PRIVACY POLICY
This privacy policy sets out how Shekinah uses and protects any personal information that you share with us.
Shekinah is committed to protecting the privacy of personal information which the organisation collects, holds and administers. Personal information is information relating to an identified or identifiable person.
Shekinah fully endorses and adheres to the following six Principles of Data Protection set out in the General Data Protection Regulations (GDPR). Any personal information that you share with us will be:
• processed lawfully, fairly and in a transparent manner.
• collected for specified purposes which we explain to you.
• necessary to achieve our stated purpose. We will not collect personal information that is not essential to our purpose.
• kept as accurate as possible and, where necessary, kept up to date.
• kept for no longer than is necessary.
• 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.
Responsibilities
Shekinah’s Board is responsible for adopting and reviewing this policy.
Shekinah’s CEO is responsible for the implementation of this policy and for advising the Board on changes in data protection law.
Why we collect personal information
We collect personal information for the following purposes:
• Service provision
To provide our support services in Devon and Cornwall.
• Keeping you in touch
To keep people at other organisations, supporters and people interested in our work and services in touch with what we are doing, how they can support us and to make them aware of other services and opportunities.
• Fundraising and donations
To raise money for Shekinah through our website or other fundraising platforms such as Give as You Live and Just Giving.
• As an employer and provider of voluntary opportunities
As an employer or potential employer and in order to offer volunteering opportunities.
How we collect personal information
• Service provision
For our support services we will collect information from you in person, over the phone and by email. When we collect personal data in relation to our services we will explain why we are recording personal data, how it will be used and processed and ask you for consent.
• Keeping you in touch
We collect information in a number of ways in order to keep you in touch with our services and those of other local organisations.
• Directly from you at events and meetings
• Indirectly, if you give via a fundraising platform such as Just Giving, Give As You Live,etc. where you have given them permission to pass your details to us.
• Social media – where you share information with us.
• Via emails from partner organisations.
• Via automated processes on our websites – see website section below.
• Fundraising and donations
We collect information via our website and other fundraising platforms including Just Giving and Give as You Live.
• As an employer and provider of voluntary opportunities
We collect personal information from our staff and volunteers and people who are applying for opportunities at Shekinah via our application processes and our internal human resources systems.
What personal information we collect and how we use it
• Service provision
For the provision of our support services the personal information we collect can include, name, address, email address, phone numbers, health information, details about your personal circumstances and equality monitoring information. You will be asked to give your consent to us holding such personal information when you access our services. If we are recording personal data about a person under the age of 16 we will always request the consent of a parent or guardian. We will use the information you provide only for the purposes of the service(s) you are using.
Using some of our services may involve us sharing your personal information with other organisations such as a referral partner organisation or funder. We will always ask your consent before we do this.
In order to provide some services, we collect information about referral partner organisations who we refer clients to. This information contains some personal information in terms of name and email address of the main contacts for referrals at each organisation.
• Keeping you in touch
To keep you in touch with our work and other local services the personal information we collect can include name, address, email address and phone number. If you are a service user we will always ask your consent to contact you with information and you can withdraw your consent at any time by writing to us.
• Fundraising and donations
In order to manage donations or enable you to fundraise for us we will need personal information including your name, address and email address. For donations we will also ask whether you are a UK tax payer. We will also ask for payment information and will always use a secure payment service to process your payment.
• As an employer and provider of voluntary opportunities
We will collect a range of information in order to process your application and assess your suitability for the opportunity that you are applying for. This will include name, address, email address, phone number, education details, employment background and details of your experience. If you become a member of staff or volunteer at Shekinah we will collect further personal information necessary for payroll and health and safety, including bank details, national insurance number and emergency contact information.
How long we will keep your data
• Service Provision
We will not keep personal information for longer than necessary and will destroy information securely according to our data retention policy. However, you can withdraw your consent at any time by writing to us and we will remove your personal data from our records within one month of your request, as long as there are no legal requirements for us to keep it. If we have shared your personal data with other organisations we will inform the relevant organisations to tell them that you have requested that we remove your personal data. We may then keep the minimum necessary information in a file for monitoring purposes.
• Keeping you in touch
We will keep your contact details on our distribution lists until you tell us that you want to be removed.
• Fundraising and donations
We retain information about Gift Aided donations as required by HMRC and for audit purposes. Information about supporters and donors is retained for 5 years after the last interaction, to help us communicate with you appropriately, to identify trends, and to fundraise more effectively. You may ask us to stop using your data at any time, and subject to our audit and HMRC responsibilities, you may ask us to delete your data. We may then keep the minimum necessary information in a file for monitoring purposes.
• As an employer and provider of voluntary opportunities
We will keep records of past employees for up to 7 years after the date they left our employment. We will keep records of unsuccessful applicants for either paid or voluntary roles for up to one year after the date of their application. We will keep details of volunteers for up to 2 years after the date they stop volunteering for the organisation.
Security of your data
Unless required to do so by law, we will never share your information with third parties unless we have your explicit permission to do so. This may be necessary for some of our services, but we will always explain this to you and seek your permission before sharing. Once we have referred you to another service your personal information will be stored by that organisation and you should refer to their Privacy Policy for information about how they will handle it.
We are committed to ensuring your personal information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. All data we collect electronically is securely backed up and hosted within the UK. We use a number of companies to help us provide our services. Any of your personal data that is processed via these companies is kept secure and remains the property of Shekinah. We will ensure that the companies that we use have up to date Privacy Policies and work to data protection legislation requirements.
• Personal information given via our website
Any personal information that you provide via our website may also be available to our website provider to enable us and them to 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 following will apply:
1. a) Your data will be made available to our website provider.
2. b) The data that may be available to them include any of the data we collect as described above for keeping you in touch and fundraising and donations purposes.
3. c) Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
4. d) They will store your data for a maximum of 7 years.
5. e) This processing does not affect your rights under this privacy policy
Our website uses cookies to collect information on how visitors use it. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web servicer 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 do not usually 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.
We use Google Analytics on our websites to monitor visitor activity and make changes to improve functionality. Google Analytics generates statistical and other information about websites use by means of cookies, which are stored on your devices. The information generated relating to the Shekinah website can be used to create reports about the use of the sites. Details captured during your visit could include, but are not limited to, the pages you visit, how long you spend on each page, how you got to the site (e.g. via a search engine), and what you click on while you’re visiting the site.
All data collected by Google Analytics is anonymous and will not identify you as an individual. Google, not Shekinah, stores activity information, and you can view Google’s privacy policy on their website, where you can also opt out of being tracked by Google Analytics across all websites.
• Cookies that our website may use
Cookie Name Used by Description Expiration
__utma Google Analytics Stores the amount of visits of a user, the time of their first visit, the previous visit, and the current visit. It does not contain any personal information and is used only for analytical purposes. 2 years from set/update
__utmz Google Analytics This performance cookie stores where a user came from (eg. search engine, search keyword, link). 6 months from set/update
_ga and _gid Google Analytics Used to distinguish between website users in Google Analytics. 2 years and 2 hours
_gat_UA-XXXXXXXX-X (where the Xs are replaced by the Google Analytics ID number) Google Analytics Used to moderate calls to the Google Analytics service. 1 minute
__unam ShareThis Set as part of the ShareThis service and monitors “click-stream” activity, e.g. web pages viewed, navigation from page to page, time spent on each page etc. The ShareThis service only identifies a user if they have separately signed up with ShareThis for a ShareThis account and given them consent. Checks how long you stay on a site: when a visit starts, and ends. It does not contain any personal information and is used only for analytical purposes. 14 months
cc_cookie_accept Website Stores whether the user has accepted the cookie message or not. 365 days
ASP.NET_SessionId Website Used for authenticating a user’s session after logging in. Closes when you exit the browser. End of session
ARRAffinity Website Tells our infrastructure which server to handle the request. End of session
MemberLoggedIn Website A binary flag which stores whether a user is logged in or not. End of session
ai_session and ai_user Website Tracks users as they navigate the website predominately for infrastructure performance insights. 1 day
DisplayName Website Keeps track of a donors preference to show their name during a Direct Debit. End of session
Our website contains links to other websites of interest. You should be aware that we do not have any control over the content or security of external sites and therefore we cannot be held responsible for the protection and privacy of any information which you provide whilst visiting these sites. You should exercise caution when disclosing personal information on any website and should read the website’s privacy statement to understand how your personal data will be used.
Legal Basis of processing
Data Protection regulations permit the processing of your data under 6 different legal bases.
When processing your data, we rely on the following bases, depending on the purpose of the processing, and how we use it to communicate with you:
• Consent basis – We rely on your consent when we record your personal information because you are using our support services. We also rely on consent basis when sending service users information about our services or other local services either by email, SMS/ text or post.
• Vital interests – We rely on vital interest in safeguarding situations where the processing of personal data is necessary to protect someone’s life.
• Legitimate interest basis – We rely on legitimate interests when sending staff connected to other organisations information by email about our work or the work of other local organisations. When we do this, we will always provide you with easy ways to ask us not to send such information in the future. We also rely on legitimate interests when processing personal data in relation to volunteers or people applying for voluntary positions.
• Contractual basis – We rely on a contractual basis if you work for us, or apply to do so, in order to process your application and provide support for employees/ monitor performance.
• Legal obligation basis – We utilise this basis for processing data for gift aid, in our role as employer, and where necessary for regulatory matters.
Your Rights
Under the Data Protection Act 1998 and the General Data Protection Regulations you have certain rights about the personal information we hold about you:
• You have the right to receive copies of the information we hold on you.
• If you are a service user you have a right to withdraw your consent to us holding your personal information and ask for it to be removed.
• You have a right to object to processing that is likely to cause, or is causing you damage or distress.
• You have a right to prevent processing for direct marketing.
• You have a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed.
• You have a right to claim compensation for damages caused by a breach of data protection legislation.
Applications for any of the above can be made in writing by email to reception@shekinah.co.uk or by post to the Data Protection Co-ordinator, Shekinah Mission, Bath Street, Plymouth, PL1 3LT. If you are unable to put your request in writing please ‘phone 01752 203480.
If you have any queries relating to how Shekinah has processed your personal information you can contact us at reception@shekinah.co.uk
If you are unhappy with our response to your enquiry about how we have processed your personal information, you have the right to lodge a complaint with the Office of the Information Commissioner.
Information Commissioner’s Office
If you would like more information about the Data Protection Act and the General Data Protection Regulations you can contact the Information Commissioner’s Officer at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Website: https://ico.org.uk/
Shekinah will review and may update this policy from time to time. You should check this page periodically to ensure that you are aware of any changes.
