St Hilda’s East Community Centre
PRIVACY STATEMENT

INTRODUCTION
St Hilda’s East Community Centre is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

St Hilda’s East Community Centre is the Data Controller. We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, Companies House).

1 SECURITY
We take the security of all the data we hold seriously. Staff are provided with guidance on data protection, confidentiality and security.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

All information you provide to us is stored on our secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

2 DATA THAT WE HOLD
We provide services to our service users, often members of the public. The exact data held will depend on the services to be provided.
Where we engage with service users, we may collect and process personal data to satisfy a contractual obligation. We request that service users only provide the personal data that is required for us to fulfil our contractual obligation.

2.1.1 Why do we process data?
Where data is collected for our service users, it is used for several purposes, as follows;

• Service User management. When communicating with and assessing the needs of service users, personal data may be processed to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services is provided to our clients are appropriate.
• Administration. To manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing service user relationships, hosting events, and maintaining internal operating processes.
• Regulatory. To undertake professional services, we may from time to time be required to collect and process personal data to fulfil regulatory, legal or ethical requirements.

2.1.2 What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

• To provide services to our users, we may collect personal data such as names, addresses, dates of birth, gender, emails, phone numbers and other contact details. We also may collect special categories of information such as ethnicity, religion and health information.

2.1.3 How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically up to 6 years). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our service users.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

2.1.4 Why do we process data?

Where personal data is held, it is used for several purposes, as follows;
• Promote and develop our services.
• Hosting and facilitating of events.
• Relationship management.
• Administration and management.

2.2 OUR PEOPLE

We collect personal data for our people as part of the administration, management and promotion of our service.

Our staff handbook explains further how personal data is held for our staff.

2.2.1 Applicants

Where an individual is applying to work for St Hilda’s East Community Centre, personal data is collected through the application process.

There are several purposes that personal data for applicants are collected.

• Employment. We process an applicant’s personal data to assess their potential employment at St Hilda’s East Community Centre.
• Administration and management. We may also use this personal data to make informed management decisions and for administration purposes.

Personal data collected for applicants is held for as long as necessary to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.

3 PEOPLE WHO VISIT OUR CENTRE
We have security in place at our offices, for the physical security of service user information and for the benefit of our staff, volunteers and trustees.

CCTV is in operation outside the building. The images are held securely and only accessed when needed when investigating an incident.

To hold and process the visitor details and CCTV, we believe it is a legitimate business interest that visitors are captured and controlled in this way.

3.1 WHY DO WE PROCESS DATA?
CCTV and building access controls may require visitors to our centre to sign in at reception and keep a record of visitors. This is retained for the safety of our visitors.

3.2 WHAT DATA DO WE HOLD?
Personal data that may be stored on CCTV will be footage of those visiting our centre. Our visitor book may include names and times of arrival / departure.

3.3 HOW LONG DO WE HOLD DATA FOR?
Visitor records are accessed on a need to know basis only. CCTV recordings are automatically overwritten after a brief period unless we identify an issue requiring investigation.

4 PEOPLE WHO USE OUR WEBSITE
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

5 SHARING PERSONAL DATA
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to third parties to support us in providing our services with appropriate consent.

Appropriate information may also be shared with auditors and law enforcement or regulatory agencies or those required by law or regulations in order for St Hilda’s East to meet its legal requirement.

6 LOCATIONS OF PROCESSING
Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination within the European Economic Area (EEA). We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.

7 INDIVIDUAL’S RIGHTS
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

• Individuals may request access to their personal data held by us as a data controller.
• Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
• Individuals may request that we erase their personal data
• Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
• Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
• Individuals may request information about, or human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please send an email to data@sthildas.org.uk.

8 COMPLAINTS
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to data@sthildas.org.uk or write to: Data Protection Officer, St Hilda’s East Community Centre, 18 Club Row, London E2 7EY. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

9 DATA CONTROLLER AND CONTACT INFORMATION
If you have any questions about this privacy statement or how and why we process personal data, please contact the Data Protection Officer at St Hilda’s East Community Centre on 020 7739 8066 or email: data@sthildas.org.uk

10 CHANGES TO OUR PRIVACY STATEMENT
Updates to this privacy statement will appear on this website. This privacy statement was last updated in May 2018.

St Hilda's East Community Centre, 18 Club Row, London E2 7EY | mail@sthildas.org.uk | 020 7739 8066
Founded by The Incorporated Guild of Cheltenham Ladies' College in 1889. Company Limited by Guarantee (no. 52880) and Registered Charity (no. 212208).

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