How and why we use your personal information?
Foothold Cymru is committed to protecting your privacy when you work with us or use one of our services. This privacy notice explains how and why we use and protect your personal information and what are your rights as individuals.
What is Personal Information?
Personal information: The definition of personal information includes anything that identifies and relates to a living person, for example, name, date of birth, address.
'Special category' information: Some types of information about you are more sensitive and need further protection. Under the General Data Protection Regulation these are called special category information and include:
- Political or philosophical beliefs
- Sex-life and sexuality
- Trade union membership
- Genetic or biometric data (fingerprints or facial recognition technology)
- Criminal records
Why do we need your information?
Dependent on the project or activity, we need to use information about you so that we can:
- Offer you services;
- Market our services;
- Manage services
- Meet our contractual obligations;
- Meet legal obligations;
- Comply with grant requirements.
The General Data Protection Regulation lays out 6 legal conditions that allow us to collect and use your personal information. These conditions are:
a) Processing based on individual's consent;
b) Processing is necessary for a contract;
c) Processing is necessary to comply with a legal obligation;
d) Processing is necessary for the individual's vital interests;
e) Processing is necessary as it undertakes a task in the public's interest.
f) Processing is necessary for legitimate interests
Most of the time, CBSA processes your personal information based on either condition a, b or c. We cannot process your information if there is no legal basis for doing so. We will always tell you the legal basis as part of a privacy notice on our forms at the point of collection.
From time to time Foothold Cymru will share your information with partnering bodies, depending on the various projects. We will always tell you at the point of collection if we will be doing so and with whom. If we rely on your consent for processing, you have every right to object for us to share externally.
Sometimes, we have a legal duty to share information with others e.g. the courts or the Department of work and pensions.
The law gives you as individuals a number of rights around how your personal information is used.
The right to know
You have the right to know why and how we process your personal information at the point of collection. Foothold Cymru will always tell you this as part of our privacy notices on each of our forms.
The right to access
You have the right to ask to access all the information about you that we keep.
But we cannot always give you the information. We will not share with you if the records include:
- Confidential information about other people;
- Information that a professional believes would cause serious harm to the physical / mental welfare of yourself or someone else;
- Information that would prevent us from preventing the solving of a crime / impact an ongoing investigation.
We have up to one month to respond to a subject access request.
The right to correct information
If you believe that the information we keep about you is incorrect, you have the right to contact us and ask us to correct it.
It may be possible that we will be unable to change the information on every occasion, but we will correct anything that is factually incorrect.
The right for deletion (right to be forgotten)
In some circumstances you have the right to ask us to delete your information, for example:
- Where your personal information is no longer needed;
- Where you have withdrawn your consent;
- Where your information has been used illegally;
- Where there is a legal requirement to delete the information;
- Where you have objected to the processing of your information;
- Where data has been collected as part of an on-line service for children.
However, we cannot always delete your information, for example:
- If It is used for freedom of expression;
- If the law states that we must keep it;
- It is used for public health purposes in the public’s interest;
- It is used for archival purposes – historical research or statistical purposes;
- It is necessary for organisational legal claims.
The right to restrict the use of your information
You have the right to ask that we restrict the use of information where:
- You have informed us that information about you is incorrect and we are in the process of checking it;
- We do not have a legal right to use the information, but you wish us to restrict the use rather than delete it completely;
- We do not have any reason to retain it but you need it to establish, execute or defend a legal claim;
- You have objected to processing and we need time to determine whether our basis outweigh the rights of the individual.
The right to data portability
You have the right to ask for your personal information in a common format, and you can ask for it to be shared or transferred to another service provider.
This can only happen if:
- Consent or contractual obligation is the legal basis for processing
- The processing is done automatically by a computer
The right to object
In some circumstances you have the right to object to the processing of your personal information:
- If the purpose of processing is public or direct marketing;
- If we are processing your information on the basis of legal interests or an official public task;
- If processing is for research or statistics purposes.
We cannot comply with the request if:
- There are strong, legal reasons for processing;
- There is a need to establish, execute or defend legal claims.
Rights in relation to automated decisions and profiling
You have the right to ask for an explanation about any decisions made by a computer, without any intervention by an individual.
You can query any decisions made by a computer about you, unless this needs to be done for a contract, there is a legal requirement, or you have given your permission for this to happen.
You also have the right to object to any 'profiling.'
Foothold Cymru will always inform you if we use your personal information to profile you.
Foothold Cymru will always take appropriate measures to keep your personal information secure. We have work processes and systems in place to manage access, transfer and disposal of information securely. All staff are trained how to keep information safe and how to comply with the General Data Protection Regulation.
How long do we keep your information?
We have a Retention schedule in place stating how long we should keep our various records. These retention periods will vary from project to project and are often based on grant or funding requirements. Our privacy notices on our various forms for collecting information will always state how long we will be keeping your personal information.
For more information, or to make a complaint
contact email@example.com Or for independent advice on data protection matters contact the Information Commissioner’s Office https://ico.org.uk/make-a-complaint/your-personal-information-concerns/