Sandwell Parents for Disabled Children (SPDC) is committed to data protection and data privacy. With the General Data Protection Regulation (GDPR) becoming enforceable from 25 May 2018, we have undertaken a GDPR readiness programme to review our entire organisation, the way we handle data and the way in which we use it to provide our services and manage operations.
We hold personal data on all our service users to meet legal obligations and to perform vital internal functions. This notice details the personal data we may retain, process and share with third parties relating to your participation and vital organisational operations. We are committed to ensuring that your information is secure, accurate and relevant. To prevent unauthorised access or disclosure, we have implemented suitable physical, electronic, and managerial procedures to safeguard and secure personal data we hold.
We have issued this notice to describe how we handle personal information that we hold about our service users (collectively referred to as "you"). We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This notice sets out the personal data that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.
If you are in any doubt regarding this notice, please contact Diane Rai, Manager.
Types of personal data we collect
During your registration with us, we may process personal data about you and your dependents, and other individuals whose personal data has been provided to us. The types of personal information we may process include, but are not limited to:
Sensitive personal data (‘special categories of personal data’ under the General Data Protection Regulation) includes any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification, trade union membership, or information about your health. Generally, we try not to collect or process any sensitive personal information about you, unless authorised by law or where necessary to comply with applicable laws. In some circumstances, we need to collect some sensitive personal information for legitimate purposes, for example:
- Identification data – such as your name, gender, photograph, date of birth.
- Contact details – such as home and business address, telephone/email addresses, emergency contact details.
- Spouse & dependents information, marital status.
- data relating to your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations
- data relating to your physical or mental health to accommodate accessible opportunities
Purposes for processing personal data
We collect and process personal data relating to our service users to meet our obligations under our funding contracts and to comply with our legal obligations. We take the security of your data seriously and are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
Once you become a service user, we collect and use this personal information for managing our working relationship with you – for example, your contact information (so we can get in touch with you or send you information), your date of birth (so we can send you relevant information) and details of your spouse and dependents (for emergency contact purposes). Where we process special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that we use for these purposes is anonymised or is only collected with the express consent of service users, which can be withdrawn at any time. We have policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed without authorisation and only accessed or used for specific legal purposes.
Legitimate business purposes
We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us run our organisation more effectively and efficiently – for example for general IT security management, accounting purposes or financial planning. We may also process your personal information to investigate violations of law or breaches of our own internal policies.
Legal basis for processing personal data
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the way we collect it. We will normally collect personal data from you only where we need it to perform a service for you (i.e. to manage the service user relationship), where we have your freely given consent to do so, or where the processing is in our legitimate interests and only where this interest is not overridden by your own interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. Any processing based on consent will be made clear to you at the time of collection or use – consent can be withdrawn at any time by contacting Diane Rai, Manager.
Who we share your personal data with
We take care to allow access to personal data only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the data is used in a manner consistent with this notice and that the security and confidentiality of the data is maintained.
Transfers to third-party service providers
In addition, we make certain personal data available to third parties who provide services to us. We do so on a "need to know basis" and in accordance with applicable data protection and data privacy laws. For example, some personal data will be available to third-party companies who provide us with health and safety support, or funding for specific activities.
Transfers to other third parties
We may also disclose personal data to third parties on other lawful grounds, including:
- To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process
- In response to lawful requests by public authorities (including for national security or law enforcement purposes)
- As necessary to establish, exercise or defend against potential, threatened or actual litigation
- Where necessary to protect the vital interests of our employees or another person, or
- With your freely given and explicit consent
Personal data will be stored in accordance with applicable laws and kept for as long as needed to carry out the purposes described in this notice or as otherwise required by law.
You may exercise the rights available to you under data protection law as follows:
- The right to be informed.
- The right of access.
- The right to rectification.
- The right to erasure.
- The right to restrict processing.
- The right to data portability.
- The right to object.
- Rights in relation to automated decision making and profiling.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You can read more about these rights at: https://ico.org.uk/for-the-public/is-my-information-being-handledcorrectly/
To exercise any of these rights, please contact Diane Rai, Manager.
Issues and complaints
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This notice was drafted with clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body which oversees data protection law – www.ico.org.uk/concerns.
Updates to this notice
This notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, we will inform you by email. We encourage you to check this notice periodically to be aware of the most recent version.
Please address any questions or requests relating to this notice to Diane Rai, Manager, [email protected]