For the purpose of Regulation (EU) 2016/679 (the "General Data Protection Regulation" or "GDPR”) and the Data Protection Act 2018, the data controller is: Urban Saints, Kestin House, 45 Crescent Road, Luton, Bedfordshire, LU2 0AH, email or telephone 01582 589580. The information you provide will be held in accordance with Data Protection legislation and used by Urban Saints to supply the services which you have requested and comply with legislation.
This policy was approved by the Trustees on 22 September 2018.
WHAT INFORMATION DO WE PROCESS AND STORE?
a) To serve in an Urban Saints team as a volunteer, member of staff or as a Trustee, we process application forms, reference forms, vetting checks and updates through DBS, AccessNI, PVS Scotland, Garda Ireland, and new starter forms with your consent. As part of an Urban Saints team, we may process various forms and information such as minibus applications, training, holidays, meeting notes, appraisals and sickness, in line with our contract or agreement. Any medical information provided is held in strictest confidence with your consent for your wellbeing. Any criminal record or vetting information provided is held in strictest confidence with your consent to comply with our legal obligations. We keep records of all staff members on our operational system and of all staff, trustees and volunteers on our secure database. This is to comply with our legal obligations and to keep in touch when we have your consent.
b) To process donations for our work, we process the information you provide on our website, fund-raising websites, campaign letters, forms and phone calls with your consent. Our website donation processing is Payment Card Industry PCI-compliant. Our support centre also processes credit card donations. We record donations on our secure database to comply with our legal obligations, and to keep in touch when we have your consent.
d) To provide resources, we process orders with your consent. These are from the Urban Saints website or phone orders from our online shop, as well as Energize trial applications and sign-ups from the Energize website, Energize contact cards, subscription and direct debit forms. We use secure third-party companies to process payments on our web shop and Energize, as well as online direct debits. All financial online transactions are Payment Card Industry PCI-compliant. We will share name, product and address details with the companies who deliver your resources with your consent. We record orders on our website to comply with our legal obligations and also on our secure database to keep in touch when we have your consent.
e) To help you stay in touch with Urban Saints, we record your communication preferences on our secure database by processing exhibition contact cards, website contact sign-ups, website Friends of Westbrook sign-ups, social media requests, emails, calls, electronic forms, consent paragraphs on various forms, and campaign opt-ins by post. You can amend or stop our communications from us at any time by emailing or by post to Urban Saints, Kestin House, 45 Crescent Road, Luton, Bedfordshire, LU2 0AH. We will only communicate with you when we have a legitimate interest to do so, where you have given your consent, or where we have a contract with you:
- We may contact you by post or telephone where we have a legitimate interest to do so. Examples include updating recent donors about how their donation has helped other people, or updating group and camp attendees about the next event. If you have asked us not to contact you in this way, we will always respect this.
- We also stay in touch through our Facebook, Twitter, Instagram and LinkedIn pages. Each social media provider has contractual conditions which are agreed to by you before you use. These can be reviewed and amended by you in the “Settings” of your social media account.
- Some people tell us about their experiences with Urban Saints to encourage other people. They may volunteer, use our resources, sit on committees or participate in ministry. The information may be sensitive and include details of their religious views, affiliations and lives, in addition to biographical and contact information. If we have consent, we may use these stories in communications, but only as agreed in advance for each publication or media recording.
f) To manage groups, we process website forms with your consent for Energize groups and leaders detailing information about “My Group”, “My Team” and “My details”. For Urban Saints and Energize+ Groups, we process Group, Leader and Volunteer application forms and record these on our secure database to comply with our legal obligations. Group leaders will process child application forms with your consent and will complete and retain accident, incident and safeguarding reports, as well as adequate records of schedules and activities locally to comply with our legal obligations. Where consent has been given, Groups may take photos, recordings and videos for records and communications. Any medical information provided by you on application forms is held in strictest confidence for your wellbeing with your consent. Any criminal record or DBS information provided during application is held in strictest confidence with your consent to comply with our legal obligations.
g) To improve our services, we conduct research from time to time. We may contact you if we have your consent to do so or a contractual basis for contacting you.
h) To pay staff, suppliers and expenses, we process information with your consent that is provided on forms, invoices and our expense reimbursement application. Staff payments are processed by our payroll company in line with contracts of employment. Supplier and volunteer payments are created and authorised on our financial system. All are paid by instruction to our bank. We record all payments in our financial system to comply with our legal obligations.
i) To respect the views of children aged 13 or over, we seek and record their consent on application forms and other permission forms, in addition to their parent or legal guardian. For children under the age of 13, we secure and record the consent of their parent or legal guardian.
j) To display our websites on your electronic devices and monitor how the websites are performing, the websites send two small, anonymous strings of text known as cookies to the electronic devices that you use:
- One cookie allows us to know when your electronic device returns to the website. If you log into our websites, this session cookie is key to staying logged in during the visit. If we have to investigate a problem, the cookie allows us to retrieve the last date, time and web-page that you visited the website. Session details are only stored temporarily (normally less than 24 hours) and the cookie effectively expires as soon as your internet session expires.
- One cookie helps us to see how the website is performing and used. This Google Analytics cookie allows us to collect the “IP address” allocated to your device that day (not your name), the type of browser and device, any anonymous socio-demographic information that Google has consent from you to share, any links that you have used to get to the website, the pages you have visited and for how long. Google Analytics aggregates the information for all users so that we can identify where the website isn’t working well, how people arrive at the website, and how we can improve our services and the use of our services. We do not combine the information with other personal data to identify you. You can read Google’s policy here: https://policies.google.com/privacy
- Our websites will only function properly when the two cookies are fully operating, but you can block or limit how cookies work on your device under “Settings” in your internet browser and can also block the Google Analytics cookie at https://tools.google.com/dlpage/gaoptout
- We use Vimeo and YouTube to embed videos on our websites and they may send cookies to your device. We cannot control cookies from these or any other third-party websites, so please do read the privacy statements of the organisations, for example at https://vimeo.com/cookie_policy.
- We use a third party to display and manage our online shop of clothing and resources. You can read about the cookies used here: https://trykong.com/cookie
k) To respect the privacy of our supporters and the integrity of the information that you have trusted to us, we do not append externally-sourced data to your information, and we do not use artificial intelligence to make automated decisions about the services and costs that we offer to you.
WHO HAS ACCESS TO MY INFORMATION?
We will never sell, swap, give away or lease your personal information to third parties unless we are required to do so by law.
We are committed to ensuring that your information is secure and are aware that a connection with Urban Saints can infer religious beliefs – a special category of personal data in Data Protection legislation.
In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your information. Many of these are managed by our IT Provider with whom we have a comprehensive agreement to ensure the confidentiality and security of your information.
Urban Saints has written contracts with secure external data processors who process or store data for us. Examples include organisations who print and post our mailings, secure database systems, and the airlines we book with for overseas discipleship trips. The processors may change from time to time, but the contracts provide assurance that personal information is only transferred, processed and stored by them confidentially, legally and securely.
Where you have chosen a password to be able to access certain areas of our websites, you are responsible for the password being strong and keeping it confidential. You must not share your password with anyone, even for a short time. If you become aware that someone may know your password, please change it online or contact us by telephone on 01582 589580 to arrange for it to be changed.
HOW LONG DO YOU KEEP MY INFORMATION?
We keep your personal information for only as long as is necessary to carry out our work or comply with legal and insurance requirements.
We have a data retention policy which requires us to delete personal data that is no longer required for the purposes you have approved and our legal and insurance obligations – at least once per year.
WHAT ABOUT LINKS TO OTHER WEBSITES?
Our websites can contain links to other websites which are not managed by Urban Saints. If you follow these links, we cannot be responsible for the protection and privacy of any information which you provide on those websites, even if you access them from our website. You should exercise caution and study the privacy statement for the website in question.
WHAT ARE MY RIGHTS?
You may request details of the personal information which is being processed or is held about you. You may also ask us to correct, delete, transfer or stop processing your personal information. Please request by email or by post to Urban Saints, Kestin House, 45 Crescent Road, Luton, Bedfordshire, LU2 0AH.
If we change how we process, use or store your information, or otherwise change this policy, we will update you if you have consented to us contacting you. You may also ask us to stop processing or to delete your information in whole or in part at any time.
If you feel that a request has not been properly responded to, please contact the Data Protection Officer by email to DPO@urbansaints.org or by post to the address above.
If the issue remains unresolved, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/ or by telephoning 0303 123 1113 at your local rate, or by post to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow. Cheshire SK9 5AF.