Your privacy is important to us. At CLEAR we value everyone who engages with us by whatever means, and we do all we can to protect your privacy and to make sure the personal data you give us is kept safe. This policy explains how we collect data, how we use and store that data and what it means for you.
2. WHO WE ARE
CLEAR (City Life Education and Action for Refugees) is part of City Life Church Southampton. The mission of CLEAR is to help those fleeing persecution to build new lives in Southampton.
City Life Church Southampton is a charity registered in England and Wales (number 1100602). City Life Church Southampton’s company number is 4913171 and its registered office is 286 Burgess Road, Southampton SO16 3BE.
3. WHAT INFORMATION DO WE COLLECT?
Information collected by CLEAR
We collect personal information when it is needed to fulfil a service for you, for example, when you come to us for advice, to enrol on a course, request information, sign up for an event or otherwise voluntarily provide your personal details. We collect the information you provide, which may include your name, email address, home address and/or telephone number.
You are not required to provide personal data to us, however, a decision not to provide personal data may affect our ability to provide the services you request. For example, we are unable to contact you about events or training opportunities if you do not give consent for us to use your contact information for this purpose.
Information collected by visiting our website
When visiting the CLEAR website, we follow standard practices and may use features which collect your IP address and data on which pages you are visiting on our site. Similarly, as for many websites, we may also issue cookies to enable certain features to function properly, track traffic or improve user experience in other ways. Cookies place certain information on your device to allow this to happen. This allows us to tailor your experience to what we think you want to see.
Information collected via social media
Depending on your own settings or the policies of social media and messaging services such as Facebook, Whatsapp or Twitter, YouTube and Instagram you may be providing CLEAR and other organisations access to certain information. If you have concerns, you should check with those services to ensure you’re happy with that information being shared.
Information collected from third parties
We use third party sites to enable you to donate to CLEAR. We will store any information that they collect from you and pass on to us in order to provide the donation service. If you have concerns, you may wish to check their privacy policies to find out more information on how they will process your data.
Information collected by CLEAR personnel (the term ‘personnel’ includes Representatives, Associates, paid staff and Trustees)
As you interact with CLEAR personnel, there will be occasions where we will collect and store basic personal information which you have given to us through them. These details may be shared within CLEAR, but only for the purposes for which you gave the information in the first place.
4. LEGAL BASIS
- Consent: You have given clear consent for us to process your personal data for a specific purpose.
- Contract: The processing is necessary for a contract we have with you.
- Legal obligation: The processing is necessary for us to comply with the law.
- Vital interests: The processing is necessary to protect someone’s life.
- Public task: The processing is necessary for us to perform a task in the public interest.
- Legitimate interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party.
We store the data you provide in cloud-based password-protected systems (e.g. AdvicePro, Microsoft OneDrive, DropBox, MailChimp, Gmail) and/or in paper form stored in filing cabinets which are locked when not in use.
Where the data is provided for financial support, we store and process your data in order to comply with current charitable and financial legislation, such as processing donations and claiming the related Gift Aid. This is a legal obligation.
We collect and process personal data for the purpose of entering into contractual relationships or for pre-contractual steps at the request of the individual, such as data processed on behalf of City Life Church employees and City Life Church-appointed Representatives.
We require consent from you as to whether we may contact you to promote CLEAR activities, events and fundraising, including the method of contact you prefer.
5. WHAT DO WE DO WITH YOUR INFORMATION?
Providing an advice service
Where you provide personal data and sensitive personal data, CLEAR personnel we may use that information to provide you with the advice service you request. This information will be used only by CLEAR personnel who are required to do so in order to fulfil their responsibilities. We may be required to show your personal data and sensitive personal data to external auditors as part of a periodic advice quality audit, but other than this we will not share your information without your permission.
Providing educational classes
Where you provide personal data and sensitive personal data to enquire about or enrol on a CLEAR course, CLEAR personnel may use that information to provide the service you request. This information will be used only by CLEAR personnel who are required to do so in order to fulfil their responsibilities, and will only be shared with course funders if required.
Processing of requests and donations
We may use the personal data we collect to do one or more of the following:
- Process donations you give us, including claiming gift aid;
- Provide information or materials you have requested;
- Keep you up to date on news and stories about our activities and work;
- Ask for financial and non-financial support, such as volunteering;
- Keep records of your relationship with us, e.g. questions you have asked.
Applying for a job or volunteering with us
Where you provide personal data and sensitive personal data when applying for a job with us, we will process, store and disclose the personal data we collect to:
- Support the recruitment process;
- Answer any questions you may have;
- Use third parties to provide services such as references.
Where you provide personal data or sensitive personal data, such as dietary requirements, mobility requirements or health information, we will store, process and disclose the personal information we collect to:
- Deliver the volunteering opportunity, including the disclosure of sensitive data, such as medical information, (e.g. to ensure the safety of children in a crèche);
- Provide the administration of these events or opportunities to serve;
- Use third parties to provide services such as references and criminal referencing, such as DBS checks;
- Provide appropriate support;
- Answer any questions or feedback you may have.
6. HOW AND WHERE DO WE STORE YOUR INFORMATION?
How long we store your information
We will keep your personal information only for as long as we consider it necessary to carry out each activity. We take account of legal obligations and accounting and tax considerations as well as considering what would be reasonable for the activity concerned.
For example, we will retain details of donations for up to 10 years to meet tax and accounting requirements, but we will hold personal data and sensitive personal data regarding the advice we have given to you for 6 years beyond the last date you consulted us.
We ensure that we have in place appropriate controls to protect any personal data you provide. We ensure that access to personal data is restricted only to those personnel whose roles require such access and that suitable training is provided for these people.
We may make limited use from time to time of external companies to process personal data on our behalf. For example, we may use Local Giving to receive donations. When we do use external companies, we remain responsible for the storing and processing of your personal data. We do not store credit card details.
Where we store your personal information
We store the data you provide in our cloud-based password-protected systems (e.g. AdvicePro, Microsoft OneDrive, DropBox, MailChimp, Gmail). Hard copies are stored in locked filling cabinets.
We take all reasonable steps to ensure that your data is stored and processed securely, whether in electronic or hard copy formats, and is protected from unauthorised access, use or disclosure.
7. WITH WHOM DO WE SHARE YOUR INFORMATION?
We may need to pass on information if required by law or by a regulatory body, for example, as part of a Gift Aid audit by HMRC or if required to do so by law.
We may use third parties to carry out tasks on our behalf, such as posting emails through MailChimp or donations through Local Giving. Some of our service providers (e.g. MailChimp) lie outside of the European Economic Area (EEA). Therefore, sometimes we transfer your data outside the EEA. These agents are bound by contract to protect your data and we remain responsible for their actions. For a copy of their safeguards, please contact us at firstname.lastname@example.org or 023 8022 1111.
We may ask for details concerning children to provide appropriate services, such as crèche groups. This may include medical and allergy information. If a child is over 16 we may collect information directly from the child, which will be processed in an age-appropriate manner.
9. YOUR RIGHTS
Current legislation provides the following rights for individuals in relation to their personal data:
- 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.
To find out more about what these rights mean for you, please refer to the Information Commissioner’s website: https://ico.org.uk/
Seeing your personal information, changing your personal information and consent preferences
You can update your personal information and/or change your preferences on what you receive from us, including marketing and fundraising materials, or how we contact you, by email, mail or phone at any time:
- CLEAR Project, 2 James Street, Southampton SO14 1PJ
- 023 8022 1111
Deleting your personal information
You have the right to ask us to delete your personal data, to ask us to restrict our processing or to object to our processing of your personal data. You can do so at any time by writing to the Data Controller, CLEAR, 2 James Street, Southampton, SO14 1PJ. This right covers all data held by us whether centrally or by our contractors.
Please note that we may need to hold onto data for legal reasons, e.g. financial information for auditing purposes. In these cases we will store the minimum data required and will delete it as soon as we are able.
10. CHANGES TO THIS STATEMENT
This statement was last updated in May 2018.