Introduction:
This privacy policy provides details of how we (Talking SENse!) collect and process personal data through our website www.talking-sense.org, email addresses and in person.
Talking SENse! is referred throughout this policy as “the charity”, “we”, “us”, and “our”.
Elliott Garbett, Secretary to the Board of Trustees is the nominated data controller for the charity.
Our contact details:
Postal address: Talking SENse! 75 Westbrook Avenue, Aldridge, Walsall, WS9 0BZ
Email: enquiries@talking-sense.org
Telephone: 07538 100 568
Complaints concerning personal data:
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO) via www.ico.org.uk
We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at enquiries@talking-sense.org
Information that we collect:
We collect personal data capable of identifying an individual such as:
• Identity Data which may include your and your child’s first name, maiden name, last name, username, marital status, title, date of birth and gender.
• Contact Data which may include your home and work address, email address, telephone numbers, billing address, and the name and address of your child’s school/s.
• Financial Data which may include your bank account and payment card details.
• Transaction Data which may include details about payments between us and other details of purchases made by you.
• Technical Data which may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access our website.
• Profile Data which may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data which may include information about how you use our website, products and services.
• Marketing and Communications Data which may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data, but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
How we collect personal data:
We collect data about you through a variety of different methods including:
• Direct interactions: You may provide data by filling in forms on our website (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
request our services or products;
subscribe to our service or publications;
request resources, information or marketing be sent to you;
enter a competition, prize draw, promotion or survey; or
give us feedback.
• Indirect interactions: We may receive personal data about you and your child from third parties such as friends, family, acquaintances, third sector organisations and groups, schools, and statutory agencies.
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.
How we store your data:
Data is stored on our own secure device in accordance with local regulations.
How we use your personal data:
We will only use your personal data when legally permitted. The most common uses of your personal data are:
• to register you as a user of our services,
• where we need to perform the contract between us, manage payments, fees and charges, and collect/recover money owed to us,
• to manage our relationship with you which may include notifying you about changes to this privacy policy, asking you to leave our office or take a survey,
• to enable you take part in a prize draw, competition or complete a survey and research regarding the services you receive from us and other agencies/services,
• to communicate with you regarding events and information,
• to administer and protect the charity including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data,
• to study how users, use our services/products, to develop them, to grow the charity and to inform our strategy,
• to use data analytics to improve our website, services/products, marketing, user relationships and experiences,
• to make suggestions and recommendations to you about services/products that may be of interest to you,
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests,
• where we need to comply with a legal or regulatory obligation.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at enquiries@talking-sense.org if you need details about the specific legal ground we are relying on to process your personal data.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We will not share your data with third parties for marketing purposes.
Disclosures of your personal data:
We may have to share your personal data with the parties set out below for the purposes set out under the heading “how we use your personal data”:
• professional advisers including lawyers, advocates/advisers, mediators, teachers, expert witnesses, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services,
• Her Majesty’s Courts & Tribunal Service, Her Majesty’s Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances,
• third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your data outside the European Economic Area.
Data security:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business and a need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long do we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our users (including contact, identity, financial and transaction data) for seven years after they cease being users for tax purposes and case notes until the child is 21 years of age.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your personal data and your rights:
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
• request access to your personal data,
• request correction of your personal data,
• request erasure of your personal data,
• object to processing of your personal data,
• request restriction of processing your personal data,
• request transfer of your personal data,
• right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us enquiries@talking-sense.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in
relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Third party links and cookies:
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
Changes to this privacy policy:
This Privacy Policy has been agreed by the Trustees of Talking SENse!
The policy will be reviewed annually to ensure it continues to meet the requirements of the GDPR and the needs of Talking SENse!
We reserve the right to amend or modify this Privacy Policy at any time; changes will be published on our website. The date of the most recent revision will appear on this policy. If we make significant changes to this policy, we may also notify you by others means such as via email.
Date policy completed May 2018
Date policy should be formally reviewed. April 2019