Hannah Williams from Gloucestershire Clinical Commissioning Group is Sleeping Out

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Hannah Williams

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Privacy Notice

Caring for Communities and People (CCP) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our service users and stakeholders, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About CCP

Caring for Communities and People (CCP) is a registered Charity No. 1043143 and a Company Limited by Guarantee registered in England under company number 3002869.

Our Registered company address is: Wolseley House, Oriel Road, Cheltenham, GL50 1TH (NO correspondence to this address.)

Our Head Office address is: 340 High Street, Cheltenham, GL50 3JF

Data Protection Officer email address: [email protected]

Telephone number: 0300 365 8999

Postal Address: 340 High Street, Cheltenham, GL50 3JF

CCP is regulated by the Financial Conduct Authority under No. 735541 for the provision of Advice and Financial Inclusion services, and the Care Quality Commission under provider ID 1-3279008024 for the provision of Personal Care services.

CCP is accredited under ISO9001, Investors in People (Gold), Investors in Diversity, and Investing in Volunteers.

2. What Does This Notice Cover?

This Privacy Information explains how CCP uses your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data. It covers data collected in order that we can provide personalised support services to meet individual needs, and data collected through individual engagement with the charity, its events, its appeals or its provision of general information that may be of interest.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to us directly, and we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

· Name

· Date of birth

· Gender

· Address

· Email address

· Telephone number

· Health and disability

· Communication needs

· Information on income, benefits, debt

· Employment, training, education

· Information about your preferences, interests and aspirations

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for ONE OR ALL of the following purposes:

· Supplying our support services to you

· Personalising and tailoring our services to your individual needs

· Communicating with you. This may include responding to emails or calls from you

· Providing and managing your account on our website

· Providing you with information on appeals or events you have signed up for or may be interested in

· Supplying you with information by email, post, SMS or newsletter that you have opted-in to. You may unsubscribe or opt-out at any time by contacting us directly or updating your contact preferences through the link on our website or newsletter

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message, or post with information and news on our services, events or funding and sponsor opportunities. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

· Where we are contracted by a local authority or clinical commissioning group to provide a service to you, for the duration of the contract.

· Where you have given us consent to use your personal data for the purposes of marketing, fundraising, appeals or event management purposes, for the duration of your active relationship or involvement with us.

8. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data in the UK or the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

The security of your personal data is important to us, and to protect your data, we take a number of important measures, including the following:

Storing data securely in the UK within a robust, secure operations centre compliant with Information Security Code of Practice ISO27001
Storing data securely on servers or paper-based systems within CCP premises. Access to data held on our premises is restricted to individuals who are authorised to use your data in order to provide a service to you.

9. Do You Share My Personal Data?

In order to deliver an effective personalised support service to you, we may need to refer you to relevant services delivered by other support agencies or charities. In some cases, those third parties may require access to some or all of your personal data that we hold.

If any of your personal data is required by an agency partner, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8. We will seek your consent before transferring any of your personal data to a third party or agency partner.

Otherwise, we will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available on request for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 7 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the Data Controller):

Email address: [email protected]

Telephone number: 0300 365 8999.

Postal Address: CCP, 340 High Street, Cheltenham, GL50 3JF

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available through the CCP website at www.ccp.org.uk

By submitting this form you are agreeing to our terms and conditions

Terms and conditions of use 1. Introduction 1.1 These terms and conditions shall govern your use of our website. 1.2 By using our website, you accept these terms and conditions in full; accordingly, if you disagree with these terms and conditions or any part of these terms and conditions, you must not use our website. 1.3 If you register with our website, submit any material to our website or use any of our website services, we will ask you to expressly agree to these terms and conditions. 1.4 Our website uses cookies; by using our website or agreeing to these terms and conditions, you consent to our use of cookies in accordance with the terms of our privacy and cookies policy. 2. Credit 2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com). 3. Copyright notice 3.1 Copyright (c) 2019 Caring for Communities and People. 3.2 Subject to the express provisions of these terms and conditions: (a) we, together with our licensors, own and control all the copyright and other intellectual property rights in our website and the material on our website; and (b) all the copyright and other intellectual property rights in our website and the material on our website are reserved. 4. Licence to use website 4.1 You may: (a) view pages from our website in a web browser; (b) download pages from our website for caching in a web browser; (c) print pages from our website; (d) stream audio and video files from our website; and (e) use our website services by means of a web browser, subject to the other provisions of these terms and conditions. 4.2 Except as expressly permitted by Section 4.1 or the other provisions of these terms and conditions, you must not download any material from our website or save any such material to your computer. 4.3 You may only use our website for your own personal and business purposes, and you must not use our website for any other purposes. 4.4 Except as expressly permitted by these terms and conditions, you must not edit or otherwise modify any material on our website. 4.5 Unless you own or control the relevant rights in the material, you must not: (a) republish material from our website (including republication on another website); (b) sell, rent or sub-license material from our website; (c) show any material from our website in public; (d) exploit material from our website for a commercial purpose; or (e) redistribute material from our website. 4.6 Notwithstanding Section 4.5, you may redistribute our newsletter in print and electronic form to any person. 4.7 We reserve the right to restrict access to areas of our website, or indeed our whole website, at our discretion; you must not circumvent or bypass, or attempt to circumvent or bypass, any access restriction measures on our website. 5. Acceptable use 5.1 You must not: (a) use our website in any way or take any action that causes, or may cause, damage to the website or impairment of the performance, availability or accessibility of the website; (b) use our website in any way that is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity; (c) use our website to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or other malicious computer software; (d) conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction and data harvesting) on or in relation to our website without our express written consent; (e) access or otherwise interact with our website using any robot, spider or other automated means, except for the purpose of search engine indexing; (f) violate the directives set out in the robots.txt file for our website; or (g) use data collected from our website for any direct marketing activity (including without limitation email marketing, SMS marketing, telemarketing and direct mailing). 5.2 You must not use data collected from our website to contact individuals, companies or other persons or entities. 5.3 You must ensure that all the information you supply to us through our website, or in relation to our website, is true, accurate, current, complete and non-misleading. 6. Registration and accounts 6.1 To be eligible for an account on our website under this Section 6, you must be resident or situated in the United Kingdom. 6.2 You may register for an account with our website by completing and submitting the account registration form on our website, and clicking on the verification link in the email that the website will send to you. 6.3 You must not allow any other person to use your account to access the website. 6.4 You must notify us in writing immediately if you become aware of any unauthorised use of your account. 6.5 You must not use any other person's account to access the website. 7. User login details 7.1 If you register for an account with our website, you will be asked to choose a user ID and password. 7.2 Your user ID must not be liable to mislead and must comply with the content rules set out in Section 10; you must not use your account or user ID for or in connection with the impersonation of any person. 7.3 You must keep your password confidential. 7.4 You must notify us in writing immediately if you become aware of any disclosure of your password. 7.5 You are responsible for any activity on our website arising out of any failure to keep your password confidential, and may be held liable for any losses arising out of such a failure. 8. Cancellation and suspension of account 8.1 We may: (a) suspend your account; (b) cancel your account; at any time in our sole discretion without notice or explanation. 8.2 You may cancel your account on our website using your account control panel on the website. 9. Your content: licence 9.1 In these terms and conditions, "your content" means all works and materials (including without limitation text, graphics, images, audio material, video material, audio-visual material, scripts, software and files) that you submit to us or our website for storage or publication on, processing by, or transmission via, our website. 9.2 You grant to us a worldwide, irrevocable, non-exclusive, royalty-free licence to reproduce, store and publish your content on and in relation to this website and any successor website. 9.3 You grant to us the right to sub-license the rights licensed under Section 9.2. 9.4 You grant to us the right to bring an action for infringement of the rights licensed under Section 9.2. 9.5 You hereby waive all your moral rights in your content to the maximum extent permitted by applicable law; and you warrant and represent that all other moral rights in your content have been waived to the maximum extent permitted by applicable law. 9.6 You may edit your content to the extent permitted using the editing functionality made available on our website. 9.7 Without prejudice to our other rights under these terms and conditions, if you breach any provision of these terms and conditions in any way, or if we reasonably suspect that you have breached these terms and conditions in any way, we may delete, unpublish or edit any or all of your content. 10. Your content: rules 10.1 You warrant and represent that your content will comply with these terms and conditions. 10.2 Your content must not be illegal or unlawful, must not infringe any person's legal rights, and must not be capable of giving rise to legal action against any person (in each case in any jurisdiction and under any applicable law). 10.3 Your content, and the use of your content by us in accordance with these terms and conditions, must not: (a) be libellous or maliciously false; (b) be obscene or indecent; (c) infringe any copyright, moral right, database right, trade mark right, design right, right in passing off, or other intellectual property right; (d) infringe any right of confidence, right of privacy or right under data protection legislation; (e) constitute negligent advice or contain any negligent statement; (f) constitute an incitement to commit a crime, instructions for the commission of a crime or the promotion of criminal activity; (g) be in contempt of any court, or in breach of any court order; (h) be in breach of racial or religious hatred or discrimination legislation; (i) be blasphemous; (j) be in breach of official secrets legislation; (k) be in breach of any contractual obligation owed to any person; (l) depict violence in an explicit, graphic or gratuitous manner; (m) be pornographic, lewd, suggestive or sexually explicit; (n) be untrue, false, inaccurate or misleading; (o) consist of or contain any instructions, advice or other information which may be acted upon and could, if acted upon, cause illness, injury or death, or any other loss or damage; (p) constitute spam; (q) be offensive, deceptive, fraudulent, threatening, abusive, harassing, anti-social, menacing, hateful, discriminatory or inflammatory; or (r) cause annoyance, inconvenience or needless anxiety to any person. 11. Limited warranties 11.1 We do not warrant or represent: (a) the completeness or accuracy of the information published on our website; (b) that the material on the website is up to date; or (c) that the website or any service on the website will remain available. 11.2 We reserve the right to discontinue or alter any or all of our website services, and to stop publishing our website, at any time in our sole discretion without notice or explanation; and save to the extent expressly provided otherwise in these terms and conditions, you will not be entitled to any compensation or other payment upon the discontinuance or alteration of any website services, or if we stop publishing the website. 11.3 To the maximum extent permitted by applicable law and subject to Section 12.1, we exclude all representations and warranties relating to the subject matter of these terms and conditions, our website and the use of our website. 12. Limitations and exclusions of liability 12.1 Nothing in these terms and conditions will: (a) limit or exclude any liability for death or personal injury resulting from negligence; (b) limit or exclude any liability for fraud or fraudulent misrepresentation; (c) limit any liabilities in any way that is not permitted under applicable law; or (d) exclude any liabilities that may not be excluded under applicable law. 12.2 The limitations and exclusions of liability set out in this Section 12 and elsewhere in these terms and conditions: (a) are subject to Section 12.1; and (b) govern all liabilities arising under these terms and conditions or relating to the subject matter of these terms and conditions, including liabilities arising in contract, in tort (including negligence) and for breach of statutory duty, except to the extent expressly provided otherwise in these terms and conditions. 12.3 To the extent that our website and the information and services on our website are provided free of charge, we will not be liable for any loss or damage of any nature. 12.4 We will not be liable to you in respect of any losses arising out of any event or events beyond our reasonable control. 12.5 We will not be liable to you in respect of any business losses, including (without limitation) loss of or damage to profits, income, revenue, use, production, anticipated savings, business, contracts, commercial opportunities or goodwill. 12.6 We will not be liable to you in respect of any loss or corruption of any data, database or software. 12.7 We will not be liable to you in respect of any special, indirect or consequential loss or damage. 12.8 You accept that we have an interest in limiting the personal liability of our officers and employees and, having regard to that interest, you acknowledge that we are a limited liability entity; you agree that you will not bring any claim personally against our officers or employees in respect of any losses you suffer in connection with the website or these terms and conditions (this will not, of course, limit or exclude the liability of the limited liability entity itself for the acts and omissions of our officers and employees). 13. Breaches of these terms and conditions 13.1 Without prejudice to our other rights under these terms and conditions, if you breach these terms and conditions in any way, or if we reasonably suspect that you have breached these terms and conditions in any way, we may: (a) send you one or more formal warnings; (b) temporarily suspend your access to our website; (c) permanently prohibit you from accessing our website; (d) commence legal action against you, whether for breach of contract or otherwise; and/or (e) suspend or delete your account on our website. 13.2 Where we suspend or prohibit or block your access to our website or a part of our website, you must not take any action to circumvent such suspension or prohibition or blocking (including without limitation creating and/or using a different account). 14. Variation 14.1 We may revise these terms and conditions from time to time. 14.2 The revised terms and conditions shall apply to the use of our website from the date of publication of the revised terms and conditions on the website, and you hereby waive any right you may otherwise have to be notified of, or to consent to, revisions of these terms and conditions. 14.3 If you have given your express agreement to these terms and conditions, we will ask for your express agreement to any revision of these terms and conditions; and if you do not give your express agreement to the revised terms and conditions within such period as we may specify, we will disable or delete your account on the website, and you must stop using the website. 15. Assignment 15.1 You hereby agree that we may assign, transfer, sub-contract or otherwise deal with our rights and/or obligations under these terms and conditions. 15.2 You may not without our prior written consent assign, transfer, sub-contract or otherwise deal with any of your rights and/or obligations under these terms and conditions. 16. Severability 16.1 If a provision of these terms and conditions is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. 16.2 If any unlawful and/or unenforceable provision of these terms and conditions would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect. 17. Third party rights 17.1 A contract under these terms and conditions is for our benefit and your benefit, and is not intended to benefit or be enforceable by any third party. 17.2 The exercise of the parties' rights under a contract under these terms and conditions is not subject to the consent of any third party. 18. Entire agreement 18.1 Subject to Section 12.1, these terms and conditions, together with [our privacy and cookies policy, shall constitute the entire agreement between you and us in relation to your use of our website and shall supersede all previous agreements between you and us in relation to your use of our website. 19. Law and jurisdiction 19.1 These terms and conditions shall be governed by and construed in accordance with English law. 19.2 Any disputes relating to these terms and conditions shall be subject to the exclusive jurisdiction of the courts of England. 20. Statutory and regulatory disclosures 20.1 We are registered with Companies House. You can find the online version of the register at https://www.gov.uk/government/organisations/companies-house , and our registration number is 3002869. 20.2 We are registered as a Charity with the Charity Commission in the United Kingdom. You can find the online version of the register at http://apps.charitycommission.gov.uk/Showcharity/RegisterOfCharities/registerhomepage.aspx , and our registration number is 1043143. 21. Our details 21.1 This website is owned and operated by Caring for Communities and People Ltd 21.2 We are registered in England and Wales under registration number 3002869, and our registered office is at Wolseley House, Oriel Road, Cheltenham, GL50 1TH. 21.3 Our principal place of business is at 340 High Street, Cheltenham, GL50 3JF. 21.4 You can contact us: (a) by post, using the postal address given above; (b) using our website contact form; (c) by telephone, on 0300 365 8999