, reporting and learning. Demographic monitoring containing sensitive data is processed in line with our Equal Opportunities Policy and our Equality and Diversity Policy.
- For the purpose of checking your identity when you interact with us or ask to access or change any of the information we hold about you.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring, or suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
- For the purposes of documenting social and organisational history.
5. Who do we share your personal data with?
In some specific circumstances it is necessary for Southmead Development Trust to share your personal data with third parties. We work with these parties to improve the Trust’s service delivery in the pursuit of our charitable objectives. When providing personal data to third parties we only provide the information needed to perform their specific services and only do so once we have clearly specified the exact purposes the data is to be processed for.
We work closely with all third parties which support our work to ensure that your privacy is respected and protected at all times.
We never sell personal data to anyone.
Examples of the kinds of third parties we work with are:
IT companies who support our website and provide our data management and storage systems. Examples are:
- Absolutely PC – Network security and maintenance
- Microsoft – Office 365 and Exchange
- EZ Facility – Our service user and customer database
- hosteurope.com – Hosting www.southmead.org
Companies or organisations that support our Operations or Service Delivery. Examples are:
- External fitness instructors – for the provision of fitness classes.
- Creative Youth Network – contract partner in the delivery of youth services.
- NHS – anonymous or pseudonymised data for reporting on contract delivery progress of the Trust’s Diabetes Prevention Programme
We may be occasionally required to share your information with public authorities when we are legal obligated to do so. An example is:
- Avon & Somerset Police – To release CCTV footage to the police when required by court order.
For further information please contact our Data Protection Lead.
6. Cookies and our website
Southmead Development Trust uses a limited number of Cookies on our website. For full details please view our separate Cookies Policy.
Our websites contain links to third party websites. We cannot be held responsible for the content of any external websites.
7. How do we secure your data?
Securing data is crucial. We respect the trust shown by anyone who interacts with Southmead Development Trust by processing all personal information securely. Here are the ways by which the Trust ensures your data security:
- Access to your personal data is password-protected, and sensitive data such as that relating to your physical and/or mental health and wellbeing is secured and/or pseudonymised to ensure it is protected.
- We have a Data Protection Policy (containing an Information Security Policy) which clearly sets out the procedures for the proper collecting, processing, transfer, sharing, retention and deletion of all data types.
- We have a Network Security Policy.
- We have separate staff and guest networks.
- Data Protection training is mandatory for all staff.
- Anti-virus software is installed on all our devices and computers. Maintenance of computer systems and equipment is provided by a professional third party.
- Documents and files are physically secured with lockable cabinets and filing rooms. Access to these areas is restricted and monitored.
How long will we retain your data for?
Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used for social or organizational history.
9. What we ask of you
- To please give us accurate information.
- To tell us as soon as possible about any changes to your personal information.
- To tell us if you notice mistakes or inaccuracies in the information we have about you.
- To respect other people’s privacy rights.
10. Contacting the Regulator
The Information Commissioner’s Office (ICO) is the Data Protection regulator. Its job is to uphold information rights in the public interest.
If you would like more information about the terminology used in this Notice you may like to visit their website.
If you feel that your data has not been handled correctly – by us or any other organisation – you can contact the ICO to escalate your concern.
- You can contact their helpline by calling 0303 123 1113.
- You can visit their website for more options and information: www.ico.org.uk (this opens in a new window; please note we cannot be held responsible for the content of external websites)
11. Questions and Contact
If you have any questions that haven’t been covered, or to exercise any of the rights contained in this Policy, please contact our Data Protection Lead who will be able to help you:
Sam Garbett – Operations Manager
firstname.lastname@example.org (please put ‘Privacy Notice’ in the subject line)
Southmead Development Trust, Greenway Centre, Doncaster Road, Bristol, BS10 5PY.