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: 15 Royal Crescent, Cheltenham, GL50 3DA
Data Protection Officer email address: [email protected]
Telephone number: 0300 365 8999
Postal Address: 15 Royal Crescent, Cheltenham, GL50 3DA
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):
· Date of birth
· 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, 15 Royal Crescent, Cheltenham, GL50 3DA.
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