INTRODUCTION

Worthing 4 Refugees (W4R) is a charity with a vision of Worthing as a place of welcome, safety, integration and justice for refugees. Initiated by church leaders, our ethos is drawn from a Christian tradition which cares for all people, especially those in need of shelter, food, clothing and support as a result of being displaced or circumstances beyond their control. We work with West Sussex County Council, Adur and Worthing Borough Council, The Good Faith Partnership and the Home Office to resettle refugees, in the first instance Syrian refugees, and to provide a safe place, helping them to integrate with their local community.

This policy covers our use of personal data, defined as any information about a living individual which allows them to be identified from that data. Our processing of personal data is governed by the Data Protection Bill/Act 2017-2019 and the General Data Protection Regulation 2016/679 (the ‘GDPR’) and other legislation relating to personal data and rights such as the Human Rights Act 1998.

The policy applies to anyone who engages with the Charity in person, via our website, email, phone or by mail. This includes supporters, subscribers, those we support, those who participate in our programmes or events, donors, volunteers, freelancers, authors, illustrators, employees, the planning group and trustees.

DEFINITIONS

Charity	means Worthing 4 Refugees (W4R), a registered charity
GDPR	means the General Data Protection Regulation
Responsible Person	means Gay Jacklin, who is responsible for data protection within the Charity
Register of Systems	means a register of all systems or contexts in which personal data is processed by the Charity

DATA PROTECTION POLICY IN BRIEF

W4R collects personal information to carry out its legitimate purposes as a charity. These purposes include, but are not limited to, provision of services or goods, to provide information, to fundraise for our work, to resource our activities and fulfil our charitable objectives and for administration.  Personal information may also be used for research, analysis and the prevention or detection of crime. A full Register of Systems is kept by the Responsible Person.We only collect the information that we need for legitimate purposes and we make sure the information we hold is accurate and kept no longer than necessary.We keep personal information secure and with restricted access. We have systems in place for appropriate deletion or archiving of records and if there is a data breach.We never sell your data and we will never share it with another company or charity for their own purposes.We only share data where we are required by law or with carefully selected service providers who carry out work for us. We recognise the importance of ensuring that all our service providers treat your data as carefully as we would, use it only as instructed, and allow us to check that they do this.Our website uses cookies. These cookies collect anonymous information on how people use our website.Appendix 1 to this policy is our privacy notice for use on website and other areas.

DATA PROTECTION PRINCIPLES

The Charity is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

GENERAL PROVISIONS

1. This policy applies to all personal data processed by the Charity.
2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.

LAWFUL, FAIR AND TRANSPARENT PROCESSING

1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.

LAWFUL PURPOSES

1. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
2. The Charity shall note the appropriate lawful basis in the Register of Systems.
3. The Charity currently relies on legitimate purposes as a lawful basis for processing data and provides clear information on how the data is used through a Privacy Notice.
4. Where communications are sent to individuals based on legitimate purpose, the option for the individual to opt out should be clearly available and systems should be in place to ensure such opt out is reflected accurately in the Charity’s systems.  

DATA MINIMISATION

1. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

ACCURACY

1. The Charity shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

ARCHIVING/REMOVAL

1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.

SECURITY

1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.  
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

BREACH

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

CONTACT DETAILS AND FURTHER INFORMATION

Gay Jacklin

Worthing 4 Refugees

c/o Maybridge Community Church

77 The Strand

Worthing

BN12 6DR

Tel: 01903 700522/07906 372947

Email: gay.jacklin@maybridge.org.uk

Appendix 1: Privacy Notice

The wording in this Notice should be used whenever personal identifiable information is processed, e.g. completing forms via the website, volunteer application forms and for the people that use our services. The Information Commissioners Office (ICO) advice on: what should be included, where information should be delivered to individuals, when privacy information should be actively communicated and how to write a privacy notice. The ICO also provides a checklist and examples:

1. Contents

1 Just in time notices 7

1.1 Privacy notice when completing forms 7

1.2 Privacy notice on application forms 7

2 Privacy notice in full 7



JUST IN TIME NOTICES

The ICO gives advice on using just in time notices as a type of layered approach to provide information at certain points of data collection, for example when filling out a form. Just-in-time notices work by appearing on the individual’s screen at the point where they input personal data, providing a brief message explaining how the information they are about to provide will be used.

W4R uses two just in time notices. The first is when people are completing a form online or in person to receive further information from us, including marketing materials. The second is when volunteers and people who work for us complete an application form. W4R may use a third for refugees that use our services.

PRIVACY NOTICE WHEN COMPLETING FORMS

The following text should appear on the same page of the website where someone is entering personal data.

The individual can either choose to carry on with the basic information or click on the link to find out more information. This can direct them to a more specific page explaining in detail what will be done with the personal information they have provided.

Worthing 4 Refugees collects personal information when you contact us via this page of the website. We will use this information to send you our news and/or prayer updates and other information that we think you might be interested in. If you do not wish to receive this information you can unsubscribe at any time. Worthing 4 Refugees will not share your information for marketing purposes with other organisations. For more information on how we use your information please see our privacy notice [link].  

PRIVACY NOTICE ON APPLICATION FORMS

We collect personal information when you apply to volunteer with us. We use this information to facilitate volunteer activities, keep records for human resources purposes and to undertake DBS vetting where appropriate. By completing this form you are giving consent for us to share your details with other W4R volunteers to facilitate volunteer activities.

For more information on how we use your information please ask for our full privacy notice.

PRIVACY NOTICE IN FULL

Worthing 4 Refugees (W4R) is a registered charity. This privacy notice explains how we use any personal information we collect about you when you use our website or make contact offline.

What information do we collect about you?

We collect information about you when you sign up to our news or prayer updates or make contact with us. We also collect information when you voluntarily complete supporter surveys, provide feedback and participate in events, volunteer with us or use our services. Website usage information is collected using cookies.

We may process sensitive personal data, for example racial or ethnic origin, sex life, mental and physical health, details or injuries, medication/treatment received, religious beliefs, political beliefs, data concerning sexual orientation and criminal records, fines and other similar judicial records. This may apply particularly to the refugees supported by the charity. It may also apply to volunteers and employees, for example via Disclosure and Barring Service checks. Data is only collected if it is legitimate and necessary for our purposes as a charity and if that purpose could not be carried out in any other way.

How will we use the information about you?

We collect information about you to respond to your request(s) or interest and send you other information that we think may be of interest to you. W4R will not share your information for marketing purposes with other organisations.

If you volunteer with us we will collect personal information via an application form. We will use this information to undertake Disclosure and Barring Service vetting where appropriate, depending on the type of role. We will also keep records for human resources purposes, to reimburse you financially (e.g. travel expenses) and to facilitate volunteer activities.

We only share data where we are required by law or with carefully selected service providers who carry out work for us.

We will not keep personal data for any longer than necessary and will dispose of it securely on request.

Access to your information and correction

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address. We want to make sure that your personal information is accurate and up to date and may contact you from time to time to check this. You may ask us to correct or remove information you think is inaccurate.

You can unsubscribe from our news/prayer updates at any time. You can also contact us directly at the details below.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

Changes to our privacy policy

We keep our privacy notice under regular review and we will place any updates on this web page. This privacy notice was last updated on 13 May 2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

By email: gay.jacklin@maybridge.org.uk

By phone: 01903 700522/07906 372947

Or write to us at:

Gay Jacklin

Worthing 4 Refugees

c/o Maybridge Community Church

77 The Strand

Worthing

BN12 6DR