Privacy Policy

Streatham Drop-in Centre for Asylum Seekers and Refugees

PRIVACY NOTICE

 

Streatham Drop-in Centre for Asylum Seekers and Refugees (registered charity number 1156824) (the “Centre”) is committed to protecting your privacy. At all times we aim to respect any personal information you share with us, or that we receive from other organisations, and keep it safe. This Privacy Notice (“Notice”) sets out our data processing practices and your rights and options regarding the ways in which your personal information is used.

 

This Notice contains important information about your privacy rights. Please read it carefully to understand how and why we use your personal information.

 

  1. We collect information about you:

            (1) When you give it to us directly

For example, by filling in forms on our website (including for contacting us or signing up to our    newsletters), communicating with us by phone, email or letter or        filling out a survey.

 

(2) When you give it to us indirectly

Your information may be shared with us by third parties including, for example, sub-contractors in technical, payment and delivery services; advertising networks; analytics providers and search information providers. To the extent we have not done so already, we will notify you when we receive information about you from them and tell you          how and why we intend to use that information.

 

(3) When it is available publicly

Depending on your privacy settings for social media services, we may access information        from those accounts or services.

 

(4) When you visit this website

When you visit this website, we automatically collect the following personal information:

(a) Technical information, including for example the internet protocol (IP) address used to           connect your computer to the internet.

(b) Information about your visit to this website, including for example the uniform resource         locator (URL) clickstream to, through and from the site (including date and time), page         response times, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.

 

In general, we may combine your personal information from these different sources for the purposes set out in this Notice.

 

  1. What personal information do we process?

We may collect, store and use the following kinds of personal information:

  • Your name and contact details, including postal address, telephone number, email address and, where applicable, social media identity.
  • Information about your computer / mobile device and your visits to and use of this website, including for example your IP address and geographical location.
  • Information about our services which you use/which we consider of interest to you.
  • any other information shared with us as per Section 1.

 

Do we process sensitive personal information?

The General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and political opinions. We will only process your sensitive personal information if there is a valid reason for doing so and where the GDPR allows us to do so.

 

  1. How and why will we use your personal information?

Your personal information, however provided to us, will be used for the purposes specified in this Notice.

 

In particular, we may use your personal information to:

  • provide you with services, products or information which you request (for example, to inform you about fundraising activities);
  • to communicate with you, including circulation of relevant news;
  • to send other types of communications to you, for example to notify you about any changes to our services or to answer any enquiries;
  • to administer this website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve your interactions with this website, for example by ensuring that content is presented in the most relevant and effective manner for you and for your computer;
  • to report on the results and impact of our work and services - for example the number of supporters;
  • as part of our efforts to keep this website and internal operations safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to conduct research into the impact and effectiveness of our work and services;
  • to deal with enquiries and/or complaints made by or about you;
  • to audit and/or administer our accounts;
  • prevention of fraud, misuse of services or money laundering; and/or
  • enforcement of legal claims.

 

  1. Communications for marketing/fundraising

We may use your contact details to provide you with information about our work, and/or services which we consider may be of interest to you (for example, events organised by the Centre that you have previously attended).

 

Where we do this via email, SMS or telephone (if you are registered with the telephone preference service), we will not do so without your consent.

 

  1. Will we share your personal information?

Otherwise, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Notice. Non-exhaustively, those third parties may include:

  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • Where required, we will obtain your consent to share your personal information for this purpose. You have the right to opt out of your personal information being used for advertising purposes by, for example, changing your browser settings. Please see our Cookie Notice for more information.
  • analytics and search engine providers that assist us in the improvement and optimisation of our operations and website; and/or
  • The Charity Commission, with whom we share aggregated information about use of our services and website.

 

In particular, we reserve the right to disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;
  • if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets; and/or
  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to satisfy our obligations under, enforce or apply terms of relevant agreements, for example to protect the rights, property, or safety of the Centre, event attendees, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

  1. Security/storage of and access to your personal information

We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destructions, misuse, alteration, unauthorised disclosure of or access to your personal information. For example, your information is only accessible by appropriately trained staff and contractors, and stored on our secure servers with features enacted to prevent unauthorised access.

 

In general, the personal information that we collect from you will be stored within the UK or European Economic Area ("EEA"). We do not use agencies and/or supplies to process personal information on our behalf.

 

Please note that we cannot guarantee the security of personal information transmitted via the internet.

 

  1. Your rights

You have the following privacy rights:

  • Right of access – you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exceptions that apply.

 

  • Right of erasure - you can ask us to delete your personal information from our records. In many cases we propose to anonymise that information, rather than delete it.

 

  • Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask us to update those records. You can also ask us to check the personal information that we hold about you if you are unsure whether it is up to date.

 

  • Right to restrict processing – you have the right to ask us to restrict the processing of your personal information if there is disagreement about its accuracy or legitimate usage.

 

  • Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of legitimate interests, (ii) using your personal information for direct marketing or (iii) using your personal information statistical purposes.

 

  • Right to data portability – where we are processing your personal information (i) because you gave us your consent, (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract, and the processing is carried out by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.

 

  • Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing/fundraising by electronic means (for example to be unsubscribed from our email newsletter list).

 

To exercise any of these rights, please send a description of the personal information in question using the contact details in section 15 below. Where we consider that the information with which you have provided to us does not enable us to identify the personal information in question, we reserve the right to ask for (i) personal identification and/or (ii) further information.

 

Please note that you may only use/benefit from some of these rights in limited circumstances. For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ or please contact us using the details in section 15 below.

 

You have the right to make a complaint to the ICO about us or the way we have processed your personal information. For further information on how to exercise this right, please see the guidance at https://ico.org.uk/for-the-public/personal-information. The contact details of the ICO can be found here: https://ico.org.uk/global/contact-us/.

  1. Lawful processing

The GDPR requires us to rely on one or more lawful grounds to process your personal information.

We consider the grounds listed below are relevant:

  • Where you have given consent to us for a particular purpose (for example, if you have signed up to our Newsletter).

 

  • Where necessary so we can comply with a legal obligation (for example where we are obliged to share your personal information with regulatory bodies who govern our work and services).

 

  • Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example if you purchase tickets to a Study Day, Masterclass or to our Convention).

 

  • Where there is a legitimate interest in us doing so.

The GDPR allows us to collect and process personal information if it is reasonably necessary to achieve our legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights).

In general, “legitimate interests” means the interests of running THE CENTRE as a charitable entity and pursuing our charitable aims; for example administering events. However, “legitimate interests” can also include your interests, such as when you have requested information or certain goods/services from us, and those of others.

 

In the unlikely event that we collect and use sensitive personal information about you (such as your health information) we will obtain your explicit consent beforehand.

 

  1. How long do we keep your personal information

In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove it from our records at the relevant time.

 

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.

 

  1. Changes to this Notice

We keep this Notice under regular review and may update it from time to time, so we recommend that you check it regularly. Where necessary we may also notify you of significant changes by email.

 

The Notice was last updated on 19 May 2018

 

  1. Third party websites

Our website contains links to other sites. This Notice does not cover external websites and we are not responsible for the content of sites and the ways in which they treat personal information. We encourage you to read the privacy policies of any external websites you visit via links on our website.

 

  1. How to contact us (including complaints)

We are a charity registered in England and Wales with the Charity Commission. Our registered office is at 2 Mitcham Ln, London SW16 6LG. However, if you wish to contact us please use the details below.

 

Please let us know if you have any questions or concerns about this Notice or about the way in which your personal information is being processed by contacting us via the following channels:

email: dropin@emchurch.plus.com

By telephone: 0208 664 7432

In each instance, please ask for or address your communication to Brian McCarthy