Volunteer Centre Tower Hamlets is committed to protecting the privacy and the security of your personal data. We are a data controller and this Privacy Notice explains the types of personal data we may collect about you when you interact with us. It also explains how we store and handle that data and keep it safe.
First of all, here are a few terms we may use in this document to explain ourselves:
“Personal data” is information relating to you as a living, identifiable individual. This could be anything from a postal address to a telephone number or a date of birth.
“Processing” your data includes various operations that may be carried out on your data, including collecting, recording, organising, using, disclosing, storing and deleting it.
A “condition for processing data” is our justification for processing the data. For example we may ask you to agree for us to send you certain information. In this instance we may ask you for your consent.
The law requires us:
• to process your data in a lawful, fair and transparent way
• to only collect your data for explicit and legitimate purposes
• to only collect data that is relevant, and limited to the purpose(s) we have told you about
• to ensure that your data is accurate and up-to-date
• to ensure that your data is only kept as long as necessary for the purpose(s) we have told you about
• to ensure that appropriate security measures are used to protect your data.
The following sections should answer any questions you have, but if they do not, please contact us – our details are at the end of this document.
It is likely that we may update this Privacy Notice from time to time. You are welcome to come back and check this at any time, or contact us by any of the means shown below.
2. What we do as an organisation
Volunteer Centre Tower Hamlets (VCTH) is the Volunteer Centre for the London Borough of Tower Hamlets. Our mission is to provide a comprehensive volunteering infrastructure service to non-profit groups and to communities in Tower Hamlets, to increase the quality, quantity and impact of volunteering in the borough.
Our 5 core functions are:
- Brokerage – ensuring that the general public and all sectors are better informed
about and have access to an effective and efficient volunteering brokerage service
- Good Practice Development – helping organisations to improve or attain positive
consistency in their volunteering programmes
- Developing Volunteering Opportunities - increasing and improving the quantity,
quality, and diversity of volunteering locally
- Voice of Volunteering – creating an increased awareness of the issues impacting
- Strategic Development of Volunteering - engagement with local networks and
decision-makers to create a positive environment in which volunteering is flourishing.
We also host the Voluntary Sector Children and Youth Forum (VSCYF), supporting voluntary and community sector organisations that provide services to children and young people in Tower Hamlets. Most of these organisations involve volunteers in their work.
For these reasons we may process your data in our Legitimate Interest as an organisation. You’ll have an opportunity to opt-out of certain communications we send you, but some which relate to the services we provide or where we have a legal obligation cannot be stopped.
3. Why we need to process data
The law on data protection sets out a number of different reasons or conditions for which an organisation may collect and process your personal data. When collecting your personal data, we will always make clear to you, which data is necessary for each purpose we have told you about. Most commonly, we will process your data on the following lawful grounds:
In specific situations, we can collect and process your data with your consent. This may include when you agree to receive an email about our services, or an event we may hold. When you make an enquiry online, for example, we may present a short privacy notice and ask you to confirm your agreement. We’ll make it easy and very clear about our intended use of your data. If you are not clear, then please contact us for your information. You can easily stop any communications at any time when you have given your consent by unsubscribing or opting out.
- Our contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations. If a law says we must process your information, we have no alternative. This might be, for example, if you worked for us, or we deliver services to you where an agreement might be enforced in a court.
- Other legal compliance
If the law requires it, we may need to collect and process your data. This might be when a criminal act is detected, or matters relating to taxation, for example. Again, we have no option but to comply with the law.
- Legitimate interest
In certain circumstances, we require your data to pursue our legitimate interests in a way which might reasonably be expected when we pursue our aims and objectives as an organisation and as detailed in section 2 of this policy. When we process data in this way we will make sure there isn’t a chance of any material impact on your rights, freedom or interests.
We have a legitimate interest in maintaining a record of our activities, the people with whom we interact and help, our organisational history, and the development of future services which will help us to achieve our aims and objectives as a charity.
- Vital use of data
We may also use your data, typically in an emergency, where this is necessary to protect your vital interests, or someone else’s vital interests. In a small number of cases where other lawful bases do not apply, we will process your data on this basis and in your best interest.
- Special category data – The most sensitive of all information
We may collect sensitive information about you. We will only collect this information where is it absolutely necessary. We will ask you to agree to this when we deliver services and support to you. You may also change your mind and stop us from processing such data. However, if you do this we may not be able to continue to support you in the future. On some occasions, and where we have a legal obligation or where it is in the public interest, we may process this data without your consent.
"Special categories" of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data. We aim to collect and process special category data as little as possible. We have assessed the risk associated with this by conducting a risk and impact assessment.
From time to time we may collect and process the following Special Categories of personal data:
• racial or ethnic origin
• religious or philosophical beliefs
• data concerning health
• data concerning sexual orientation.
We do not collect or process the following Special Categories of personal data:
• trade union membership
• political opinions
• genetic data
• biometric data (eg fingerprints) for the purpose of uniquely identifying someone
We may process Special Categories of personal data in the following circumstances:
• With your explicit written consent
• Where it is necessary in the substantial public interest, and further conditions are met
• Where the processing is necessary for archiving purposes in the public interest, or for scientific or historical research purposes, or statistical purposes, subject to further safeguards for your fundamental rights and interests specified in law
• Where there is a legal obligation.
Further legal controls apply to data relating to criminal convictions and allegations of criminal activity. We may process such data on the same grounds as those identified for “Special Categories” referred to above.
4. When we collect your personal data:
These occasions will include, but are not limited to:
• When you work or volunteer with us
• When we deliver services to you
• When you visit our offices or attend an event we may organise
• When you supply goods and services to us
• When you contact us about any subject by any means
• When you post, like, follow or reply on any of our social media feeds
• When you access or engage with our website.
5. How and why we collect your personal data
We collect personal data in order to manage our organisation and deliver services to our beneficiaries. The data collected is most likely in electronic format, but can also be in paper form.
When you visit our website, we may collect your IP address, pages visited, web browser, any search criteria entered, previous web pages visited and other technical information. This information is used solely for web server monitoring and to deliver the best visitor experience. We may use technology such as cookies to help us deliver relevant and interesting content.
We may also collect your social media username if you interact with us through those channels in order to help us respond to your comments, questions and feedback. The Data Privacy Law allows this as part of our Legitimate Interest in understanding our audience.
For your security, we use appropriate organisational and technical security controls to safeguard your data.
When we interact with you we may also collect notes from our conversations with you, and details of any complaints or comments you make. We may record your age or identity, where the law requires this.
We will only ask for and use your personal data collected for the purpose stated at the point at which it is collected. If we believe your data is no longer needed for this purpose we may not process your data further.
6. We are committed to your data protection rights
You have eight important rights under the Data Protection Act 2018. Here is a brief explanation of each.
a) Right to Object
You have the right to object to our processing of your personal information if we used it for the purpose of direct marketing. But remember in some cases we are bound by law to process your data. If you have given us your consent to collect and process your personal data, you have the right to change your mind at any time and to withdraw that consent.
b) Right to challenge automated decisions
Volunteer Centre Tower Hamlets does not currently make automated decisions.
c) Right to a copy of your information and a chance to correct inaccuracies
You have the right to request a copy of any information about you that we may hold at any time to check whether it is accurate. To ask for that information, please contact us using the details below. To protect the confidentiality of your information and the interests of our organisation, we will ask you to verify your identity before proceeding with any request for information. 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 request such information.
d) Right to be forgotten
You have the right to ask us to forget you from our records. We will always uphold this right, unless there is a legal obligation upon us to keep your data. This might be a contractual obligation for example.
e) Right to be informed
You have a right to be informed, to know what we are doing with your data and why. We promise to publish privacy notices wherever they may be required to clearly explain our reasons.
f) Right to Restriction
You have the right to ask us to stop processing your data for a number of difference reasons. For example, it might be because you think the data we hold about you is incorrect. Or maybe, you think we are doing something wrong. Please contact us for further details.
g) Right of portability
If we hold information about you and you want us to ‘port’ it or send it to another organisation that does similar work to us, or provides a similar service, you can ask us to do that. This service will be free-of-charge and we will endeavour to provide this service without undue delay.
h) Other important information
Sometimes we are required to inform you about certain changes, including updates to this Privacy Notice, and where we have a legal obligation, such as a duty of care or safeguarding. These administrative messages will not include any marketing content and do not require prior consent when sent by email. This ensures that we are compliant with our legal obligations.
We may use your data to send you a survey and feedback requests to help improve the way we communicate. These messages will not include any marketing and do not require prior consent when sent by email. We have a Legitimate Interest to do so, as this helps improve our services and make them more relevant to you. Of course, you are free to opt out of receiving any of these communications should you wish.
7. Data retention and how long we may keep data
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. Our Retention Schedule includes retention periods and indicate the types of data concerned and clearly indicate the period for which it will be retained. Annual reviews will ensure that Retention Schedules are followed. At the end of the retention period, your data will either be deleted completely, put beyond use or anonymised. In some cases, personal data will be kept in perpetuity.
8. Protecting your data outside the EEA
Occasionally we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA). The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
We may transfer personal data that we collect from you to third party data processors in countries that are outside the EEA, such as the USA. For example, this might be required when we store data in a Cloud Service or use tools such as Survey Monkey. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA, and we will treat the information under the guiding principles of this Privacy Notice.
9. How to complain about our processing of your data
If you feel that your data has been handled incorrectly, or you are unhappy with the way we have dealt with your query regarding the way we use your personal data, you have the right to complain. You can complain to us using our Complaints Procedure and/or to the Information Commissioner’s Office (ICO), which regulates the use of information in the UK.
You can call them on 0303 123 1113 or go online to www.ico.org.uk/concerns
If you are based outside the UK you have the right to complain to the relevant data protection supervisory authority in your country.
10. Stopping us from using your data in the future
You can stop us from processing your data by either:
- clicking the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails and will ‘forget’ your information in line with your rights unless we have a legal obligation to keep it
- by contacting us using the information below.
Remember, some administrative communications cannot be stopped if we are legally obliged to communicate with you, or you wish to continue to receive a service from us.
If you would like to discuss any aspect of this Privacy Notice, or the way we process your information, please contact us;
By Email – firstname.lastname@example.org
By Telephone – 07595 219603