Nova Wakefield District Limited is a charity registered in England and Wales (Charity No 1143640) and a private company limited by guarantee without share capital registered in England (Company No 07183132).
Purpose of the policy
This policy sets out how we will collect, process, store and use the information we hold about you. We take the protection of your privacy and confidentiality seriously and we understand that you are entitled to know that your personal data will not be used for any unintended purpose and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. This information can be found at www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any personal data we collect.
What personal data do we collect?
In most cases we collect personal data about you only when you give it to us. This can include your name, email address, postal address, telephone numbers and date of birth. We collect personal data about you when you:
- ask about our activities;
- register with us as a member or for one of our services;
- are appointed to deliver a service on our behalf;
- apply for one of our grant programmes or support programmes;
- make a donation to us;
- sign up for an event or training;
- engage with our social media or message boards;
- sign up for or order products and services (such as publications and email newsletters);
- or otherwise give us personal data.
The basis on which we process information about you
The law requires us to determine under which of the defined bases we process different categories of your personal data, and to notify you of the basis for each category.
If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.
If the basis changes, then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
Information we process because we have a contractual obligation with you
When you register to become a Nova member, subscribe to any of our services, are appointed to deliver a service on our behalf, apply for one of our grant programmes or support programmes, a contract is formed between you and Nova Wakefield District Limited.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.
We may use it in order to:
- verify your identity for security purposes;
- provide you with our services;
- provide you with suggestions and advice on products, services and how to obtain the most from using our website.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website, ask us to provide you with more information about our business, including our services, sign up to receive our e-bulletin, comment on a blog post on our website, add an event on our website, you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, when you sign up to receive our e-bulletin.
Sometimes you might give your consent implicitly, such as when you send us a message by email to which you would reasonably expect us to reply, comment on a blog post or add an event on our website to which you would reasonably expect us to publish.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at firstname.lastname@example.org. However, if you do so, we may not be able to provide you with our services further.
Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal data.
Information we process because it is in our legitimate interest to do so
We can process your personal data if we have a genuine and legitimate reason and we are not harming any of your rights and interests by doing so. We will process the personal data you have supplied to us to conduct and manage our business to enable us to give you the most appropriate information, service and products. These are what we consider to be our 'legitimate interests'.
Examples of where we would apply legitimate interests include:
- for administration purposes;
- for internal record keeping, such as the management of feedback or complaints;
- to analyse and improve the services we offer;
- to check on your preferences from time to time to ensure they are up to date;
- to process any donation(s) we may receive from you;
- to make contact with you for administrative purposes connected to your membership or relationship with us.
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will 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).
Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people. Examples include:
- posting a comment on a blog post;
- posting a job, event, training or news on our website.
In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it. We do not specifically use this information except to allow it to be displayed or shared. We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time. Provided your request is reasonable and there is no legal basis for us to retain it, then we may agree to your request to delete personal data that you have posted. You can make a request by contacting us at email@example.com.
Our website allows you to sign up to receive our monthly e-bulletin featuring Nova news, events, jobs, funding and training opportunities related to the voluntary and community sector locally and nationally.
We use MailChimp to send these communications. If you choose to receive them your email address, first name and surname will be stored on our secure account with MailChimp. Your data will only be used for the purpose of sending you our communications as described above. You can unsubscribe at any time by clicking the link at the bottom of the emails.
Job application and employment
If you send us information in connection with a job application, we may keep it for up to six months in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for seven years before destroying or deleting it, unless we are required to keep it longer to comply with our funding agreements.
You have the following rights in relation to our processing of your personal data:
- The right to be informed about how we use your personal data.
- The right to request a copy of all the information we hold about you. You will need to give adequate information (for example full name, address, date of birth etc). We will generally provide the information free of charge and are required to respond to you within one month. You will be required to provide identification before any information is released to you.
- The right to request to have personal data rectified if inaccurate or incomplete.
- The right to request erasure of your personal data where there is no compelling reason for its continued processing. This may limit the service we can provide to you.
- The right to request that we restrict the processing of your personal data in certain circumstances.
- The right to data portability which, subject to certain conditions, allows you to obtain and reuse your personal data across different services.
- The right to object to the processing of your personal data in certain circumstances – you can ask to be excluded from receiving Nova communications.
- Rights to information in relation to automated decision making and profiling.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Retention period for personal data
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to comply with our funding agreements;
- to support a claim or defence in court.
When we no longer need to retain your information we will ensure it is securely disposed of at the appropriate time.
How we use the information we collect to improve our website
We may collect and store the following information each time you visit our website: the date and time, the originating IP, the type of browser and operating system used, the URL of the referring page, the object requested, and the completion status of the request.
Visitors to our website remain anonymous as none of the data collected is linked to any personal data. The information allows us to assess the popularity of the pages on the website, so that we can continue to improve our website and access to information.
Cookies are small text files that are placed on your computer's hard drive or mobile phone by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It should also allow you to prevent or limit their use. You can find out more about cookies here: https://ico.org.uk/for-the-public/online/cookies/
Links to other websites
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates on our website to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser's URL bar or toolbar.
How you can complain
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
If you complain about any of the content on our website or Twitter feed, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate. We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
You can find out more about our complaints procedure here: https://www.nova-wd.org.uk/complaints.html
If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
How to contact us
Telephone: 01924 367418
Post: Nova Wakefield District Limited, 11 Upper York Street, Wakefield, WF1 3LQ