The Chichester Information Shop are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Who are we?
The Chichester Information Shop is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are; address: 34a Little London, Chichester, West Sussex PO19 1PL, phone: 01243 839093, email: firstname.lastname@example.org.
For all data matters contact our data representative, Fern Sadler, at email@example.com.
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
Name: (Staff and Service Users) So that we may address you by the correct name and identify from others.
Mobile Phone Number: (Staff): So that you may be contacted regarding work related matters. For example, being a part of the group conversations on a messaging app, keeping in touch with colleagues who may ask that you cover them so as to avoid lone working. (Service Users): To be contacted in regards to counselling or emotional support sessions.
Work Phone Number: (Staff): As this is property of The Chichester Information Shop, we are required to keep track of which member of staff (primarily counsellors only) has which mobile phone.
Email: (Staff): So that you may be contacted regarding work related matters. For example, work events, staff training, travel expenses. (Service Users): To be contacted in regards to counselling or emotional support sessions.
Preferred Gender Pronouns: (Staff and Service Users): So that all members of The Chichester Information Shop team and any service users can be addressed by the correct pronouns, to be considerate of others.
Address: (Staff): So that those who claim travel expenses can have their mileage calculations checked by means of comparing distance from their home address to The Chichester Information Shop. (Service Users): For statistical data collection or safeguarding.
Medical Information: (Staff and Service Users): So that if there were to be a medical emergency occur at The Chichester Information Shop, the correct procedures could take place to ensure the safety of all present.
Next of Kin Details: (Staff and Service Users): So that if there were to be a medical emergency occur at The Chichester Information Shop, the correct person of your choice could be made aware of the situation.
Bank Details: (Staff):So that if you are owed money by the The Chichester Information Shop for worked hours (Supervisors) or travel expenses.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data: name, home address, private email address, bank details.
- Special categories of data: health data.
We have obtained your personal data from the ‘Staff Contact Information’ document. Previously this would have been provided to us by you in a varying number of ways. For example, when initially applying for your role here, or when providing bank details for travel expenses payments.
5. What is our legal basis for processing your personal data?
- Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
|☐ Consent of the data subject;||Consent was approved if the subject signed the ‘Staff Contact Details’ form. Or the service user has signed the ‘Data Consent’ form.|
|☐ Processing necessary for compliance with a legal obligation||Personal details given for administrative purposes e.g. written consent in staff contract, volunteer agreement, service user forms.|
- Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
|☐ Explicit consent of the data subject||Consent was approved if the subject signed the ‘Staff Contact Details’ form. Or the service user has signed the ‘Data Consent’ form.|
|☐ Processing necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement||To provide bank details for travel expenses purposes/ staff payroll.|
|☐ Processing necessary for reasons of preventative or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional||If there were to be a medical emergency occur at The Chichester Information Shop, the correct procedures could take place to ensure the safety of all present.|
More information on lawful processing can be found on the ICO website.
- Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with members of The Chichester Information Shop staff team, where necessary.
- How long do we keep your personal data?
Timescales for disposal of data held
The Data Controller holds overall responsibility for maintaining these timescales and this is delegated as described below:
(L = Legal / D = Discretionary)
|Data||Timescale||Responsibility||L or D|
|Staff and volunteer application forms||1 year after leaving
(Summary record must be kept as below)
|Application forms of unsuccessful applicants||6 months||Manager||D|
|Summary record of service||10 years after employment ends||Manager||L|
|Payroll and tax information||6 years||Manager||L|
|Sickness records||3 years||Manager||L|
|Annual leave records||3 years||Manager||L|
|Individual staff meeting notes||1 year||Manager||D|
|Unpaid or special leave||3 years||Manager||L|
|Annual appraisal records||5 years||Manager||L|
|Records relating to promotion, transfer, training, disciplinary matters||1 year after end of employment||Manager||L|
|Incident forms||3 years||Manager|
|References given||5 years after end of employment||Manager||L|
|Records relating to accidents or injuries||12 years||Manager||L|
|Client referral forms in and out of the organisation||3 months after end of service||Manager||D|
|Information regarding clients to and from other organisations||3 months after end of service||Manager||D|
|Notes from client meetings||3 months after end of service||Manager||D|
|Electronic client data including emails||3 months after end of service||Manager||D|
|Counselling records||7 years||Manager||D|
|Agreements with clients||3 months after end of service||Manager||D|
|Registers of attendance||3 months but retain numbers/anonymised data logged for monitoring purposes if required e.g. 3 new attendees, 40 in total attended||Manager||D|
At times it may be reasonable to keep client information for longer than the timescale stipulated above for example if a client is likely to return to the service and the information would be conducive to providing a service in the clients best interests.
This is permissible if it adheres to the principle of shall not being kept for longer than is necessary for the purpose or purposes it was given and consented for.
- Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences:
Members of The Chichester Information Shop staff team will not be able to contact you regarding a number of work related matters.
- Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
- Transfer of Data Abroad
We do not transfer personal data outside of the EEA.
- Automated Decision Making
We do not use any form of automated decision making in our business.
- Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
- How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Fern Sadler, on firstname.lastname@example.org.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.