"Seeking to provide a safe environment where Refugees and Asylum Seekers can find friendship, food and practical help."

We're looking for help! >>

English Teachers - the Destitution Project is looking for experienced English teachers who would like to volunteer to teach beginner or intermediate/advanced classes for our service users. Classes are up to 2 hours long and take place on Wednesdays at various times and we currently have 2 levels for women and 2 levels for men. Each volunteer teacher would work with one class, and likely be part of a small team of teachers (some of whom are not trained in teaching English). We also try to provide one-to-one instruction throughout the day for those service users with very little English knowledge.

Reception Volunteers - the Destitution Project is in need of volunteers to man our reception desks each Wednesday. This would require you to be present between 9.45am and 3.00pm. You will need to have good interpersonal and organisational skills, and like to meet and greet people but also comfortable ensuring that access to the Drop-In Centre and its services are well managed. You will likely work as part of a two-person team. Previous experience in this sort of task would be ideal, but not essential.
You must be 18 and over to apply.

Privacy Policy

Typography

The Destitution Project (DP) respects your privacy and is committed to protecting your personal information (personal data). This privacy notice lets you know how we look after your personal data which either you provide to us or we obtain and hold about you and it tells you about your privacy rights and how the law protects you.

This privacy notice is available online on our website (https://www.boltondp.org/). Alternatively you can request a copy by emailing the DP Manager at info@boltondp.org .  Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

PURPOSE OF THIS PRIVACY NOTICE

The Destitution Project (DP) seeks to advance the education and relieve financial hardship among asylum seekers and refugees, and to provide them with suitable facilities for recreation and other leisure.  Our services focus around a weekly Drop in Centre held at Victoria Hall in Bolton.  We are a registered charity, dependent on the help of volunteers and donations from range of sources to achieve our objectives. 

This privacy notice aims to give you information on how DP collects and processes your personal data which either you provide to us or we obtain and hold about you including any data you may provide when you become a volunteer, donor or service user.    It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or dealing with personal data about you (e.g. website privacy notices and employment privacy notices) so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

The DP is a registered charity in Bolton in the United Kingdom (Charity # 1109703). This privacy notice is issued on behalf of DP and when we mention, “we”, “us” or “our” in this privacy notice, we are referring to the charity DP that is responsible for processing your data.

Trustees for DP are the controller and responsible for general data protection issues arising in respect of day to day matters such as lists of staff and volunteers, service users. The Chair of the DP Trustees is the controller and responsible for data protection matters concerning safeguarding and complaints and discipline issues. When we mention the controller we mean the relevant controller.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the relevant contact for the DP using the details set out below.

CONTACT DETAILS

Our full details are:

The contact for routine, day to day data protection matters for DP is:

The DP Manager

Destitution Project

Email: info@boltondp.org

Postal Address: DP Manager, Destitution Project, Victoria Hall, Knowsley Street, Bolton. BL1 2AF

The controller for matters relating to safeguarding matters or complaints and discipline for DP is:

ADDRESS

Chair of Trustees

Destitution Project

Email: info@boltondp.org

Postal Address: DP Manager, Destitution Project, Victoria Hall, Knowsley Street, Bolton. BL1 2AF

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on September 12th  2018.  We have the right to update and amend the provisions of this notice to ensure continual compliance with data protection legislation.  We will provide you with copies of the new notice wherever it is practically possible to do so but please check the online notice regularly to see if any updates have been made.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with the DP.

THE DATA WE COLLECT ABOUT YOU 

Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  We may collect, use, store and transfer different kinds of personal data about our volunteers, employees, service users, those who are interested in and supportive of the work of the DP , individuals who provide services to us and individuals who contact us.

DATA GROUPS

We have grouped the different kinds of personal data together as follows:

·         Administrative Data includes details about you included in meeting Minutes; DP notices; application forms; invoices; supplier and contractor details; something that you said in a DP meeting that could identify you.

·         Image Data includes photographs taken of you where it is possible to identify you and images of you caught by any CCTV or similar devices at DP premises.

·         Contact Data includes home address, email address and telephone numbers e.g. information used to contact you.

·         Employment Data includes employment history, training records, pension information, details about next of kin and other details relating to your employment by DP.

·         Financial Data includes bank account and payment card details.

·         Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

·         Marketing and Communications Data includes your preferences in receiving information from us about DP events and fundraising and your communication preferences.

·         Member and Group Data includes details of membership of the DP, offices held, rotas, registration for DP groups and events, attendance information.

·         Special Categories of Data includes your race or ethnicity, your religious beliefs, sex life, sexual orientation, information about your health, also information about criminal convictions and offences in keeping with the Safeguarding Policy of the DP.

·         Tax Data includes national insurance numbers and other information that may be required by HMRC relating to gift aid donations and other tax related payments and receipts.

·         Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access any websites or social media operated by DP .

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to process gift aid payments). We will notify you if this is the case at the time.             

HOW YOUR PERSONAL DATA IS COLLECTED

 We use different methods to collect data from and about you including through:

  • Direct exchanges. You may choose to provide personal information to us direct e.g. by speaking to us at the DP Drop in Centre and events, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • join and take part in DP groups;
    • apply for paid or voluntary roles within the DP
    • offer to donate goods, services or money to DP
  • Automated technologies or interactions. As you interact with any website run by DP, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see website privacy notices and cookie policies available from such Local Websites for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties if required for our providing casework support to asylum seekers or refugees who request such assistance from DP               

HOW WE USE YOUR PERSONAL DATA

FAIR PROCESSING

The DP takes its obligations under data protection law (including the General Data Protection Regulation) seriously.  DP keeps personal data as up to date as possible and takes active steps to rectify any personal data we find to be incorrect.  DP stores and destroys personal data securely and does not collect or retain personal data which is in excess of our processing activities.  DP takes steps to protect all personal data (including Special Category Data) from loss, misuse, unauthorised access and disclosure by ensuring that appropriate measures are in place to protect personal data.

DP ensures that personal data is processed in accordance with the principles of the GDPR and is processed lawfully, fairly and in a transparent manner:

·         For specified, explicit and legitimate purposes and not processed in a manner which is incompatible with those purposes;

·         Accurately, relevantly and limited to what is necessary in relation to the purposes for which it is processed;

·         Kept accurate and where necessary kept up to date, with all reasonable steps being taken to ensure that all inaccurate data is erased or rectified without delay;

·         Is not kept longer than is necessary for the purposes for which the personal data is processed; and

·         In a manner that ensures appropriate security of the Personal Data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical and organisational measures.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests means the interests of DP in operating, supporting our service users, employees and volunteers and the communities we work in and conducting and managing our activities to enable us to fulfil the aims and objective of the DP. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DP data controller (contact above).
  • Where we need to perform the contract we are about to enter into or have entered into with you. Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract including employment contracts.
  • Where we need to comply with a legal or regulatory obligation.  Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
  • In rare cases we may need to use your personal data in the following circumstances:
    • Where we need to protect your vital interests e.g. in an emergency life or death situation where the emergency services are called to treat you when you are with us.  Vital interests means where it is necessary to use your personal data to protect your "vital interests" or those of another person (such as a child) in a life-or-death situation.
    • Where we need to perform a task carried out in the public interest e.g. in certain safeguarding situations.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sharing your personal data with third parties (including where Contact Details are made publically available through DP website and noticeboards, etc.), sending marketing communications to you via email or to legitimise dealing with Special Category Data. You have the right to withdraw consent at any time by contacting the appropriate DP Data Controller Contact (the DP Manager – contact details given above) although this will not prevent processing where the law allows us to process for a different reason in addition to consent.

SPECIAL CATEGORY DATA

Where data processing relates to Special Categories of Data (e.g. health information included in casework records or volunteer/employee personal files) the following processing conditions apply in addition to the legal basis identified in the table in the Annex to this privacy notice:

  • Explicit Consent has been given by the data subject;
  • Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
  • Processing relates to personal data manifestly made public by the data subject;
  • Processing is necessary for the establishment, exercise, defence of legal claims or where the courts are acting in their judicial capacity; or

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out in detail in the Annex to this privacy notice, in a table format, a description of the main ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.  Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the DP Data Controller (contact above) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table in the Annex.

NOTIFYING YOU ABOUT DP EVENTS AND FUNDRAISING

We like to notify our volunteers, service users, employees, those in regular contact with the DP  and third parties who support the DP about upcoming DP events and fundraising opportunities so that you can play as much of a role in the life of the DP as you choose from time to time. Most of the time we will let you know about such opportunities on the basis that we have a legitimate interest in doing so.  If we decide to contact you by email or telephone where you are registered with the telephone preference service we will provide you with choices as required to do so under data protection legislation and the Privacy and Electronic Communications Regulations 2003 (PECR).

THIRD-PARTY MARKETING

As a DP we will not share your personal data with any third parties for marketing purposes.

OPTING OUT

You can ask us to stop sending you messages about DP events or fundraising) at any time by contacting your DP Data Controller (the DP Manager - contact details given above).

COOKIES

If you are using the DP Website you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly. For more information about the cookies we use on the DP Website please see the DP website privacy notice.

CHANGE OF PURPOSE

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DP Data Controller (the DP Manager - contact details given above).   If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

SHARING PERSONAL DATA

Personal data will not be shared with third parties, other than those listed below, unless we are legally obliged to do so or:

  • with your explicit consent;
  • it is necessary for law enforcement purposes; or
  • it is necessary to protect our rights, property or safety of our Trustees, volunteers or employees.
  • We may have to share your personal data with the parties set out below for the purposes set out in the table in the Annex: external third parties such as:
    • Any third party groups who provide support for DP in providing services to service users which they serve.
    • Professional advisers including lawyers, surveyors, bankers, auditors and insurers based in the UK who provide legal, surveying, consultancy, banking, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We will ask all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

TRANSFER OF PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA (‘EEA’)

We may at times transfer and process personal data outside of the EEA.  Storing, publishing or transmitting personal data via the internet, (this includes by email), is not completely secure and therefore whilst DP take all reasonable and necessary precautions to protect personal data from unauthorised access, you acknowledge that there is a risk that your personal data may be transferred and accessed outside of the EEA.

DATA SECURITY 

We implement reasonable and appropriate security measures against unlawful or unauthorised processing of personal data and against the accidental loss of, or damage to, personal data in accordance with our internal data security policy. In addition, we limit access to your personal data to those employees and volunteers and essential Third Parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  We have put in place reasonable and appropriate procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data 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.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data:  see the details about Request Erasure below for further information.  In some circumstances we may choose to anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS 

Unless personal data is subject to an exemption under GDPR, such as it is subject to the prevention, investigation, detection or prosecution of a criminal offence, you have the following rights with regards to your personal data:

·         Where consent is used as the legal basis for processing personal data, you have the right to withdraw consent to the data processing at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or processing carried out using an alternative legal basis such as performance of a contract or legal obligation;

·         The right to request a copy of the personal data which the DP hold about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you would like to exercise this right then please contact the data  controller (DP Manager – contact details given above) and you will be sent the appropriate form to complete. 

·         The right to request that the DP corrects any Personal Data which is found to be inaccurate. Note that we may need to verify the accuracy of the new data you provide to us;

·         The right to request that the DP erases any Personal Data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

·         Where consent or the performance of a contract is used as the legal basis for processing Personal Data, you have the right to request the transfer of your personal data to you or to a Third Party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you and this right is unlikely to apply to personal data held by us.

·         The right to request for a restriction on data processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

·         Where legitimate interest is used as the legal basis for processing Personal Data, you have the right to object to the processing of personal data where there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Note that in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

·         The right to lodge a complaint with the Information Commissioners Office (ICO).

Contacting the ICO

Further information, guidance and advice is available from the ICO at:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113

Web: https://ico.org.uk/global/contact-us/

 If you wish to exercise any of the rights set out above, please contact your DP Data Controller (via the DP Manager - contact details above).

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY 

“controller” is the controller described in Section 1 of this privacy notice.

“data subject” is a living, identified or identifiable individual about whom personal data is held. e.g. our members, volunteers, lay employees, those who join us in worship and/or those who are interested in and supportive of the work of the DP  and third parties such as community groups who use our buildings and other third parties.

“explicit consent” is a very clear and specific statement of consent.

GDPR means the General Data Protection Regulation ((EU) 2016/679). Personal data is subject to the safeguards specified in the GDPR.

“lawful bases” are the five lawful grounds on which we can lawfully process personal data set out under Article 6 of GDPR. The lawful basis or bases on which we rely are set out under Section 4 of this privacy notice.

“DP Data Controller contact” ” is the individual at the DP who is responsible for day to day administration of data protection matters whose details above  or, in their absence, the Chair of the DP Trustees .

“ DP”  is the Destitution Project

“personal data” is any information identifying a living individual or information relating to an individual that can be identified from that information/data (alone or in combination with other information in your hands or that can reasonably be accessed). Personal Data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour. Personal information includes an individual’s name, address, date of birth, telephone number, email address, a photograph or disability, health or ethnicity data.

“Processing” “processed” or “process” means any activity that involves the use of personal data. It includes obtaining, recording or holding the data, or carrying out any activity or set of activities on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring personal data to third parties.  E.g. sharing member information by email and shredding when information is no longer required.

ANNEX 

Purposes for which we will use your personal data

 

Purpose/Activity

Type of data

(see section above entitled ‘DATA GROUPS’)

Lawful basis

for processing

Contact

 To publicise details of relevant employees and volunteers.

(a) Contact

(b) Identity

 (c) Member and Group

(a) Necessary for our legitimate interests (to operate as a charity and enable relevant  third parties to contact specific role holders in DP)

(b) Consent (where information about you is made public to third parties and you are not an employee Trustee or manager we will rely on legitimate interests)

Contact

To notify you about DP services, activities and events that may be of interest to you or which you have signed up



 

(a) Contact

(b) Identity

(c) Image

(d) Marketing and Communications

(e) Member and Group

(f) Technical

(a) Necessary for our legitimate interests (to fulfil the aims and objectives of the charity by engaging with current and prospective supporters of DP, developing activities and events  and general fundraising (in all cases in respect of individuals who have a continuing relationship DP)

(b) Consent (where there is no continuing relationship with DP and we cannot rely on legitimate interests as described above and contact you by any electronic form of communication and/or telephone where you are registered with the telephone preference service).

Lists

To keep and maintain records of:

(a) volunteers, service users and visitors to the DP Drop In Centre and DP activities, groups and events

(b) Trustees, Managers, employees

(a) Contact

(b) Identity

(c) Member and Group



 

(a) Necessary for our legitimate interests (to operate as an charity organisation, keep our records updated, study how our membership changes over time, identify the needs of the groups we seek to help and support our members)

(b) Performance of a contract with you

Administration

To administer our charity including planning our activities, managing and maintaining DP premises and equipment, keeping accounts and tax records including Gift Aid, taking audits and recording decisions reached at meetings.   

To administer, run and protect our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Administrative

(b) Contact

(c) Identity

(d) Financial

(e) Member and Group

(f) Tax

(g) Technical

 

(a) Necessary for our legitimate interests (for running our charity, fulfilling our obligations under charity law, complying with the policies and procedures of the Charity and providing of support to members and the groups we assist.

(b) Performance of a contract with you

(c) Necessary to comply with a legal obligation

(d) Details provided in relevant website privacy notices.

Employment

To administer applications for job vacancies and administer and manage our relationship with our employees.

(a) Contact

(b) Identity

(c) Employment

(d) Financial

(e) Special Category (e.g. right to rent under the Immigration Act)

(f) Tax

(a) Necessary for our legitimate interests (for running our charity, fulfilling employer responsibilities and looking after our employees)


(b) Performance of a contract with you

(c) necessary to comply with a legal obligation

Safeguarding

To record and maintain safeguarding records, self-declarations, incident reports, and carry out volunteer checks and Disclosure and Barring Service (DBS) checks, as and when necessary.

(a) Contact

(b) Identity

(c) Employment

(d) Special Category

(a) Necessary for our legitimate interests (for ensuring and demonstrating compliance with Safeguarding Policy and Practice to protect accompanied children, young people and vulnerable adults within DP and its activities

(b) Performance of a contract with you

(c) Necessary to comply with a legal obligation

(d) Needed in the public interest

Security

To record and use images, as necessary.

(a) Image

(b) Identity

 

(a) Necessary for our legitimate interests (to keep DP premises and our volunteers, employees and third parties secure)

Targeted marketing/fundraising

To contact you personally about specific fundraising activities/ initiatives and/or with targeted marketing material.

e.g. where we contact you personally/ target you with a request for a donation to DP

(a) Contact

(b) Identity

(c) Marketing and Communications

(d) Member and Group

Consent

 

The Destitution Project (DP) respects your privacy and is committed to protecting your personal information (personal data). This privacy notice lets you know how we look after your personal data which either you provide to us or we obtain and hold about you and it tells you about your privacy rights and how the law protects you.

This privacy notice is available online on our website (https://www.boltondp.org/). Alternatively you can request a copy by emailing the DP Manager at This email address is being protected from spambots. You need JavaScript enabled to view it. .  Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

PURPOSE OF THIS PRIVACY NOTICE

The Destitution Project (DP) seeks to advance the education and relieve financial hardship among asylum seekers and refugees, and to provide them with suitable facilities for recreation and other leisure.  Our services focus around a weekly Drop in Centre held at Victoria Hall in Bolton.  We are a registered charity, dependent on the help of volunteers and donations from range of sources to achieve our objectives. 

This privacy notice aims to give you information on how DP collects and processes your personal data which either you provide to us or we obtain and hold about you including any data you may provide when you become a volunteer, donor or service user.    It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or dealing with personal data about you (e.g. website privacy notices and employment privacy notices) so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

The DP is a registered charity in Bolton in the United Kingdom (Charity # 1109703). This privacy notice is issued on behalf of DP and when we mention, “we”, “us” or “our” in this privacy notice, we are referring to the charity DP that is responsible for processing your data.

Trustees for DP are the controller and responsible for general data protection issues arising in respect of day to day matters such as lists of staff and volunteers, service users. The Chair of the DP Trustees is the controller and responsible for data protection matters concerning safeguarding and complaints and discipline issues. When we mention the controller we mean the relevant controller.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the relevant contact for the DP using the details set out below.

CONTACT DETAILS

Our full details are:

The contact for routine, day to day data protection matters for DP is:

The DP Manager

Destitution Project

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Postal Address: DP Manager, Destitution Project, Victoria Hall, Knowsley Street, Bolton. BL1 2AF

The controller for matters relating to safeguarding matters or complaints and discipline for DP is:

ADDRESS

Chair of Trustees

Destitution Project

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Postal Address: DP Manager, Destitution Project, Victoria Hall, Knowsley Street, Bolton. BL1 2AF

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on September 12th  2018.  We have the right to update and amend the provisions of this notice to ensure continual compliance with data protection legislation.  We will provide you with copies of the new notice wherever it is practically possible to do so but please check the online notice regularly to see if any updates have been made.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with the DP.

THE DATA WE COLLECT ABOUT YOU 

Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  We may collect, use, store and transfer different kinds of personal data about our volunteers, employees, service users, those who are interested in and supportive of the work of the DP , individuals who provide services to us and individuals who contact us.

DATA GROUPS

We have grouped the different kinds of personal data together as follows:

·         Administrative Data includes details about you included in meeting Minutes; DP notices; application forms; invoices; supplier and contractor details; something that you said in a DP meeting that could identify you.

·         Image Data includes photographs taken of you where it is possible to identify you and images of you caught by any CCTV or similar devices at DP premises.

·         Contact Data includes home address, email address and telephone numbers e.g. information used to contact you.

·         Employment Data includes employment history, training records, pension information, details about next of kin and other details relating to your employment by DP.

·         Financial Data includes bank account and payment card details.

·         Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

·         Marketing and Communications Data includes your preferences in receiving information from us about DP events and fundraising and your communication preferences.

·         Member and Group Data includes details of membership of the DP, offices held, rotas, registration for DP groups and events, attendance information.

·         Special Categories of Data includes your race or ethnicity, your religious beliefs, sex life, sexual orientation, information about your health, also information about criminal convictions and offences in keeping with the Safeguarding Policy of the DP.

·         Tax Data includes national insurance numbers and other information that may be required by HMRC relating to gift aid donations and other tax related payments and receipts.

·         Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access any websites or social media operated by DP .

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to process gift aid payments). We will notify you if this is the case at the time.             

HOW YOUR PERSONAL DATA IS COLLECTED

 We use different methods to collect data from and about you including through:

  • Direct exchanges. You may choose to provide personal information to us direct e.g. by speaking to us at the DP Drop in Centre and events, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • join and take part in DP groups;
    • apply for paid or voluntary roles within the DP
    • offer to donate goods, services or money to DP
  • Automated technologies or interactions. As you interact with any website run by DP, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see website privacy notices and cookie policies available from such Local Websites for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties if required for our providing casework support to asylum seekers or refugees who request such assistance from DP               

HOW WE USE YOUR PERSONAL DATA

FAIR PROCESSING

The DP takes its obligations under data protection law (including the General Data Protection Regulation) seriously.  DP keeps personal data as up to date as possible and takes active steps to rectify any personal data we find to be incorrect.  DP stores and destroys personal data securely and does not collect or retain personal data which is in excess of our processing activities.  DP takes steps to protect all personal data (including Special Category Data) from loss, misuse, unauthorised access and disclosure by ensuring that appropriate measures are in place to protect personal data.

DP ensures that personal data is processed in accordance with the principles of the GDPR and is processed lawfully, fairly and in a transparent manner:

·         For specified, explicit and legitimate purposes and not processed in a manner which is incompatible with those purposes;

·         Accurately, relevantly and limited to what is necessary in relation to the purposes for which it is processed;

·         Kept accurate and where necessary kept up to date, with all reasonable steps being taken to ensure that all inaccurate data is erased or rectified without delay;

·         Is not kept longer than is necessary for the purposes for which the personal data is processed; and

·         In a manner that ensures appropriate security of the Personal Data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical and organisational measures.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests means the interests of DP in operating, supporting our service users, employees and volunteers and the communities we work in and conducting and managing our activities to enable us to fulfil the aims and objective of the DP. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DP data controller (contact above).
  • Where we need to perform the contract we are about to enter into or have entered into with you. Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract including employment contracts.
  • Where we need to comply with a legal or regulatory obligation.  Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
  • In rare cases we may need to use your personal data in the following circumstances:
    • Where we need to protect your vital interests e.g. in an emergency life or death situation where the emergency services are called to treat you when you are with us.  Vital interests means where it is necessary to use your personal data to protect your "vital interests" or those of another person (such as a child) in a life-or-death situation.
    • Where we need to perform a task carried out in the public interest e.g. in certain safeguarding situations.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sharing your personal data with third parties (including where Contact Details are made publically available through DP website and noticeboards, etc.), sending marketing communications to you via email or to legitimise dealing with Special Category Data. You have the right to withdraw consent at any time by contacting the appropriate DP Data Controller Contact (the DP Manager – contact details given above) although this will not prevent processing where the law allows us to process for a different reason in addition to consent.

SPECIAL CATEGORY DATA

Where data processing relates to Special Categories of Data (e.g. health information included in casework records or volunteer/employee personal files) the following processing conditions apply in addition to the legal basis identified in the table in the Annex to this privacy notice:

  • Explicit Consent has been given by the data subject;
  • Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;
  • Processing relates to personal data manifestly made public by the data subject;
  • Processing is necessary for the establishment, exercise, defence of legal claims or where the courts are acting in their judicial capacity; or

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out in detail in the Annex to this privacy notice, in a table format, a description of the main ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.  Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the DP Data Controller (contact above) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table in the Annex.

NOTIFYING YOU ABOUT DP EVENTS AND FUNDRAISING

We like to notify our volunteers, service users, employees, those in regular contact with the DP  and third parties who support the DP about upcoming DP events and fundraising opportunities so that you can play as much of a role in the life of the DP as you choose from time to time. Most of the time we will let you know about such opportunities on the basis that we have a legitimate interest in doing so.  If we decide to contact you by email or telephone where you are registered with the telephone preference service we will provide you with choices as required to do so under data protection legislation and the Privacy and Electronic Communications Regulations 2003 (PECR).

THIRD-PARTY MARKETING

As a DP we will not share your personal data with any third parties for marketing purposes.

OPTING OUT

You can ask us to stop sending you messages about DP events or fundraising) at any time by contacting your DP Data Controller (the DP Manager - contact details given above).

COOKIES

If you are using the DP Website you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly. For more information about the cookies we use on the DP Website please see the DP website privacy notice.

CHANGE OF PURPOSE

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DP Data Controller (the DP Manager - contact details given above).   If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

SHARING PERSONAL DATA

Personal data will not be shared with third parties, other than those listed below, unless we are legally obliged to do so or:

  • with your explicit consent;
  • it is necessary for law enforcement purposes; or
  • it is necessary to protect our rights, property or safety of our Trustees, volunteers or employees.
  • We may have to share your personal data with the parties set out below for the purposes set out in the table in the Annex: external third parties such as:
    • Any third party groups who provide support for DP in providing services to service users which they serve.
    • Professional advisers including lawyers, surveyors, bankers, auditors and insurers based in the UK who provide legal, surveying, consultancy, banking, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We will ask all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

TRANSFER OF PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA (‘EEA’)

We may at times transfer and process personal data outside of the EEA.  Storing, publishing or transmitting personal data via the internet, (this includes by email), is not completely secure and therefore whilst DP take all reasonable and necessary precautions to protect personal data from unauthorised access, you acknowledge that there is a risk that your personal data may be transferred and accessed outside of the EEA.

DATA SECURITY 

We implement reasonable and appropriate security measures against unlawful or unauthorised processing of personal data and against the accidental loss of, or damage to, personal data in accordance with our internal data security policy. In addition, we limit access to your personal data to those employees and volunteers and essential Third Parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  We have put in place reasonable and appropriate procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data 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.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data:  see the details about Request Erasure below for further information.  In some circumstances we may choose to anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS 

Unless personal data is subject to an exemption under GDPR, such as it is subject to the prevention, investigation, detection or prosecution of a criminal offence, you have the following rights with regards to your personal data:

·         Where consent is used as the legal basis for processing personal data, you have the right to withdraw consent to the data processing at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or processing carried out using an alternative legal basis such as performance of a contract or legal obligation;

·         The right to request a copy of the personal data which the DP hold about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you would like to exercise this right then please contact the data  controller (DP Manager – contact details given above) and you will be sent the appropriate form to complete. 

·         The right to request that the DP corrects any Personal Data which is found to be inaccurate. Note that we may need to verify the accuracy of the new data you provide to us;

·         The right to request that the DP erases any Personal Data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

·         Where consent or the performance of a contract is used as the legal basis for processing Personal Data, you have the right to request the transfer of your personal data to you or to a Third Party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you and this right is unlikely to apply to personal data held by us.

·         The right to request for a restriction on data processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

·         Where legitimate interest is used as the legal basis for processing Personal Data, you have the right to object to the processing of personal data where there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Note that in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

·         The right to lodge a complaint with the Information Commissioners Office (ICO).

Contacting the ICO

Further information, guidance and advice is available from the ICO at:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113

Web: https://ico.org.uk/global/contact-us/

 If you wish to exercise any of the rights set out above, please contact your DP Data Controller (via the DP Manager - contact details above).

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY 

“controller” is the controller described in Section 1 of this privacy notice.

“data subject” is a living, identified or identifiable individual about whom personal data is held. e.g. our members, volunteers, lay employees, those who join us in worship and/or those who are interested in and supportive of the work of the DP  and third parties such as community groups who use our buildings and other third parties.

“explicit consent” is a very clear and specific statement of consent.

GDPR means the General Data Protection Regulation ((EU) 2016/679). Personal data is subject to the safeguards specified in the GDPR.

“lawful bases” are the five lawful grounds on which we can lawfully process personal data set out under Article 6 of GDPR. The lawful basis or bases on which we rely are set out under Section 4 of this privacy notice.

“DP Data Controller contact” ” is the individual at the DP who is responsible for day to day administration of data protection matters whose details above  or, in their absence, the Chair of the DP Trustees .

“ DP”  is the Destitution Project

“personal data” is any information identifying a living individual or information relating to an individual that can be identified from that information/data (alone or in combination with other information in your hands or that can reasonably be accessed). Personal Data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour. Personal information includes an individual’s name, address, date of birth, telephone number, email address, a photograph or disability, health or ethnicity data.

“Processing” “processed” or “process” means any activity that involves the use of personal data. It includes obtaining, recording or holding the data, or carrying out any activity or set of activities on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring personal data to third parties.  E.g. sharing member information by email and shredding when information is no longer required.

ANNEX 

Purposes for which we will use your personal data

 

Purpose/Activity

Type of data

(see section above entitled ‘DATA GROUPS’)

Lawful basis

for processing

Contact

 To publicise details of relevant employees and volunteers.

(a) Contact

(b) Identity

 (c) Member and Group

(a) Necessary for our legitimate interests (to operate as a charity and enable relevant  third parties to contact specific role holders in DP)

(b) Consent (where information about you is made public to third parties and you are not an employee Trustee or manager we will rely on legitimate interests)

Contact

To notify you about DP services, activities and events that may be of interest to you or which you have signed up



 

(a) Contact

(b) Identity

(c) Image

(d) Marketing and Communications

(e) Member and Group

(f) Technical

(a) Necessary for our legitimate interests (to fulfil the aims and objectives of the charity by engaging with current and prospective supporters of DP, developing activities and events  and general fundraising (in all cases in respect of individuals who have a continuing relationship DP)

(b) Consent (where there is no continuing relationship with DP and we cannot rely on legitimate interests as described above and contact you by any electronic form of communication and/or telephone where you are registered with the telephone preference service).

Lists

To keep and maintain records of:

(a) volunteers, service users and visitors to the DP Drop In Centre and DP activities, groups and events

(b) Trustees, Managers, employees

(a) Contact

(b) Identity

(c) Member and Group



 

(a) Necessary for our legitimate interests (to operate as an charity organisation, keep our records updated, study how our membership changes over time, identify the needs of the groups we seek to help and support our members)

(b) Performance of a contract with you

Administration

To administer our charity including planning our activities, managing and maintaining DP premises and equipment, keeping accounts and tax records including Gift Aid, taking audits and recording decisions reached at meetings.   

To administer, run and protect our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Administrative

(b) Contact

(c) Identity

(d) Financial

(e) Member and Group

(f) Tax

(g) Technical

 

(a) Necessary for our legitimate interests (for running our charity, fulfilling our obligations under charity law, complying with the policies and procedures of the Charity and providing of support to members and the groups we assist.

(b) Performance of a contract with you

(c) Necessary to comply with a legal obligation

(d) Details provided in relevant website privacy notices.

Employment

To administer applications for job vacancies and administer and manage our relationship with our employees.

(a) Contact

(b) Identity

(c) Employment

(d) Financial

(e) Special Category (e.g. right to rent under the Immigration Act)

(f) Tax

(a) Necessary for our legitimate interests (for running our charity, fulfilling employer responsibilities and looking after our employees)


(b) Performance of a contract with you

(c) necessary to comply with a legal obligation

Safeguarding

To record and maintain safeguarding records, self-declarations, incident reports, and carry out volunteer checks and Disclosure and Barring Service (DBS) checks, as and when necessary.

(a) Contact

(b) Identity

(c) Employment

(d) Special Category

(a) Necessary for our legitimate interests (for ensuring and demonstrating compliance with Safeguarding Policy and Practice to protect accompanied children, young people and vulnerable adults within DP and its activities

(b) Performance of a contract with you

(c) Necessary to comply with a legal obligation

(d) Needed in the public interest

Security

To record and use images, as necessary.

(a) Image

(b) Identity

 

(a) Necessary for our legitimate interests (to keep DP premises and our volunteers, employees and third parties secure)

Targeted marketing/fundraising

To contact you personally about specific fundraising activities/ initiatives and/or with targeted marketing material.

e.g. where we contact you personally/ target you with a request for a donation to DP

(a) Contact

(b) Identity

(c) Marketing and Communications

(d) Member and Group

Consent

 

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