‘ONCE, WE WERE SOLDIERS’
DATA PROTECTION, PRIVACY AND COMMUNICATIONS
ONCE, WE WERE SOLDIERS (OWWS) takes the privacy of our Clients, Beneficiaries, Volunteers and Supporters, very seriously. This notice summarises how OWWS collects and uses personal information about people who contact us and who we contact by phone, face to face, by email, in writing, or by visiting our website. The notice includes details of how we store personal information, how we use it, and how those who give us their details can request that their data is used by OWWS. Every reasonable effort is taken to ensure that personal information is kept secure and intact. For details of OWWS Data Protection, Privacy and Communications Policy, which contains fuller detail, please contact OWWS at the address below.
The terms of this notice may change, so please check it from time to time. This version published on 14th May 2018 supersedes all previous versions.
By using our website, you are accepting and consenting to the practises described in this notice.
General Data Protection Regulation (“GDPR”) provides the legal framework that defines how personal information can be used. OWWS is fully committed to complying with the principles set out in GDPR and has a legal duty to protect any information we collect from you.
How To Contact OWWS?
If you have any queries about this notice, or to contact OWWS regarding our processing of your personal data, please contact OWWS at our Head Office:
The Springboard Centre
1. How Do We Notify You of Changes to this Notice?
We keep this Notice under regular review and will contact you by post, email, or by telephone, should there be any changes. We will also update the Notice on our website . If you keep using the services of OWWS after we notify you of any changes, this will be taken that you consent to the updated Privacy Notice. If not, you may request that your data is removed from our records and destroyed.
2. Who Are We?
OWWS is the Data Controller. This means it decides how your personal data is processed and for what purpose. OWWS is a registered charity (Registration No 1158318) that provides support and assistance for former serving members of the British Armed Forces. OWWS service is aimed towards homeless British Armed Forces veterans, those facing homelessness, and veterans that have fallen on hard times, and provides support for veterans who have served at any time in the Armed Forces. OWWS engages in fundraising activities to enable this support to be provided with an eventual aim to open one or more fully functional transition centres in the UK to provide training and support for Armed Forces personnel who are about to embark on their journey of resettling into civilian life.
3. Your Personal Data – What Is It?
Personal data is any information relating to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the Data Controller’s (ie OWWS’s) possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
4. How Do We Process Your Personal Data?
We process (ie obtain’) personal information from you when you enquire about our activities (including fundraising), request our help or support, register with us, send or receive an email, make a donation to us, ask a question about our services, or otherwise provide us with personal information. We may also receive information about you from third parties, for example from someone contacting us on your behalf (eg another organisation, charity or agency, or a friend or family member).
OWWS complies with its obligations under the “GDPR” by keeping personal data up to date, by storing and destroying it securely, by not collecting or retaining excessive amounts of data, by protecting personal data from loss, misuse, unauthorised access and disclosure, and by ensuring that appropriate technical measures are in place to protect personal data.
5. What Is The Legal Basis For Processing Your Personal Data?
The legal basis for OWWS processing your personal data is one of the following:
• Your explicit consent
• To protect your interests or that of another person
• For the performance of a contract to which you are a party
• For legal obligations for us to comply with the law
• For the performance of a task carried out in the public interest
• For the purpose of our legitimate interests or the legitimate interests of a third party, except where your rights as a data subject override our legitimate interest. The legitimate interest we rely upon is subject to an assessment based on the specific context and circumstances.
6. What Information Do We Collect?
The personal information we collect will depend on the reason for your contact with OWWS, and only information that we actually need is collected. We collect this information for the purpose of providing support to our clients/beneficiaries, and to communicate effectively and appropriately with our volunteers and supporters. It may include your name, address, telephone number and email address. We may also collect more sensitive information such as details of medical health, criminal record and other sensitive information. For more specific details of the personal information we may collect from you please request a copy of our full Data Protection, Privacy and Communications Policy which is available from OWWS at the above address.
7. How Do We Use Your Data?
Personal data will be protected from unauthorised or accidental disclosure and processed in an appropriate manner to maintain its integrity and confidentiality. OWWS only uses your personal data for the purpose for which you provided it, and to provide the services and support you request. For more specific details of how we use your data, please request a copy of our full Data Protection, Privacy and Communications Policy which is available from the Data Protection Officer at the above address.
8. Sharing Your Personal Data
Your personal data will be treated as strictly confidential and will only be seen by those who need to see it in order to carry out their roles at OWWS. This may include Trustees, Volunteer Case Workers and Admin Volunteers.
OWWS will only share your data with third parties, other organisations, charities and agencies, with your explicit consent, in order to provide you with advice, support, access to accommodation, assistance with health needs, or in order to carry out a OWWS event or activity.
Before sharing any sensitive, special category personal data, OWWS will inform you of the details of the third party with whom we wish to share the information, and your explicit consent for this sharing will be obtained. For more specific details of special category information please refer to Section 6 of the full Data Protection, Privacy and Policy which is available on request from OWWS at the above address.
OWWS will only share your personal data with third parties without your explicit consent in exceptional circumstances such as to comply with the law, if requested to provide the information by law enforcement authorities, or as expressly permitted under applicable data protection legislation. Examples of this might include people contacting OWWS reporting abuse, reporting serious self harm, expressing the intention of harming someone else, or any matter regarding national security. It includes requests by HMRC if you are a Donor making a donation under the Gift Aid scheme.
Occasionally personal data may be shared with third party organisations, charities and agencies via email to enable support, shelter or housing to be provided to you.
9. What Are Your Rights?
OWWS recognises that your personal data belongs to you and we don’t wish to use it in ways that you don’t want us to.
You can exercise a variety of rights regarding our use of your data:
• You can ask us at any time for a copy of the information we have about you in a common, machine-readable format by completing a Subject Access Request Form (available from OWWS office above)
• You can ask us to update, correct or amend any data we have about you. This will be done as soon as possible.
• You can ask us to delete your data
• You can object to any processing of your data that we do on the basis of legitimate interests
• You can withdraw your consent to the processing of your data at any time
• You can ask us to restrict the processing of your data if there is a dispute in relation to the accuracy or processing of your personal data
• You can lodge a complaint with the UK Information Commissioners Office (see address below)
These rights apply whether we hold your information on paper or in electronic form.
To exercise any of the foregoing rights, or to have your personal details amended or removed, please contact OWWS in writing at the above address, or by email. OWWS will respond to your request within one month of receiving it.
Please note that some of these rights are not absolute. For example, we may not be able to forget you if we have to keep some of your data to comply with the law, but we will evaluate your request in accordance with applicable data protection laws.
If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records. If your personal details change, please help us to keep your information up to date by notifying us at the address above.
10. How Do We Store Your Data?
We place great importance on the security of all personally identifiable information associated with our clients/beneficiaries, supporters and volunteers. We have security measures in place to protect against the unauthorised or accidental disclosure, loss, misuse, alteration or destruction of personal data under our control. Personal data held on paper is stored in a locked filing cabinet, and personal data held on electronic devices is password/pin number/fingerprint protected. For more specific details of how we store your data, please request a copy of our full Data Protection, Privacy and Communications Policy which is available from OWWS at the above address.
Payment Card and Bank Cheque Information
OWWS does not store any sensitive payment card data, or data from bank cheques, in our systems.
11. How Long Do We Keep Your Personal Data?
Personal data will not be retained for any longer than is necessary for the purpose it is collected, and will be deleted within a maximum period of 7 years from the date of the last contact made by an individual to OWWS, or at the point at which a request is received to delete. For more specific details please request a copy of our full Data Protection, Privacy and Communications Policy which is available from OWWS at the above address.
12. Under 16’s
OWWS is concerned to protect the privacy of children aged under 16. Before collecting personal information about a child aged under 16 we will seek consent from a parent or guardian who holds ‘parental responsibility’ We will not knowingly request or collect from a child any information that can be traced to the child, such as an email address, name, or information about the child’s family. Unless a parent or guardian who holds ‘parental responsibility’ consents to such use in advance, we will not knowingly use information that a child provides to us for any fundraising or promotional purpose.
For our raffle and gaming products, due to Gambling Commission regulations, we cannot allow people under the age of 16 to take part.
13. Your Choices
You have a choice about whether you want to receive information about our progress and fundraising activities. We will not use your personal information for marketing purposes unless you have given explicit consent to be contacted. You can change your marketing preferences (such as email or post at any time), by contacting OWWS at the above address.
14. Transfer of Information Outside of the EU
As OWWS sends and receives emails containing personal information, given that the Internet is a global environment, using it to collect and process personal data necessarily involves the transmission of data on an international basis. This means for instance that data you pass to us may be processed outside the European Economic Area, although the data will always be held securely and we will take steps to ensure they provide an adequate level of protection in accordance with the UK’s Data Protection Act. By submitting your personal information you agree to this transfer, storing or processing at a location outside the EEA.
15. Cookie Usage
You have a right to report any of your concerns about our use of your data to the Information Commissioner’s Office:
The Office of the Information Commissioner
Tel: +44(0) 01625 545 745