Data protection and privacy
The Hub takes data protection and your privacy very seriously. Set out below is its policy in relation to the protection of your personal information and your rights to privacy.
This policy was last updated in: September 2022
Reasons for holding your personal information
There are four potential reasons for holding or using your personal information:
~ You have given us explicit permission to hold and use your personal information for specific purposes which we have notified to you;
~ We hold your personal information in order to fulfil a contractual obligation that we believe we have taken on;
~ We hold your personal information as we believe that we have a legitimate interest in doing so; or
~ We hold your personal information in order to comply with our current understanding of the legal requirements around record keeping.
Please see below, why we might be holding your personal information and for what purposes.
Your rights under under the law
You have a number of rights under the law relating to data privacy. If you have any concerns about personal information we may hold on you, please get in touch with Ian Vale, our Data Protection Officer at firstname.lastname@example.org
If you want an independent view on those rights, we recommend looking at the website of the Information Commissioner’s Office by following this link.
Our purposes for holding your personal information and what we will do with it are as follows:
1. If you have asked to receive information about what we do and opportunities to help support our work with the youth of Claygate and its surrounding areas, then we will keep your personal information for six years from June 2021, and will periodically send you such information.
2. If you have attended one of our fundraising events, we believe we have both a contractual and legal basis for holding your personal information for a period of three years relating to the event. We also believe that in return for your support we incur an obligation to keep you in touch with the work that you have helped support and with opportunities to keep on supporting that work. We will keep your personal information for six years from June 2021, and will periodically send you such information.
3. If you have given us a separate donation, then we believe we have a contractual and legal basis for holding your personal information related to that donation. We currently believe that our legal obligations related to the donation itself may require us to hold your personal information for 7 years. We also believe that in return for your support we incur an obligation to keep you in touch with the work that you have helped support and with opportunities to keep on supporting that work. We will keep your personal information for six years from June 2021 for this purpose, and will periodically send you such information.
4. If you have hired our hall for events that you are holding, we are required by our landlord, Surrey County Council, to hold regular Building User Meetings and also to report on the bookings that we have had in the last 12 months and forward bookings. This information has to be provided to the User Group on a quarterly basis. We will keep your personal information in order to fulfill these obligations, unless and until you inform us that you do not wish to be informed of and invited to the Building User Group meetings.
5. If you are a member of the youth club or a parent or guardian of a member of the youth club, we will hold your personal information in order to invite you (or your child) to events, inform you of youth club activities, and to make sure that we have the information required to respond to any emergency that you (or your child) may be involved in under our care. We will also use that personal information to contact you and, where applicable, your parents for feedback on the services we are providing. We will keep your personal information until you instruct us otherwise or for three years after you have stopped attending the Youth Club, whichever is the earlier. In the case of the personal information of a child, their parents or legal guardian’s consent will be obtained before we hold any personal information in relation to that child.
6. If you are a volunteer we will hold your personal information for the purpose of our ongoing safeguarding obligations and in order to correspond with you about volunteering opportunities, including in relation to youth club activities. We will keep your personal information until you instruct us otherwise or for 3 years after you have ceased to volunteer for us, whichever is the earlier.
Your personal information may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting personal information we receive from you on the website to personal information available from other
sources. Your personal information will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us.
In the case of this activity the following will apply:
1) Your personal information will be made available to our website provider.
2) The personal information that may be available to them include any of the personal information we collect as described in this policy.
3) Our website provider will not transfer your personal information to any other third party, or transfer your personal information outside of the EEA.
4) They will store your personal information for a maximum of 6 years.
Our obligations in relation to your personal information
The Hub will ensure that all personal information that it holds will be:
processed lawfully, fairly and in a transparent manner;
collected for specified, explicit and legitimate purposes (please see above) and not further processed in a manner that is incompatible with those purposes;
adequate, relevant and limited to what is necessary;
accurate and kept up to date;
kept in a form which permits identification of you, as the data subject, for no longer than is necessary;
processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
How we comply with these rules
• All computers on which your personal information is held are password protected.
• All databases are password protected.
• Any paperwork containing your personal information is kept in a locked file/cabinet when not in use.
• Paperwork or laptops transported between venues are carried in locked carry cases.
• Documents with personal information will not be left out on a desk if the person who has possession of it is not working on it;
• Computers with your personal information will not be open if the person responsible for the safekeeping of the personal information is not there.
• Only designated people within The Hub have access to the personal information. These are:
the Centre manager and youth club leader - Katie Holmes;
the Chair of Trustees and Safeguarding Officer - Susannah Moffat;
The people responsible for volunteers - Susannah Moffat, Vicki Schmidt and Katie Holmes.
• We will only keep personal information for as long as is necessary.
• A paper shredder will be used to dispose of any hard copy documents that contain personal information.
If at any stage you want us to stop sending you information and/or to cease holding your personal information, then please let us know at either of the email address below and we shall do so.
You have the right to see what personal information we hold and to request that any errors or omissions are corrected immediately. Please make any request to see your personal information in writing and sign and date that request. We will call you to verify your request.
Chair of Trustees
Please contact us on the following email in relation to any personal information we hold: email@example.com