Privacy Notice – May 2018
Should you have a question about any of these Privacy Notices or the information we store, please contact the CEO of ihAg by email or by post to the CEO, ihAg, 22 – 24 Carr Street, Ipswich IP4 1EJ or by phone on 01473 213102
1 Introduction
ihAg respects your privacy and is committed to protecting your personal data. This privacy notice will provide you with information about how we look after your personal data and tell you about your privacy rights and how the law protects you.
This Privacy Notice covers how we collect, use, store, and disclose the data that you supply to us and your rights about data that we hold about you.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice supplements those other notices and is not intended to override them.
ihAg holds a wide range of data and information on individuals and organisations for the purpose of carrying out its charitable Objects which are:
2 Legally Required Data Protection Principles
The data protection principles set out the main responsibilities for organisations. Personal data shall be:
3 ihAg’s Data Protection Values
At ihAg we collect and use your personal information to help solve your problems, improve our services and tackle wider issues in society that affect people’s lives.
For these reasons:
When we record and use your personal information we:
Privacy Notices will always consist of the following Sections:
Additionally, depending on relevance and appropriateness, the following may be included
4 Managing Data on the Behalf of Others
Where ihAg, or a particular ihAg staff member, manages a professional network/forum, the specific network will have its own privacy statement that relates specifically to that network and which will set out the information that ihAg will hold, the reason for holding that information, what we will and will not do with that information and a simple option to opt out.
To facilitate the different ways that you interact with ihAg, there are specific Privacy Notice for each type of interaction as set out below.
Advice Services Privacy Notice – Chapman Centre and Money Advice
This Privacy Notice is subject to ihAg’s overarching Privacy Notice which can be found above.
ihAg is committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve.
This Privacy Notice covers how we collect, use, store, and disclose the data that you supply to us and your rights about data that we hold about you.
For more information please contact the Data Protection Officer, (the CEO of ihAg), who will provide you with our Data Protection Policy.
The Information we collect from you
Personal data includes any information about an individual from which that person can be identified.
It does not include data where the identity has been removed (anonymous data). We will collect, store, and use the following categories of personal information about you:
Sensitive Personal Information and Information about Criminal Convictions
We may also collect, store and use “special categories” of more sensitive personal data which require a higher level of protection:
How the Information is Collected
We may use the following ways to collect personal information about you, from when you are initially referred to the service until you are no longer receiving advice from us or your case is closed:
When we will use your Personal Information
We may use your information for a number of different purposes, which include:
The Legal Basis for processing your Personal Data
We process personal data if it is necessary to deliver a service to you. The law sets out six available lawful bases for processing your data:
Disclosure/Data Sharing
We will get your permission by either signing a consent form or verbally over the telephone, to share information with other organisations:
Safeguarding
Children and adults with care and support needs are recognised as needing protection. If someone is identified as being at risk from harm we have a responsibility to protect them. There are laws in place allowing us to share safeguarding concerns with other relevant agencies whether or not consent is given.
Transfers of Data Outside of the EU
We may transfer the personal information we collect about you outside the EU in order to perform our contract with you. We use Microsoft Office365 services which cover our email and other cloud-based services, these services are based on a UK geo location but some of those services may be hosted across other locations. Further information is available from the Data Protection Officer, (the CEO of ihAg).
For how long we keep your Data
If we provide advice or undertake casework (that is, an Adviser assists you over a period of time), we keep your information for 6 years (or 7 for tax information) from when we close your case and then anonymise it.
If you never receive advice, we keep your information for 1 year following referral to our service.
If you use the Chapman Centre as a safe mailing address and do not collect your mail within three months, we will seek to return it to the sender. Where this is not possible, we will destroy it.
CCTV images are normally kept for a maximum of 6 weeks unless there is an incident, which requires us to keep it for longer (for example, if we receive a legal request to provide CCTV images by the court or the police).
If you have been involved in a serious incident at ihAg, we may keep relevant personal data for longer than the periods detailed above.
Your Rights
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
For Chapman Centre, please contact admin@ihagcc.co.uk or telephone 01473 232426 and inform us of the consent you wish to withdraw.
For Money Advice, please contact mas@ihag.co.uk or telephone 01473 213102 (Option 1 for the Money Advice department) and inform us of the consent you wish to withdraw.
Complaints & Questions
If you have any questions about this privacy notice or how we handle your personal information, please contact a Manager. If we have breached our duty of care, we will take appropriate action.
If you are not satisfied by our response you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (Email: casework@ico.org.uk)
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Housing (in relation to Housing Related Support)
This Privacy Notice is subject to IHAG’s overarching Privacy Notice which can be found above.
ihAg is committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve.
This Privacy Notice covers how we collect, use, store and disclose the data that you supply to us and your rights about data that we hold about you.
For more information please contact the Data Protection Officer, (the CEO of ihAg), who will provide you with our Data Protection Policy.
The Information we collect from you
Personal data includes any information about an individual from which that person can be identified.
It does not include data where the identity has been removed (anonymous data). We will collect, store, and use the following categories of personal information about you:
Sensitive Personal Information and Information about Criminal Convictions
We may also collect, store and use “special categories” of more sensitive personal data which require a higher level of protection:
How the Information is collected
We may use the following ways to collect personal information about you, from when you are initially referred to the service until you are no longer receiving advice from us or your case is closed:
When we will use your Personal Information
We may use your information for a number of different purposes, which include:
The Legal Basis for processing your Personal Data
We process personal data if it is necessary to deliver a service to you. The law sets out six available lawful bases for processing your data:
Disclosure/Data Sharing
We will get your permission by either signing a consent form or verbally over the telephone, to share information with other organisations:
Safeguarding
Children and adults with care and support needs are recognised as needing protection. If someone is identified as being at risk from harm we have a responsibility to protect them. There are laws in place allowing us to share safeguarding concerns with other relevant agencies whether or not consent is given.
Transfers of Data Outside of the EU
We may transfer the personal information we collect about you outside the EU in order to perform our contract with you. We use Microsoft Office365 services which cover our email and other cloud-based services, these services are based on a UK geo location but some of those services may be hosted across other locations. Further information is available from the Data Protection Officer, the CEO of ihAg.
For how long we keep your Data
We keep case notes and other information for no longer than 6 years, except where we have a legal and legitimate reason to keep it for longer (such as licence agreements, debt owed to ihAg and serious incidents involving you). In most cases information will be handed back to you on exiting the service (such as proof of income).
If you continue to use ihAg as a safe mailing address after exiting the service, we will help you to seek an alternative address, to which we will forward your mail. If you do not collect your mail within one month, we will seek to return it to the sender. Where this is not possible, we will destroy it.
CCTV images are normally kept for a maximum of 7 days unless there is an incident, which requires us to keep it for longer (for example, if we receive a legal request to provide CCTV images by the court or the police).
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
If you wish to withdraw consent, please contact your Housing Support Co-ordinator (if you are currently housed or receiving a service from ihAg’s Housing Team) or ruth@ihag.co.uk or telephone 01473 213102 (Option 2 for the Housing department) and inform us of the consent you wish to withdraw.
Complaints & Questions
If you have any questions about this privacy notice or how we handle your personal information, please contact a Manager. If we have breached our duty of care, we will take appropriate action.
If you are not satisfied by our response you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (Email: casework@ico.org.uk)
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Framework Forum
This Privacy Notice is subject to ihAg’s overarching Privacy Notice which can be found above.
The ILHP will hold your contact details, and those of your organisation, for the sole purpose of keeping in touch with you and your organisation about the ILHP and ILHP related issues.
We will keep your contact details safe and secure and will never sell, market or in any other way use your contact details.
To opt out of this network, please click here and send the auto-generated email with an explanation if at all possible.
The ILHP Manager is employed by IHAG and therefore is subject to ihAg’s Privacy Statement, the relevant passage of which states:
Where ihAg, or a particular ihAg staff member, manages a professional network/forum, the specific network will have its own privacy statement that relates specifically to that network and which will set out the information that ihAg will hold, the reason for holding that information, what we will and will not do with that information and a simple option to opt out.
To aid effective communication, when we email the ILHP network, we will show the names and email addresses of all the recipients – in this way you will know who else has received the communique. Recipients will not use the ‘cc’ addresses to ‘reply to all’ unless specifically requested to do so.
In this way, the integrity of the ILHP communiques are maintained and are not used by recipients to contact the whole network. Should people wish to contact the whole network, they are expected to do so by contacting the Locality Manager and they will manage the communication if appropriate.
Money Advice Forum
This Privacy Notice is subject to ihAg’s overarching Privacy Notice which can be found above.
ihAg,s Money Advice Service team are subject to ihAg’s Privacy Notice, the relevant passage of which states:
“Where ihAg, or a particular ihAg staff member, manages a professional network/forum, the specific network will have its own privacy statement that relates specifically to that network and which will set out the information that ihAg will hold, the reason for holding that information, what we will and will not do with that information and a simple option to opt out.”
ihAg’s Money Advice Service will hold your contact details for the sole purpose of keeping in touch with you about the Money Advice Forum (MAF) and MAF related issues.
We will keep your contact details safe and secure and will never sell market or in any other way use your contact details.
To opt out of this network, please click here and send the auto-generated email with an explanation if at all possible.
To aid effective communication, when we email the MAF network, we will show the names and email addresses of all the recipients – in this way you will know who else has received the communique.
ILHP - Privacy Statement
This Privacy Notice is subject to ihAg’s overarching Privacy Notice which can be found above.
The ILHP will hold your contact details, and those of your organisation, for the sole purpose of keeping in touch with you and your organisation about the ILHP and ILHP related issues.
We will keep your contact details safe and secure and will never sell, market or in any other way use your contact details.
To opt out of this network, please click here and send the auto-generated email with an explanation if at all possible.
The ILHP Manager is employed by ihAg and therefore is subject to ihAg’s Privacy Statement, the relevant passage of which states:
Where ihAg, or a particular ihAg staff member, manages a professional network/forum, the specific network will have its own privacy statement that relates specifically to that network and which will set out the information that ihAg will hold, the reason for holding that information, what we will and will not do with that information and a simple option to opt out.
To aid effective communication, when we email the ILHP network, we will show the names and email addresses of all the recipients – in this way you will know who else has received the communique. Recipients will not use the ‘cc’ addresses to ‘reply to all’ unless specifically requested to do so.
In this way, the integrity of the ILHP communiques are maintained and are not used by recipients to contact the whole network. Should people wish to contact the whole network, they are expected to do so by contacting the Locality Manager and they will manage the communication if appropriate.
This Privacy Notice is subject to ihAg’s overarching Privacy Notice which can be found above.
Cookies
Cookies are small text files that are placed on your computer or smartphone by websites that you visit. They allow the website to recognise your device and store some information about your preferences or past actions. They are also used to make websites work or work more efficiently.
How we use cookies
When the website opens it will ask you if a Cookie can be placed on your computer’s hard drive. Once you agree, the file is added and the Cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We also use traffic log cookies to identify which pages are being used so that we can analyse data about web page traffic and improve the website experience for our visitors.
Please note that we only use this information for statistical analysis purposes and then the data is removed from the system.
Our cookies never give us access to your computer or any information about you, other than the data you choose to share with us.
Should you wish, you can choose to decline cookies. Your web browser will normally automatically accept cookies, but you can usually modify its settings to decline cookies if you prefer. We suggest consulting the Help section of your browser or taking a look at the following websites www.aboutcookies.org or www.allaboutcookies.org which will tell you about cookies and how to remove them from your browser. However. in a few cases. some of our website features may not function as a result.
Google Analytics
The ihAg is website sets “first party” cookies through its use of Google Analytics. We use Google Analytics to provide us with non-personal site analytics, which in turn help us improve this website. Google Analytics tracking uses cookies in order to provide meaningful reports about web site visitors’ but they do not collect personal data about you. Google Analytics sets or updates cookies only to collect data required for the reports. Additionally, Google Analytics only uses first-party cookies. This means that all cookies set by Google Analytics cannot be altered or retrieved by any service on any domain other than [yourdomain.com]. Further detailed information on Google Analytics cookies can be found here.
Other websites
Our website may contain links to other websites. This privacy policy only applies to this website so when you visit to other websites you should read their own privacy policies.
Media – Photographs / Recordings / Videos / Filming
We may use media (photographs, recordings, videos and film) for purposes of publication, display or broadcast (print, web, social media, digital display and all other forms of media and promotion). Data which identifies an individual, even without a name associated with it, may be personal data if you are processing it to learn or record something about that individual, or where the processing has an impact on that individual. If the media “relates to” an individual, we will ensure they sign a disclaimer/release form (or in some cases, verbally consent) to enable us to, for example, publish the media.
Right to Withdraw Consent
If you are included in any piece of media and would like to be removed, please contact maureen@ihag.co.uk and inform us of the media you wish to be removed.
This Privacy Notice is subject to ihAg’s overarching Privacy Notice which can be found above.
ihAg is committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve.
This Privacy Notice covers how we collect, use, store and disclose the data that you supply to us and your rights about data that we hold about you.
It applies to current and former employees, workers, volunteers, interns and contractors and does not form part of any contract of employment or other contract to provide services.
For more information please contact the Data Protection Officer, (the CEO of ihAg), who will provide you with our Data Protection Policy.
The Information we collect from you
Personal individual information means any information about an individual from which that person can be identified.
It does not include data where the identity has been removed (anonymous data). We will collect, store, and use the following categories of personal information about you:
We may also collect, store and use special categories of more sensitive personal data which require a higher level of protection:
Purpose | Type of data | Lawful basis |
---|---|---|
Making a decision about your recruitment or appointment. | PC, DVLA, RI, CC | *** |
Determining the terms on which you work for us. | SI, SD, LOE, RI, ER | *** * |
Checking you are legally entitled to work in the UK.. | PC, DOB, NI, RI | ** |
Paying you and, if you are an employee, deducting tax and National Insurance contributions. | PC, DOB, NI, BD, SI, AN | *** |
Liaising with your pension provider. | PC, DOB, NI, SI, SD | * |
Administering the contract we have entered into with you. | PC, NOK, NI, BD, SI, SD, LOE, PI, DG, HR, AN | *** * |
Business management and planning, including accounting and auditing. | PC, NI, BD, SI, SD, LOE, ER, CH, PI, DG, CCTV, ICS, HR, TU | *** |
Conducting performance reviews, managing performance and determining performance requirements. | PC, SI, SD, LOE, ER, PI, DG, CCTV, ICS, HR, AN | *** * |
Making decisions about salary reviews and compensation. | PC, DOB, BD, SI, SD, LOE, RI, ER, CH, PI, DG | *** * |
Assessing qualifications for a particular job or task, including decisions about promotions. | PC, RI, ER, PI, DG | *** * |
Gathering evidence for possible grievance or disciplinary hearings. | PC, DOB, S, MSD, PI, DG, CCTV, ICS, HR, AN, DI | *** * |
Making decisions about your continued employment or engagement. | PC, PI, DG, CCTV, ICS, HR, AN | *** * |
Making arrangements for the termination of our working relationship. | PC, DOB, NI, BD, SI, SD, ER, PI, DG, HR, AN | *** * |
Education, training and development requirements. | PC, RI, ER, PI, DG | *** |
Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work | PC, DOB, S, MSD, BD, SI, SD, LOE, RI, ER, CH, PI, DG, CCTV, ICS, P, HR, AN, DI, TU, GBD | *** * |
Ascertaining your fitness to work and managing sickness absence. | PC, DOB, S, NOK, LOE, PI, DG, CCTV, P, HR, AN | *** * |
Complying with health and safety obligations. | PC, NOK, LOE, CCTV, P, HR, AN | *** |
To prevent fraud. | PC, NI, BD, DVLA, RI, ER, CCTV, ICS, P, CC | *** ** |
To monitor your use of our information and communication systems to ensure compliance with our IT policies. | PC, CCTV, ICS | *** |
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. | PC, CCTV, ICS | *** |
To conduct data analytics studies to review and better understand employee retention and attrition rates. | PC, DOB, S, MSD, HR, DI | *** |
Equal opportunities monitoring. | PC, DOB, S, MSD, HR, DI | *** ** |
How the Information is Collected
We collect personal information through the application and recruitment process, either directly from candidates or sometimes from an employment agency. We may sometimes collect additional information from third parties including former employers or other background check agencies. We may collect
When we will use your Personal Information
We need all the categories of information identified above primarily to allow us to perform our contract with you[*] and to enable us to comply with legal obligations[**]. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties[***] (provided your interests and fundamental rights do not override those interests). We will process your personal information as follows, the asterisks show the purpose for processing:
Please refer to our Data Protection Policy which provides more detail on how we collect your data, the basis on which we hold it and how we store, use and destroy it.
Failure to Provide Information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing employee benefits), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
Sensitive Personal Information
Special categories of particularly sensitive personal information require higher levels of protection. We may process special categories of personal information in the following circumstances:
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.
Our Obligations as an Employer
We will use your particularly sensitive personal information in the following ways:
We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
Information about Criminal Convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.
We envisage that we will hold information about criminal convictions and access your DBS portal.
Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.
We are allowed to use your personal information in this way.
Your Duty to inform us of Changes
It is important that the personal information we hold about you is accurate and current, so please let us know if your information changes.
Disclosure/Data Sharing
We may have to share your data with third parties, including third-party service providers (including contractors and designated agents); other entities in the group; in the context of a sale of the business; or with a regulator or to otherwise comply with the law; our insurers and/or professional advisers to manage risks legal disputes.
We do this where required by law; where it is necessary to administer the working relationship with you; or where we have another legitimate interest in doing so.
We contractually require third party contractors to respect the security of your data and to treat it in accordance with the law.
Currently, the only third-party service providers who process personal information about you are our HR consultancy firm (HR Department), AC Contracts (Allen Clarke ) who delivers our IT support, and HMRC (the Tax office) which operates the RTI system (real Time Information) to adjust monitor your earnings and Tax.
Additionally, each year our Auditors carry out a full audit of our finances (this required by Law) and they have access to the payroll system to check that we have managed it correctly.
Transfers of Data Outside of the EU
We may transfer the personal information we collect about you outside the EU in order to perform our contract with you. We use Microsoft Office365 services which cover our email and other cloud-based services, these services are based on a UK geo location but some of those services may be hosted across other locations. Further information is available from the Data Protection Officer, the CEO of ihAg.
Data Retention
We must store most of your HR data for a period of at least 6 years following the termination of your employment; some personal financial data will be destroyed after 2 years; Health and Safety information must be held for a minimum of 40 years.
Your Rights
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Please contact the person responsible for Data Protection in our Company.
Complaints & Questions
If you have any questions about this privacy notice or how we handle your personal information, please contact the person responsible for Data Protection in our Company. If we have breached our duty of care, we will take appropriate action.
If you are not satisfied by our response you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (Email: casework@ico.org.uk)
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.