1. YOUR PERSONAL DATA - WHAT IS IT?
Personal data relates to a living individual (‘Data Subject’) who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulations (GDPR) which replaces the existing Data Protection Act 1998 and will come into force on the 25th May 2018.
2. WHO ARE WE?
Action in the Community Trust is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
Action in the Community Trust is a registered Charity (Charity Number 1140949) and a registered Company (Company Number 7550894). It is commonly known by its trading name, the Speakeasy or The Speakeasy Advice Centre. It will be referred to as the Speakeasy for the remainder of this document.
3. HOW DO WE PROCESS YOUR PERSONAL DATA?
The Speakeasy complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the following purposes:
To enable us to provide a free advice service for the benefit of the public in a particular geographical area as specified in our constitution;
To administer client records;
To monitor our service to ensure we provide a fair and equitable service, without discrimination on grounds of sex, race, religion, age, marriage or civil partnership, pregnancy or maternity, disability, gender reassignment or sexual orientation;
To manage our employees and volunteers;
To maintain our own accounts and records (including the processing of gift aid applications);
To inform you of news, events, activities and services provided by the Speakeasy.
4. WHAT IS THE LEGAL BASIS FOR PROCESSING PERSONAL DATA?
Explicit consent of a client so that we can act on their behalf in accordance to what is agreed between client and solicitor or adviser employed by the Speakeasy;
Implied consent of a client so that we can act on their behalf in accordance to what is agreed between client and solicitor or adviser employed by the Speakeasy;
Legislation or other statutory obligations;
The legitimate retention of data for a period of 6 years after closure of a matter so as to be able to defend any action taken against the Speakeasy;
Explicit consent of a data subject to keep them informed about news, events, activities and services and process your gift aid donations.
5. SHARING YOUR PERSONAL DATA
Your personal data will be treated as strictly confidential and will only be shared with other staff members of volunteers of the Speakeasy in order to carry out a service to you. We will only share your data with third parties outside of the Speakeasy with your consent and where it is necessary to pursue your case or one of the other objectives outlined in paragraph 4.
6. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We keep data in accordance with the guidance set out by the ICO and outlined in the Speakeasy’s Data Protection Policy. Specifically, we retain client data for 6 years following closure of a file and gift aid declarations and associated paperwork for up to 6 years after the calendar year to which they relate.
7. YOUR RIGHTS AND YOUR PERSONAL DATA
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -
The right to request a copy of your personal data which the Speakeasy holds about you;
The right to request that the Speakeasy corrects any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary for the Speakeasy to retain such data;
The right to withdraw your consent to the processing at any time;
The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability) (where applicable).
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to lodge a complaint with the Information Commissioners Office.
8. THIRD PARTIES
Visitors to our website
When someone visits www.speakeasy.cymru we use a third party service, SquareSpace Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow SquareSpace to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Our website search is powered by SquareSpace. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either The Speakeasy or any third party.
People who contact us via social media
People who email us
The Speakeasy uses a third-party service, Gmail Apps. Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
People who use our LiveChat service
We use a third party provider, TawkTo, to supply and support our LiveChat service, which we use to handle enquiries in real time. If you use the LiveChat service we will collect your name, email address (optional) and the contents of your LiveChat session. This information will be retained for two years and will not be shared with any other organisations. You can request a transcript of your LiveChat session if you provide your email address at the start of your session.
People who use our services
When you access our services you are agreeing to submit the personal information we need to properly advise, assist or represent you. When we gather this information we use a third-party web-based service, Advanced Case Management Solutions (ACMS). We may also store information on a secure server.
“Though ACMS will make every effort to preserve the privacy of personal data collected, ACMS may be required to disclose personal information when required by law wherein ACMS has a good faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our website. ACMS is also registered under the Data Protection Act 1998 and as a data controller. Any personal information collected by ACMS on this website, such as your name, address and e-mail address may be provided to necessary third-party service providers involved in advice and counselling.”
9. FURTHER PROCESSING
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
10. CONTACT DETAILS
To exercise all relevant rights, queries or complaints please contact us in the first instance, marking your correspondence for the attention of the Centre Director.
You can contact the Information Commissioners Office on 0303 123 1113, via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
We may update this policy from time to time. When we do, we will revise the updated date at the bottom of this page. We encourage our users to frequently check this page for any changes to stay informed about how we are helping to protect your personal information.