The Almshouse Association – Members’ Privacy Notice
1. Important information and who we are The Almshouse Association is committed to protecting your personal data and ensuring that it is only ever used in accordance with your rights and expectations. The Association decides what personal data we hold, how we hold it and how we use it. This makes us responsible for that data as a “data controller” and requires us to provide you with this privacy notice, outlining why we need your personal data, what we do with it and your rights in relation to it.
When we refer to:
• “we”, “us” or “our”, we mean The Almshouse Association;
• “personal data”, we mean any information relating to an identified or identifiable living individual;
• “processing”, we mean collecting, recording, organising, storing, sharing, destroying or anonymising personal data.
How to contact us and how to complain
We have appointed a data privacy lead who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact The Almshouse Association at admin@almshouses.org or write to The Almshouse Association, Leonard Hackett House, 17-21 Victoria Street, Windsor, Berkshire SL4 1HE or call 01344 452922.
You 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 9/05/2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The personal data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data including your name, data of birth, username or similar identifier, marital status, title and gender;
• Contact Data including your address, email address and telephone numbers;
• Financial Data including your bank account;
• Transaction Data including details about payments to and from you and other details of services and/or products you have purchased from us;
• Technical Data including your internet protocol (IP) address and your login data;
• Usage Data including information about how you use our website and services;
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences;
• Feedback data including notes of any conversations with you, and details of any comments or complaints you make.
We collect this data from you and may sometimes collect data from other sources such as the Charity Commission.
3. Why we collect personal data and the legal basis for handling your data
We collect, hold and use personal data about you because, as your charity is a member of the Almshouse Association, we provide clerks and trustees of member charities and other persons engaged by member charities with guidance and support as part of the membership offer your charity has subscribed to. This may include using your data in the following ways:
• To provide advice to you by telephone, email and post;
• To provide you with access to our publications, model documents, information and services on the members’ pages of our website;
• To provide you with any products you wish to obtain, such as interest free loans available to member charities;
• To allow you to confer with other member charities in the members’ forum on our website
• To maintain relevant contact about your membership including keeping you updated about information which forms part of your membership and about our products and services;
• To send you subscription renewals;
• To communicate with you for any other reason related to your membership;
• To carry out our obligations under any other contract entered into between you and us including any training event, seminars or conferences booked by you;
• To enable us to respond to any questions you ask;
• To send you marketing communications and our quarterly magazine;
• To allow members of the public to contact you to register an interest in obtaining almshouse accommodation.
We only use your personal data when we have a proper reason for doing so.
The legal bases we rely on most commonly to process your data include:
• contract: where our use of your personal data is necessary for the membership or other contract we have with you, or because you have asked us to take specific steps before entering into a contract;
• legal obligation: where our use of your personal data is necessary for us to comply with the law;
• legitimate interests: where our use of your personal data is necessary to pursue our legitimate interests in a way which might reasonably be expected (that is, to pursue our aims of promoting the establishment, continuation and efficiency and effectiveness of almshouses, and to promote the provision, improvement, upkeep and maintenance of almshouses) and in a way which does not materially impact your rights, freedoms or interests.
In a small number of cases, we may also rely on the following legal base:
• consent: where you have given us clear consent for us to process your personal data for a specific purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If you have given your consent for us to process your personal data, you have the right to change your mind at any time and withdraw your consent.
4. Who we share your personal data with
To manage our functions, we work with carefully selected third-party service providers whom we trust to carry out work on our behalf. We do not allow such service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We routinely share your personal data (where the law allows us in the circumstances set out above) with:
• support companies we use to help us run our operations, for example, IT, cloud storage and backup service providers, and our bank and website operator;
• service providers in connection with the running of our training events, seminars and conferences.
• the distributor of our quarterly magazine, Push Mailing;
• other member charities, in order to share best practice and experience within the almshouse movement.
We will also share your personal data with third parties:
• if we are legally required to do so, for example, by a law enforcement agency or court;
• to enforce or apply any contract we have with you;
• if it is necessary to protect our rights, property or safety or to protect the rights, property or safety of others;
• if we sell or buy any other organisation or part of it (including the Association, if we are forming a new entity to replace and continue our operations or merging with another organisation), in which case we may disclose your personal data to the prospective seller or buyer so that they may continue using it in the same way.
5. Marketing
We strive to provide you with options around marketing.
Marketing from us
You will receive marketing communications from us that promote our aims and objectives if you have requested information from us and you have not opted out of receiving that marketing.
You will receive our quarterly magazine to enable us to pursue our legitimate interest of improving practice within the almshouses sector.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by contacting us at any time at admin@almshouses.org, or writing to The Almshouse Association, Leonard Hackett House, 17-21 Victoria Street, Windsor, Berkshire SL4 1HE or calling on 01344 452922. We will update our records to reflect your wishes.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We take the security of your personal data seriously. 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 need to know. 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.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Different retention periods apply for different types of personal data. 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, regulatory, tax, accounting or other requirements.
At the end of the relevant retention period, your personal data will either be deleted completely, put beyond use or anonymised. Some data about clerks and trustees of member charities, and other persons engaged by member charities, will be kept in perpetuity as a record of our history and heritage.
Details of retention periods for different types of personal data are available in our retention policy which you can request from us by contacting us.
9. Your rights
You have the following rights, which you can exercise free of charge and on request:
• to access the personal data we hold about you;
• to require us to update or correct the personal data we hold about you;
• to require the erasure of your personal data in certain circumstances;
• to receive the personal data we hold about you in a structured, commonly used and machinereadable format, and to transmit it to a third party in certain situations;
• to object at any time to the processing of your personal data for direct marketing purposes;
• to request the restriction of the processing of your personal data;
• to challenge any automated decisions we make about you;
• to withdraw your consent at any time. If you wish to exercise any of these rights, please contact The Almshouse Association at admin@almshouses.org or write to The Almshouse Association, Leonard Hackett House, 17-21 Victoria Street, Windsor, Berkshire SL4 1HE or call 01344 452922, and let us have enough information to identify you.
If you request the personal data that we hold about you, we will respond within one month (unless the complexity and number of requests mean that we need more time).
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 could refuse to comply with your request in these circumstances.
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