Policies

CORNWALL COUNTY PLAYING FIELDS ASSOCIATION

PRIVACY POLICY-STATEMENT

Cornwall County Playing field Association (CCPFA) is committed to protecting your privacy and security and ensuring you remain informed and in control of your information.
This policy explains when we use your personal information: how we use it, keep it secure and in what circumstances we may share it with other organisations.

Who is it for?
It is for everyone who works with or interacts with CCCPFA.

About us
CCPFA is an independent charity providing information, advice and support services to playing field, sports pitches and open spaces across Cornwall.

CCPFA’s main office is located at ClayTAWC, Fore Street St Dennis ST AUSTELL PL26 8AF. For the purposes of data protection law, CCPFA will be the controller and processor of personal information.

Personal information
Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person. For example, this could be your name, contact details, or national insurance number.

Why do we need your personal information?
We may need to use some information about you to:
 Deliver services and support to you (eg information and advice services, training, email newsletters)
 Manage those services we provide to you
 Recruit train and manage the employment of our workers who deliver those services
 Help follow up any feedback or concerns you have about our services
 Monitor the effectiveness of our services
 Check the quality of services (internally and by external organisations)
 Help with research and planning of new services

Keeping you in control
We want to ensure you remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:
• the right to confirmation as to whether or not we have your personal data and, if we do, to be able to obtain a copy of the personal information we hold (this is known as Subject Access Request)
• the right to have your data erased (although this will not apply where it is necessary for us to continue to use the data for a lawful reason)
• the right to have inaccurate data rectified
• the right to object to your data being used for marketing or profiling
• where technically feasible; you have the right to personal data you have provided to us (which we process automatically on the basis of your consent or the performance of a contract) to be provided in a commonly used and machine-readable format and to reuse it for your own purposes. This is known as the ‘right to data portability’

Please keep in mind that there are exceptions to the rights above and though we will always try to respond to your satisfaction there may be situations where we are unable to do so.

If you would like further information on your rights or wish to exercise them, please write to our Data Protection Lead, CCPFA ClayTAWC, Fore Street ,St Dennis, ST AUSTELL, PL26 8AF or email info@cornwallcpfa.org.uk

When do we collect information about you?
We collect information about you when you contact CCPFA to receive a service, or when you are referred to us by another organisation, or when you are employed by us.

When you contact us for information, advice or support relating to one of our contracted services you are engaging with us in an agreement for the provision of those agreed services (known as a ‘contract’ for lawful processing).

What information do we collect about you?
The personal information we collect could include your name, address, age, contact details, and details of your caring role, if appropriate.

For monitoring purposes, we may ask you for your religious beliefs and ethnic background. This information will only be held with your explicit consent. It will not restrict your access to a service if you choose not to provide this detail.

For some of our services, we will collect or store information relating to your health. This information will only be held with your consent and we will take extra care to ensure your privacy rights are protected.

If you provide information about another person (the person you care for or an emergency contact) we will need to confirm that they are aware of this. We will ask you for their contact details so that we can write to them and inform them of the information we hold and their rights under data protection law.

If you volunteer with us, then we will collect extra information about you (for example: references, criminal records check, professional certificates, details of emergency contacts, medical conditions). This information will be retained for legal reasons, to protect us (including in the event of an insurance or legal claim) and for safeguarding purposes.

If you are a donor, we will collect financial information (direct debit / standing order details) and whether your donations are gift-aided.

We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.

How will we use the information about you?
We collect information about you in order to:
• carry out our obligations arising from any agreement entered into by you and us, for the provision of information, advice and support to you in relation to the service you receive from us
• seek your views or comments on the services we provide
• notify you of changes to our services
• send you communications which you have requested
• inform our future service development to ensure that these are fully accessible

We occasionally carry out analysis of data we hold about clients, donors and volunteers, to better understand the value of our work and identify patterns and trends. This helps inform how we work and make CCPFA a stronger and more effective organisation and provide better services.

How long will we hold your information?
We will hold your personal information on our systems for as long as you are registered for our services and/or where we are legally required to hold the information for a specified time.

Where there is not a specified time period for retention in law or in official government guidelines, we follow best practice guidelines from the Information Commissioner’s Office and carefully consider an appropriate retention period for the personal information we hold.

We may aggregate and anonymise personal data so that it can no longer be linked to any particular person. This information can be used for a variety of purposes, such as reporting to funders and identifying trends to help inform our actions and improve our services.

How do we store your information?
CCPFA operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside the EEA, but we’ll only allow them to do if your data is adequately protected.

For example, some of our systems use Microsoft products. As a US company, it may be that using their products result in personal data being transferred to or accessible from the US. However, we will allow this as we are certain personal data will still be adequately protected (as Microsoft is certified under the USA’s Privacy Shield scheme).

If you use our services while you are outside the EU, your information may not be governed by legislation to the same standard and we are not able to guarantee the security of your information.

How do we protect your information?
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to, or use or disclosure of your personal information.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means).
Paper documents are stored securely in locked cupboards and destroyed promptly when they are no longer needed.
Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.

We carry out regular data audits to ensure the quality and security of the data we hold.
Security: All electronic forms that request data will use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers.

Please note: We cannot guarantee the security of your home computer or the internet, and any online communications (eg information provided by email or our website) are at the user’s own risk.

In the unlikely event that there is a data breach we have a procedure in place to inform the Information Commissioner’s Office and anyone whose personal information was mishandled. We will investigate any breaches or near misses immediately to ensure it does not happen again.

When will we share information about you?
We will never sell your personal data, and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed.

If you request that we refer you to a third party organisation we will only undertake this with your permission.

Under our contracts with statutory organisations we are required to share personal information (name, address, age, address, ethnic background, religious beliefs) for those clients accessing information, advice support services.

Under our agreement with other funders we will only share information as required by the agreement and where necessary only with your explicit consent.

We may share personal data with subcontractors or suppliers who provide us with services. However, these activities will be carried out under a contract which imposes strict requirements on our supplier to keep your information confidential and secure.

Occasionally, where we partner with other organisations, we may also share information with them (for example, if you register to attend an event being jointly organised by us and another charity). We will only share information when necessary and we will make sure to notify you first.

Disclosure
CCPFA has a legal duty to disclose some information including:
 Safeguarding concerns will be reported to Children’s Services / Adult Social Care
 Drug trafficking, money laundering, acts of terrorism or treason will be disclosed to the police
 In addition, where colleagues believe an illegal act has taken place it will be reported to the appropriate authorities
 If a court orders that we provide the information
 In order to prevent crime and fraud
 If there are serious risks to the public, our staff or to other professionals

CCPFA will always inform you of any disclosure.

Marketing
CCPFA does not undertake unsolicited marketing and will not sell, rent or otherwise share your information to third parties for marketing purposes.

We do send out information about our services and updates relating to carers and our clients such as legislation changes, initiatives, activities and requests for fact finding surveys or other targeted communication.

Should you no longer wish to receive this information at any point simply let us know and we will ensure you are removed from our mailing list:
Email: info@cornwallcpfa.org.uk
Post: Admin CCPFA ClayTAWC, Fore Street St Dennis, ST AUSTELL PL26 8AF
Phone: 01726 821904 (9am – 4pm, Tuesday, Wednesday, Thursday)

If you have opted in to communications from us, we may contact you with information about our partners, or third party products and services, but these communications will always come from CCPFA.

When you receive a communication, we may collect information about how you respond to or interact with that communication, and this may affect how we communicate with you in future.

Fundraising
As a charity, we rely on donations and support from others to continue our work. From time to time, we may contact carers, clients, volunteers and supporters with fundraising material and communications. This might be about an appeal or to suggest ways you can raise funds (eg a sponsored event or activity).

As with other marketing communications, we will only contact you specifically about fundraising if you have opted in to receiving marketing from us. You can unsubscribe at any time by contacting:
Email: info@cornwallcpfa.org.uk
Post: Admin CCPFA ClayTAWC, Fore Street St Dennis, ST AUSTELL PL26 8AF
Phone: 01726 821904 (9am – 4pm, Tuesday, Wednesday, Thursday)

If you decide to donate to us, then we will keep secure records of when and how much you give to a particular cause.

Profiling
CCPFA does not analyse your personal information for profiling purposes.

Website
Cookies: Our website uses local storage (such as cookies) to provide you with the best possible experience and to allow you to make use of certain functionality.

A cookie is a piece of information in the form of a very small text file that is placed on an internet user’s hard drive when they visit our website. They do not contain any personal information like your name or address, only data concerning your visit to our website.

We use cookies on our website to measure how people are using our website. We use Google Analytics to collect this information, which allows us to see how many people visited our website, where they came from, how they are using the website and where it can be improved.

Cookies store the type of referral used by a visitor to reach our site, whether via a direct method, a referring link, a website search, or a campaign such as an ad or an email link.
For further information visit www.aboutcookies.org or www.allaboutcookies.org

Links to other sites: Our website contains hyperlinks to many other websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage you to be aware when your leave our websites and to read the privacy notices of any other site that collects personally identifiable information, as the information you provide them will not be covered by CCPFA’s Privacy Policy.

If any of our links are not working please let us know.

When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with CCPFA.

Questions?
Any questions you have in relation to this policy or how we use your personal data should be sent to:
Admin CCPFA ClayTAWC, Fore Street St Dennis, ST AUSTELL PL26 8AF
Phone: 01726 821904 (9am – 4pm, Tuesday, Wednesday, Thursday)

We will never sell your personal data, and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed.

Complaints
You can complain to CCPFA directly by contacting our Data Protection Lead using the details set out above.

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK.

You can also contact them for independent advice about data protection, privacy and data sharing issues. You can contact the Information Commissioner’s Office (ICO) at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113

Alternatively, visit www.ico.org.uk or email casework@ico.org.uk

Changes to this Privacy Policy
We will amend this Privacy Policy from time to time to ensure it remains up-to-date and accurately reflects how and why we use your personal data. The current version of our Privacy Policy will always be posted here.