01926 422 123

Privacy policy

Our Privacy Principles

BHLC takes your privacy very seriously.  It is important that you feel confident about how we look after any personal information you share with us.   We want you to know that:

  • We only use your personal information in ways that we need to and that we think you would expect
  • We will never share your information with other organisations for their marketing purposes
  • We take all reasonable care to protect your personal information
  • We will be especially careful with information about children and vulnerable people
  • We may use your personal information to contact you about our services, but only if you have told us that is OK.

 When do we collect your information?

We may ask you for personal information (for example your name, your address, your date of birth, your telephone number) when you:

  1. Register for one of our services
  2. Apply for a paid or unpaid role within BHLC
  3. Make a donation to us
  4. Subscribe to our newsletter
  5. Give us some feedback
  6. Contact or become involved with us in another way, for example through our website, using email, by letter, or on Social Media.

Someone else may give your personal information to us (e.g. your name and contact details). This is usually because they are asking us to provide you with information or services.  Where possible and appropriate, we will check that:

  1. They have your permission to do this
  2. You know what information they have given to us and why.

We may take photographs or video during activities in and around Brunswick Hub or at outreach locations. We will not share or publish these without your permission.

Who decides which information to collect and what it is used for?

In most cases, BHLC is the data controller.  This means that we decide which personal information is collected, how it is stored, and what it is used for.

Sometimes our funders ask us to collect certain information so that they can keep track of how we are using the money they give to us.  In this case, the funder may be a joint data controller together with BHLC.  There is more information about how we share information with funders later on in this document.

What is our legal basis for collecting your information?

By law, we must have good reasons for collecting and using your personal information.  These reasons will depend on the nature of your involvement with BHLC and the type of information.  We will only collect personal information for one or more of the following reasons:

In order to pursue the Legitimate Interests of BHLC as a Registered Charity and a Charitable Company Limited by Guarantee:

  1. Recruitment, management and support of Staff, Volunteers and Trustees
  2. Staff, Volunteer and Trustee administration, including payroll and expenses
  3. Planning and delivering services in line with the Aims, Objectives and Constitution of BHLC
  4. Reviewing and improving our services
  5. Monitoring our work to make sure that we are achieving defined outcomes and reaching people who could benefit from our services
  6. Raising essential funds through grant applications, service level agreements and local fundraising events / activities.

Where an individual has given us clear and explicit consent:

  1. To process special categories of information such as race, ethnicity, religious beliefs
  2. To make a referral to other services or organisations
  3. Where possible and appropriate we will seek consent from a parent or guardian before collecting information about children.

 To enter into or fulfil a contract:

  1. Employment
  2. Suppliers or contractors.

In order to comply with our legal obligations under:

  1. Charity Law
  2. Company Law
  3. Employment Law
  4. Social Protection Law
  5. Criminal Law.

To protect the vital interests of an individual we may ask for:

  1. Emergency contact information
  2. Essential medical information such as allergies.

If you have any questions about our legal basis for collecting and storing your personal information, please ask us – it is your right to be fully informed.

What do we use your information for?

We may use your personal information to:

  1. Provide the support, information and services you have asked us for, whether in person, on the phone, by email or through our Website and Social Media accounts
  2. Keep proper records of your relationship with us
  3. Support your volunteering activities with us
  4. Make sure we know how you prefer to be contacted
  5. Keep you up to date with our services, for example by sending you our newsletter – we will only do this if you have told us it is OK
  6. Respond to a complaint you have made
  7. Understand how we can improve our services and information
  8. Look at the characteristics of the people who are using our services to see how well we are reaching people in our communities
  9. Gather and analyse feedback.

How do we deal with sensitive information?

 If you are using our services, you may choose to share personal information that is particularly sensitive.

We may also need to ask for sensitive information, for example about your ethnicity, so that we can monitor and evaluate the services we provide.  You can choose not to give us this information and your decision will not affect the services that you receive.

If you do share sensitive information with us, we treat it with extra care and do not pass on your details to anyone else without your permission, except if we are required by law to do so.

A note about our website

 You may choose to send us messages using the Venue Hire or Contact Us forms on our website.

When you send us a message in this way, your permission will be asked for us to use your personal information to contact you and respond to your request.  The information in these forms is not stored on the website but is sent to us in an email.

We use Cookies and Google Analytics to track visitor use of the website and to compile statistical reports on website activity.  This information may include your IP address, which can tell us your general location.

You can set your browser not to accept cookies and the following websites tell you how to remove cookies from your browser, however in a few cases some of our website features may not function as a result:

https://www.aboutcookies.org/

http://www.allaboutcookies.org/

https://tools.google.com/dlpage/gaoptout

How do we keep your information safe?

 We take the security of your personal information very seriously.  Here are some of the ways that we protect it:

  1. Paper records are kept securely in our offices at Brunswick Hub
  2. Computer files are stored locally on our server, with controlled access so that only people who need to see the information can do so. Sensitive information is password protected for extra safety.
  3. Some of your personal information may be contained in emails, for example so that we can contact you or communicate with other organisations on your behalf. Email is not fully secure and we cannot guarantee that these communications are protected.  If we need to send sensitive information by email, this will be password-protected and / or encrypted
  4. We use a secure online database system called PSIAMS to store and analyse personal information. All data on the PSIAMS system is held locally or on UK/EU centres and is encrypted for security.  Our contract with PSIAMS identifies them as a data processor for BHLC, meaning that they have a legal responsibility to protect your information.

 Who sees your personal information?

  1. Your personal information will be used by our staff and volunteers so that they can provide the support, information and services you have asked us for
  2. We may need to share your information with other organisations so that we can refer you to them for further support. We will never do this without your permission
  3. BHLC is a registered charity and receives funding from various organisations, including Warwick District Council, Orbit and the Big Lottery Fund. These organisations will ask for information from us in order to make sure that we are providing the agreed services and to monitor quality.  The great majority of information that we provide is anonymised so that individuals cannot be identified.  We will never share personal information with funding organisations unless we have your permission
  4. If you have made a Gift Aid declaration we may share this with HMRC for the purpose of claiming Gift Aid on your donation
  5. We may disclose your personal information if we are required to do so by any law or court order
  6. BHLC may enter into contracts with other organisations and consultants to support us with providing services and with administrative tasks such as human resources, payroll, website hosting, IT, charity governance and data analysis. In each case we will make sure that the company or individual has signed a data processing agreement with us so that they are legally bound to take care of your information in the same way we do

 

How long do we keep your information for?

 Your personal information is only stored for as long as it is needed to fulfil the purposes we have collected it for.

In most cases, we will not keep your personal information for more than two years after your involvement with us has ended.  Where there are legal requirements that determine how long we must keep information, for example in the case of financial records, we will comply with these.

We have procedures in place to ensure that personal information is destroyed or deleted once the appropriate time period has passed.

What are your rights?

Under data protection law, you have a number of rights.  The following are most relevant to the data processing that is carried out by or on behalf of BHLC:

The right to be informed about how we collect and use your personal information. This privacy statement is intended to provide the relevant information, however if you have any questions please get in touch with us.

The right to have access to your personal information so that you can check that we are collecting and storing it lawfully. You do not have to ask in a particular way – just get in touch and let us know that you would like access to your personal information and we will respond to your request according to our data protection policy and our legal obligations.

The right to have corrections made to information that is incomplete or inaccurate

The right to request that your personal information is deleted or destroyed. This only applies in certain circumstances:

    1. The personal data is no longer necessary in relation to the purpose for which it was originally collected and processed
    2. You withdraw the consent that you had previously given
    3. You object to the processing and there is no overriding legitimate interest for us to continue
    4. The personal data was unlawfully processed
    5. The personal data has to be erased in order to comply with a legal obligation
    6. The personal data is processed in relation to the offer of information society services to a child, e.g. online shops, live or on-demand streaming services, and companies providing access to communication networks.

The right to ‘block’ or suppress processing of personal data – in this case we are allowed to continue storing the data but must not use it.  This right applies in the following circumstances

    1. If you have told us that the information we have is incorrect, then we must stop processing it until we are sure that the information is correct
    2. If you have objected to the processing and we are considering whether we have legitimate grounds that override your objection
    3. If the processing is unlawful, but you request that we restrict processing of your information instead of erasing it
    4. If we no longer need your information but you need it in relation to a legal claim.

The right to object to:

  1. Processing based on legitimate interests
  2. Direct marketing.

Who can you contact if you have a question or concern about privacy?

 If you have a concern or complaint about how we have handled your personal information, please contact us:

Centre Manager
Brunswick Hub
98-100 Shrubland Street
Leamington Spa
Warwickshire
CV31 3BD
T: 01926 422123
E: centremanager@bhlc.services

You can also contact the Information Commissioner’s Office (ICO), which is an independent authority responsible for upholding information rights in the UK.

You can report a concern to the ICO via their website: https://ico.org.uk/concerns or by calling 0303 123 1113.