1. Introduction
This Privacy Notice sets out information in relation to the processing of data and how privacy of data is protected.
The privacy and security of your personal information is extremely important to PROPS North East.
We want to make sure you are informed and can be confident about giving us your information.
We, PROPS North East (PNE), are the ‘controllers’ of the information which we collect about you (‘personal data’). Being controllers of your personal data, we are responsible for how your data is processed.
The word ‘process’ covers most things that can be done with personal data, including collection, storage, use and destruction of that data.
This notice explains why and how we process your data, and explains the rights you have around your data, including the right to access it, and to object to the way it is processed. Please see the section on ‘Your rights as a data subject’ for more information.
We are a registered charity (1146582) and company limited by guarantee (07902767), our contact details are:
Address: Registered Address – PROPS North East, The Linskill Centre, Linskill Terrace, North Shields, Tyne & Wear, NE30 2AY.
Satellite Office – PROPS North East, Fenham Library, Fenham Hall Drive, Newcastle NE4 9XD.
Email: [email protected]
Telephone number: 0191 2263440
Our Data Protection Lead is Helen Thompson, the Chief Executive, who you can contact at the head office address.
2. Scope
This policy applies if you’re a carer, substance user, volunteer, trustee, donor or use any of our services, visit our website, email, call or write to us. In certain circumstances we may also provide an extra privacy notice, which we will always inform you about.
3. Young People
If you are under the age of 16 and would like to use any of the support services we offer, or are referred to us, we will need to use your personal data so we can help you.
An example of personal data would be your name, or email address. Please see section 6 of this policy for more information.
If you are worried, or don’t understand any part of this policy, please talk to us and we will explain how we will use your information and what rights you have.
4. Responsibility for Implementation
All staff, volunteers and trustees are responsible for the implementation of this policy, with overall responsibility resting with the Board of Trustees.
5. Dissemination
PROPS North East disseminates policies and procedures to relevant staff, volunteers and Trustees by:
- Hard copies of current policies and procedures provided during induction.
- All policies and procedures available to staff, trustees and volunteers on the server.
- Updated/new policies and procedures circulated by email, and discussed in staff meetings, volunteer meetings and/or Trustee meetings as appropriate.
- Policies and Procedures a standard item on staff and Trustee meeting agendas.
As this Privacy Notice also applies to carers and anyone contacting us with an enquiry it will also be available on our website.
6. What do we mean by personal data?
‘Personal data‘ is any information that can be used to identify a living person.
This data can include your name, contact details, and other information we gather as part of our relationship with you. It can also include ‘special categories’ of data, which is information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation.
The collection and use of these types of data is subject to strict controls. Similarly, information about criminal convictions and offences is also limited in the way it can be processed.
We keep special category data in accordance with Article 9, section d of the General Data Protection Regulations, which details the legal requirements for charities to hold this type of information.
We are committed to protecting your personal data, whether it is ‘special categories’ or not, and we only process data if we need to for a specific purpose, as explained below.
7. How we collect your personal data
a. Information provided by you
We collect your personal data mostly through our contact with you, and the data is usually provided by you when you: enquire about our services; register as a carer or substance user with PROPS North East; tell us about your caring role, access services and attend events; donate or fundraise on our behalf or other things that we do in the course of our work.
b. Information provided by other people
In some instances, we may receive data about you from other people/organisations e.g. the local authority, treatment services etc, if they refer you to us for support.
c. Personal data created by your involvement with us
Your activities and involvement with us will result in personal data being created. This could include details of the events and activities sessions you’ve attended, records of the support we’ve provided, how you’ve helped us by volunteering etc. If you decide to donate to us, then we’ll keep records of when and how much you give.
8. How we use your information
Any information we hold about you will be stored securely and treated in accordance with the relevant legislation (currently the General Data Protection Regulations (GDPR).
- In general terms, we process your data in order to manage our relationship with you. We will use the information that you give to us:
- To send you information that you have asked for
- To understand your situation so we can offer you individually tailored support to meet your needs
- To contact you about support services which may help you in your caring role
- To inform you about events, fundraising, campaigning and our other work
- To administer your donation or support your fundraising, including processing gift aid
- To keep a record of your relationship with us
- To ensure we know how you prefer to be contacted
More detailed information on how we use your personal information, including how long we keep it for can be found below.
What we collect/generate Why we hold it How long it will be kept for Our lawful basis
Service delivery data
Information we collect in order to support you as a carer/substance user.
This includes but is not limited to:
Details about you and the person you care for/or for you, including where you live, how to contact you, which of our services have helped you in the past, etc.
This may include special category data relating to the health of yourself. We keep this information to understand your situation so that we can offer you individually tailored support to meet your needs and to contact you about support services which may help you. The majority of your data will be kept in our secure database for as long as you are supported by our charity.
We will keep your data for three months after your work with us comes to an end.
if we lose contact with you, your record will be archived and kept for a further 7 years before it is deleted. This means that if you contact us within that 7 year period, we could find the information easily, if you needed our support again. Performance of a contract with regards to personal data.
In order to provide a personalised support service to you, we will need to collect information surrounding the impact substance misuse has in your life.
In this instance, our lawful basis is because processing is necessary for health and social care purposes.
If you do not wish to provide this information, we will not be able to offer this personalised service to you.
For all other categories of special category data, we will ask for your consent.
Marketing Data
This is information we use to send you newsletters and other updates. This includes but is not limited to:
Your postal address, email, phone number and contact preferences.
We may also process special category data for marketing purposes, e.g. to identify carers who have more than one caring role and require additional services.
We keep this information so we can send you general information on our events and activities.
This counts as marketing under GDPR. We will ask your permission of how you would like to receive this information.
We only send newsletters and updates if you have opted in for them. We generate these mailing lists from our secure database (see above for retention period).
If you no longer wish to receive marketing from us, please let us know by contacting [email protected]
and we will remove you from the mailing lists within two weeks of receiving your request to unsubscribe.
Consent
Monitoring data
Information we generate to monitor our service, report to our funders and prove that we are meeting our charitable aims and objectives.
The reports we generate are statistical, and it is not possible to identify individuals from the completed report.
This includes special category data such as health conditions, ethnicity, sexuality etc.
We use your data to generate statistical information which we use to report to our funders.
We also use this data to check whether we are reaching all parts of the community and to identify any gaps in our services.
The monitoring data will be kept in our secure database for as long as you are supported by our charity.
Either three months after support is no longer required by you, or if we lose contact with you, your records will be archived and kept for a further 7 years before it is deleted. This means that if you contact us within that 7 year period, we could find the information easily, if you needed our support again.
Not applicable as this data is not classed as personal data.
Financial Information
If you make a donation, we will keep financial records of any payments made or received.
This information includes but is not limited to:
Dates and amounts of payments, the account the payment was made to, Gift Aid eligibility etc.
We use this information to meet our legal requirement to keep accurate financial records.
We are legally obliged to keep this information for a minimum of 7 years.
Performance of a contract or legal obligation to keep financial records
Photo, Video and Written Statements
We will only use photos and videos of you with your express permission.
This includes any written evaluations and feedback statements you give us whilst accessing parts of our service e.g. group,
1 to 1, respite evaluations. We will always explain how we intend to use it.
We use photos videos and written statements to raise awareness and to promote our services and the benefits to carers who access support.
We keep copies of photos and videos in our archive on our secure server for 2 years, or as otherwise agreed with you in writing, after which it is deleted.
We are legally obliged to keep copies of written statements for a minimum of 7 years.
Once images or videos are uploaded to a website or shared on social media, we may not have the ability to remove images, and although every reasonable effort will be made, we have no control over how images/media is distributed on other social media sites.
PROPS North East are not to be held responsible for any third parties sharing information or images. Consent
Historic Data
Archived records, i.e. those of people who no longer have a caring role or who we have lost touch with.
This may include special categories of data as specified above.
We hold this information because we know people often are significantly impacted by their caring and recovery can be complex. It is helpful for us to have information on the support you’ve had in the past if you request our support in future.
Archive records are kept on our secure database for seven years. If we have not heard from you within 7 years they are securely deleted
Legitimate business interest in retaining information for you, so that we can support you in the best way possible, if you need to come back to us in the seven year period for support.
At times, we may further process data which we have already collected. We will only do this if the new purpose for processing it further is compatible with the original purpose that the data was collected for. We will tell you about any further processing before carrying it out.
To provide some of our services we need to collect and process additional information about you. We will always make it clear when we are doing this. This could include, but is not limited, to the following:
Complementary Therapy
If you are referred for complementary therapies, the therapist will need to take more detailed information about your physical and mental health to ensure we provide you with the best possible service. This information is kept with your record in our secure database (see above for retention details).
Counselling Service
If you are referred to our counselling service your counsellor may keep records about your counselling sessions. These are separate and confidential, with only the counsellor and their line manager having access. They are confidentially disposed of after seven years.
Volunteering
If you choose to volunteer with us then we will collect extra information about you (e.g. references, criminal records checks, details of emergency contacts, medical conditions etc.). This information will be retained for legal or contractual reasons, to protect us (including in the event of an insurance or legal claim) and for safeguarding purposes.
9. Who we share your data with
We will not pass your personal contact details to other people or organisations or discuss details of your caring role or the support you receive from us, without first obtaining your consent, e.g. we will ask your permission to refer you to another organisation for additional support or to discuss something with external professionals supporting you and your family.
However, where there appears to be a clear risk to your or someone else’s safety we have a legal duty to contact relevant authorities to address this. Where appropriate, we will inform you before we do so. You can find out more about this in our Safeguarding Policies and Procedures which are available on request.
For some processing purposes we use third party software and systems, which means we need to pass on some of your data to external recipients. The type of information we may share, and for what purpose, includes but is not limited to:
Contact and monitoring information
We use third parties to help us process some of our data, this includes but is not limited to: Mailchimp to send newsletters and updates by email; Just Giving to collect and process donations; Google Analytics for website statistics; Survey Monkey to collect feedback on our services. We have GDPR compliant agreements with every third party we use.
10. International transfers
Many of our external third parties are based outside the European Economic Area (EEA), for example, Mail Chimp and we use Google Analytics, so their processing of your personal data will involve a transfer of data outside the EEA. We only transfer personal data outside of the EEA in compliance with Chapter V of the GDPR.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
11. How we store your data
Your personal data is held in both hard copy and electronic formats.
Electronic data, including emails, is stored on our servers, which are located in the UK and on our software suppliers’ servers. In addition, we securely back up our electronic data to our IT provider, who also ensures electronic data is disposed of securely when it is no longer needed. To ensure compliance we have a written GDPR compliant contract with our software and IT providers.
Hard copy data is stored securely in locked offices and storage spaces within PNE. We employ a confidential shredding service to ensure secure disposal of all hard copy data.
12. Cookies
Cookies on our website are covered by a separate policy which is available at https://www.newcastleprops.org.uk/cookies/.
13. Your rights as a data subject
As a data subject, you have the following rights in relation to your personal data processed by us:
- To be informed about how your data is handled;
- To gain access to your personal data;
- To have errors or inaccuracies in your data changed;
- To have your personal data erased, in limited circumstances;
- To object to the processing of your personal data for marketing purposes or when the processing is based on the public interest or other legitimate interests;
- To restrict the processing of your personal data, in limited circumstances;
- To obtain a copy of some of your data in a commonly used electronic form (sometimes known as data portability), in limited circumstances;
- Rights around how you are affected by any profiling or automated decisions.
a. Withdrawing consent
If we are relying on your consent to process your data, you have the right to withdraw your consent at any time.
b. Exercising your rights, queries and complaints
For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Lead – Claire Robinson at PROPS North East.
c. Complaints to the Information Commissioner
You have a right to complain to the Information Commissioner’s Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk/.