Privacy Policy
*Please note that references to staff/employees in the following text also incorporates volunteers*

Introduction

Queens Hall Action on Poverty Limited is committed to ensuring that your privacy is protected and will treat all personal data held about you in accordance with this policy which is in line with current the EU General Data Protection Regulation (GDPR) and relevant UK Data Protection legislation.
Queens Hall Action on Poverty is a ‘data controller’ meaning that we decide how and why the personal data that we collect is used.

This Privacy Policy explains:
•    The categories of personal data we may process
•    The purposes for which we collect personal data.
•    The legal bases for the processing of personal data.
•    Your rights and how you can manage the use of your personal information.
•    Procedures that we have in place to safeguard your privacy and how we use cookies.
•    How you can contact us or make a complaint.

1.0 What Information do we collect ?

We only gather the personal information we need for business purposes in order to provide you with the services you have requested or to comply with our regulatory obligations, as well as appropriate news and information where you have consented to this. The personal information we typically collect includes:
•    Name
•    date of birth
•    gender
•    business/company name
•    job title
•    profession
•    contact information such as email addresses and telephone numbers
•    demographic information such as post code, preferences, and interests
•    IP address
•    web browser type and version
•    operating system
•    a list of URLs starting with a referring site, your activity on our website, and the site you exit to.
•    Information collected via our live chat facility
•    Information from donors
Queens Hall Action on Poverty is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

1.1 The purposes for which we collect personal data

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

•    For the provision of our services
•    Internal record keeping
•    We may use the information to improve our services.
•    We may periodically send promotional emails about our services or other information which we think you may find interesting using the email address which you have provided.
•    If you make a donation to us, we like to say Thank you, if you provide your contact details we may write to or email you to thank you for your donation.
If you have opted in via our website, over the telephone or by email to receive marketing communications from us, we will handle your personal information to provide you with marketing communications in line with any preferences you have told us about. When we send you marketing emails, we rely on your consent to contact you for marketing purposes. You are not under any obligation to provide us with your personal data for marketing purposes.  You can tell us that you do not want your personal information to be processed in this way at any time by contacting us at receptionbworks@thebrick.org.uk  or by calling 01942 417290.

2.0 The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information 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.

Because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
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 information.
•    We may use it in order to:
•    Verify your identity for security purposes
•    Provide you with our services
o Provide you with suggestions and advice on products, services and how to obtain the most from using our website

With your consent

When there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including our services, you will provide your consent to us to process information that may be personal information Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
We will always ask for your consent when accessing our Live Chat service and provide you with a link to this privacy policy.’

For the purposes of legitimate interests

•    We may process information on the basis there is a legitimate interest, either to you or to us, such as send out Thank you letters / emails if you make a donation or if you attend one of  our Recycling Sessions , we will let the council know if you attended.
Where we process your information on this basis, we do so after having given careful consideration to:
•    whether the same objective could be achieved through other means
•    whether processing (or not processing) might cause you harm
•    whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
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.

3.0 Retaining, deleting and access to personal data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:

•    Name, Address, Date of Birth, contact details, Financial Information will be retained for a minimum period of 6 years.
If you disclose personal information to us during Live Chat this may be recorded and stored on our organisational database in line with this privacy policy.  This may be retained for up to 6 years in line with the organisation’s legitimate interests.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. You may request details of personal information which we hold about you under the EU GDPR and relevant UK Data Protection legislation.
If you believe that any information, we are holding on you is incorrect or incomplete, please contact us as soon as possible, at enquiries@thebrick.org.uk . We will promptly correct any information found to be incorrect.

Your rights

Your principal rights under data protection law are:
•    the right to access;
•    the right to rectification;
•    the right to erasure;
•    the right to restrict processing;
•    the right to object to processing;
•    the right to complain to a supervisory authority; and (g)     the right to withdraw consent.
(h)     Data Portability – Does not apply to QHAP
4.0 Sharing your personal data with others

We will only pass your data to third parties in the following circumstances:
•    you have provided your explicit consent for us to pass data to a named third party;
•    we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third-party data processors; or
•    we are required by law to share your data.

5.0 Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Other security measures to safeguard your data are contained in our Information Security Policy.

5.1  Cookies
What are Cookies?
We collect information about your use of our Site through cookies. Cookies are information that files stored on your computer, tablet or smartphone that help websites remember who you are and information about your visit. Cookies can help to display the information on our Site in a way that matches your interests. Most major websites use cookies.

•    What cookies are used on this Site?

The cookies we and our business partners use on our Site are broadly grouped into the following categories:

•    Essential – Some of the cookies on our Site are essential for us to be able to provide you with a service you have requested. An example of this could be a cookie used to enable you to log into your account on our Site or which allows communication between your browser and our Site. Our cookie preference cookie described in the section “How can I reject or opt out of receiving cookies?” is also an essential cookie. You may not be able to use our Site without these cookies.

•    Analytics – We use analytics cookies to helps us understand how users engage with our Site. An example is counting the number of different people coming to our Site or using a particular feature, rather than the total number of times the site or feature is used. Without this cookie, if you visited our Site once each week for three weeks we would count you as three separate users. We would find it difficult to analyse how well our Site was performing and improve it without these cookies.
•    User Cookies – We use cookies to improve your experience by remembering your preferences so we know how you like to use our Site. Examples of this would be remembering you so that you are served with the same content or to remember you when you come back to our Site.
•    Social Sharing – We use third party cookies to allow you to share content directly on the social networking/sharing sites like Facebook, Twitter or Google+. Examples would be if you wanted to “like” or “tweet” about us or our products or services. Please see our “Third Party Cookies” section below for more details.

b. How can I reject or opt out of receiving cookies?

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you use our Site. The “Help” menu of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

For more information about cookies and how to stop cookies being installed or how to delete existing cookies from your hard drive visit the following website: http://www.allaboutcookies.org.

c. Third party cookies

Some of the cookies described in the “What Cookies are used on our Site” section above are stored on your machine by third parties when you use our Site. Third parties may also read cookies on your browser to collect information or to serve content or advertisements to you. We have no control over these cookies or how the third parties use them. They are used to allow that third party to provide a service to us, for example analytics. For more information on these cookies and how to disable them, please see:

•    Internet Advertising Bureau website at http://www.youronlinechoices.com/ where you will be able to opt-out of receiving Interest-Based Advertising cookies from some of the third parties listed below; and/or
•    If you want to know more about how cookies work and how to manage or delete them, visit the World Wide Web Consortium’s website.

6.0 Your Rights
You have the following rights regarding your personal data:
Rights
What does this mean?
1.    Rights to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.
2.     Right of access
You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your personal data in accordance with data protection law.
3.    Right to rectification
You are entitled to have your personal data corrected if it is inaccurate or incomplete.
4.    Right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enable you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5.    Right to restrict    processing
You have the right to ‘block’ or supress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.
6.    Right of data portability
You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
7.    Right to object to   processing
You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling).
8.    Right to withdraw consent to processing
If you have given your consent to us to process your personal data for a particular purpose (for example, direct marketing), you have the right to withdraw your consent at any time (although if you do so, it does not mean that any processing of your personal data up to that point is unlawful).
9.    Right to make a complaint to the data protection authorities
You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your personal data or believe our processing of your personal data does not comply with data protection law.

6.1 Complaints

If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data, please feel free to contact our Nominated Person for Data Protection on 01942 417290, or via email enquiries@thebrick.org.uk or via the ‘Contact Us’ section of our website.

If you’re not satisfied with our response to any enquiries or complaint or believe our processing of your personal data does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:

•    writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
•    calling: 0303 123 1113; or
•    submitting a message through the ICO’s website at: https://ico.org.uk/concerns/

7.0 Other websites

Our website contains links to other websites.  This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

8.0 Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on this web page.  This privacy policy was last updated on 6th June and the Version number is 1.4 in line with the new GDPR guidelines.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:
By email: enquiries@thebrick.org.uk
Or write to us at The Data Manager
10 Arcade Street
Wigan
WN1 2LU