Privacy Notice and Cookies
At Home-Start Bradford District we are committed to protecting and respecting your privacy.
This Privacy Notice explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights and choices in relation to your information.
Any questions regarding this notice and our privacy practices should be sent to us using the contact details below.
- The personal data we collect from you, how we collect and how we use it
- Employees, volunteers, trustees
- Website users (including information about cookies)
- Your Rights
- Keeping your information safe and up to date
- Vulnerable circumstances
- Changes and review
- How to complain
- How to contact us
- Appendix 1: Job applicants
Home-Start Bradford District is committed to protecting your personal information and to being transparent about what information we hold. We understand our obligations to you to help you understand how and why we process your personal data. We will only do so in accordance with all applicable UK data protection legislation, including the General Data Protection Regulation.
In this notice ‘HSBD, ‘we’, ‘us’ or ‘our’ means:
Home-Start Bradford District, a registered charity (#1090435) and charitable company (#4297771) limited by guarantee.
Registered office: The Thornbury Centre, Leeds Old Road, Bradford, BD3 8JX.
2. The personal data we collect from you, how we collect and how we use it
Employees, volunteers and trustees will be given detailed information as part of the application, induction and training process.
Families will have to sign our family privacy notice on referral or at initial visit.
Job applicants should see appendix 1.
Types of data we process
- Usage Data: We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
- Account Data: We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- Profile Data: We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and social media IDs. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.
- Service Data: We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include name, address, email address, details of donations made or items ordered. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- Publication Data: We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
- Enquiry Data: We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
- Transaction Data: We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
- Notification Data: We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
- Correspondence Data: We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- Other: We may process any of your personal data identified in the other provisions of this notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, for example, anti-money-laundering purposes or a court order. Please do not supply any other person's personal data to us, unless we prompt you to do so.
Who has access to your information?
Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the follow will apply:
- Your data will be made available to our website provider
- The data that may be available to them include any of the data we collect as described above.
- Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
- They will store your data for a maximum of 7 years.
- This processing does not affect your rights
In addition to the specific disclosures of personal data, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
How long is your information kept for?
This section sets out our data retention policy, which is designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
All personal data will be retained for a maximum of seven years following the date it was submitted, at the end of which period it will be deleted from our systems, unless requested by users.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Third party websites
Our website includes hyperlinks to, and details of, third party websites. This Privacy Notice only governs our websites and we are not responsible for the Privacy Policies that govern third party websites even where we have provided links to them. If you use any link on our website, we recommend that you read the privacy notice of that website before sharing any personal or financial data.
We operate a number of social media pages including Facebook and Twitter. Although this notice covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the Privacy Notice of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.
Personal data of children
Our website and services are targeted at persons over the age of 16. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
- Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|PHPSESSID||Session cookie. Allow you to use our site in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket.
Expires after you close your browser.
|eu_cookie_law_ok||Session cookie. Allow you to use our site in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket.
Expires after you close your browser.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari);
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use some of the features on our website.
3. Your Rights
Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that apply to you when we are processing your personal information:
- Right of access: You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply. If you want to access your information, please contact the address provided below, telephone or e-mail
- Right to have your inaccurate personal information corrected: You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us, so if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email, telephone or post (see below).
- Right to restrict use: You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we are not lawfully allowed to use it.
- Right of erasure: You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to by law. In many cases, we will anonymise that information, rather than delete it.
- Right for your personal information to be portable: If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, for example, when you shop from our website, you may ask us to provide it to you or another service provider in a machine-readable format.
- Right to object: You have the right to object to processing where we are using your personal information based on legitimate interests, (or for statistical/research purposes). In these circumstances we will consider your request against our legitimate reasons for continuing to process your information.
You have an absolute right to object to direct marketing. If you wish to opt-out of receiving marketing materials from us at any time, please contact the address below.
If you want to exercise any of the above rights, please contact us. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office.
4. Keeping your information safe and up to date
When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it, such as firewalls, anti-virus protection and encryption. We have developed a set of security policies that include device security, authentication requirements, acceptable usage of resources, data storage requirements. We undertake regular reviews of who has access to information that we hold to ensure that your info is only accessible by appropriately trained staff, volunteers and contractors.
We take reasonable steps to ensure your information is accurate and up to date. Where possible we use publicly-available sources to identify deceased records or whether you have changed address. We really appreciate it if you let us know when your contact details change.
5. Vulnerable circumstances
We are committed to protecting vulnerable supporters, customers and volunteers, and appreciate that additional care may be needed when we use their personal information. In recognition of this, we observe good practice guidelines in our interactions with vulnerable people.
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian's permission beforehand whenever you provide us with personal information.
6. Changes and review
Any changes we may make to this notice in the future will be posted on this website so please check this page occasionally to ensure that you are happy with any changes. If we make any significant changes we will make this clear on this website.
We keep this Notice under regular review. It was last updated in October 2019.
7. How to complain
Please report any complaint to the details set out in ‘How to contact us’ below. We hope we can resolve any query or concern you raise about our use of your information. You also have the right to lodge a complaint with the ICO who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
8 How to contact us
Please contact us if you have any questions about this Privacy Notice or the information we hold about you at firstname.lastname@example.org, The Thornbury Centre, Leeds Old Road, Bradford, BD3 8JX or 01274 666711
Our Data Protection Officer/Lead is Ursula Blagg (Trustee)
Appendix 1: Job applicants
How do we collect information from you?
As part of our application and recruitment process, we collect, process and store personal information about you. We process this information for a range of purposes relating to the recruitment process and this may include your application, assessment, pre-employment checks and your worker permissions.
What type of information is collected from you?
The following are some examples of the type of information we may process:
- Name, work and home contact details
- Date and place of birth
- Education and work history
- * Individual demographic information in compliance with legal requirements (such as marital status, national identifier, passport/visa information, nationality, citizenship, military service, disability, work permit, gender)
- * Health issues requiring adaptations to working environment
- Job title, grade and job history
- Employment contract related information (including compensation, location, hours of work, etc)
- Reporting and managerial relationships
- * Leaves of absence (such as maternity leave, sickness absence)
- Disciplinary/grievance records
- Time and attendance details
- Bank account details for salary payment purposes
- Expenses such as travel and expenses
- Skills and qualifications
- Training history and plans
- Results of original and ongoing employee screening (where relevant)
- * Health and safety incidents, accidents at work and associated records
- Face to face interview notes
- Audio recordings of interviews
- Video recordings of interviews
- Interview test/exercise results
* During the process we also capture some personal data that is considered under data protection law to be ‘special category data’ about you, eg. disability information. We do this in order to make reasonable adjustments to enable all candidates to apply for jobs with us, to be able to take online/telephone assessments or interviews, to attend interview/assessment centres and to ensure that we comply with regulatory obligations with regard to hiring.
How and why is your information used?
In order to manage your application, we need to process certain personal information about you. The purposes for this are set out below. We only process your information as necessary for the purposes of progressing your application or as required by law or regulatory requirements, so not all of the purposes set out below will apply to you all of the time.
- Application: Application form or CV, name, address, employment history, academic and professional qualifications, age, diversity, (i.e. gender, ethnicity, disability, sexual orientation), nationality, previous disciplinary matters.
- Assessment: CV, interview (face to face, telephone or video), exercise or test.
- Pre-employment: Right to work in the UK, qualifications, references
How long is your information kept for?
For unsuccessful candidates, personal information will be retained for 6 months following the recruitment process. For successful candidates all personal information collected as part of the recruitment process will be transferred to an employee personnel file and will be retained for six years following termination of employment.
Who has access to your information?
The recruitment process will involve:
- Assessing and progressing your application
- Assessing your suitability (skills, strengths and behaviours) for the role
- Activities needed to complete on-boarding and screening processes should your application be successful
To enable these processes your personal information may be shared internally. The information shared is limited to what is required by each individual to perform their role in the recruitment process. Your personal information may be shared with the following:
- The Senior Management Team (including line manager)
- Other members of shortlisting and interview panels not included above
Our HR and recruitment systems are protected to ensure that unauthorised or unlawful processing of personal information, accidental loss or destruction of personal information does not occur. This is done in line with the Data Protection & Confidentiality policies.
As part of the recruitment and selection process HSBD will carry out pre-employment checks. These checks are only performed on candidates who have been selected for a role. Your consent will be requested before pre-employment checks are carried out.
Our entitlement to process your personal information is governed under data protection law by a number of processing conditions. This means we may rely on more than one of these conditions in order to process elements of your personal information throughout the recruitment process.
We will process your personal information where it is required by law or regulation or it is in the legitimate interest of the applicant or our organisation.
During the course of your application it may also be necessary for us to process your sensitive personal information as per the detail above.