Privacy Policy ~ Volunteers
1. INTRODUCTION
1.1 Shared Interest Society AND Shared Interest Foundation (or "SI") is committed to protecting the privacy and security of your personal information.
1.2 This privacy notice describes how we collect and use personal information about you during and after your volunteering role with us, in accordance with the General Data Protection Regulation (GDPR).
1.3 It applies to all volunteers.
1.4 SI is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
1.5 This notice applies to active, inactive and former volunteers. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
1.6 It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
2. DATA PROTECTION PRINCIPLES
2.1 We will comply with data protection law. This says that the personal information we hold about you must be:
2.1.1 Used lawfully, fairly and in a transparent way.
2.1.2 Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
2.1.3 Relevant to the purposes we have told you about and limited only to those purposes.
2.1.4 Accurate and kept up to date.
2.1.5 Kept only as long as necessary for the purposes we have told you about.
2.1.6 Kept securely.
3. THE KIND OF INFORMATION WE HOLD ABOUT YOU
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.2 There are "special categories" of more sensitive personal data which require a higher level of protection.
3.3 We may collect, store, and use the following categories of personal information about you:
3.3.1 Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
3.3.2 Date of birth.
3.3.3 Gender.
3.3.4 Next of kin and emergency contact information.
3.3.5 Bank account details.
3.3.6 Out of pocket expenses information.
3.3.7 Start date.
3.3.8 Location of workplace.
3.3.9 Volunteer appointment information (including references (where relevant and other information or cover letter or as part of the volunteer application process).
3.3.10 Records (including job titles, work/voluntary history, working/volunteering hours and training records.
3.3.11 Performance information.
3.3.12 Information about your use of our information and communications systems.
3.3.13 Photographs.
We may also collect, store and use the following "special categories" of more sensitive personal information if you disclose it to us. Information about your religious beliefs, and health.
4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
4.1 We typically collect personal information about volunteers through the appointment process, directly from volunteers who apply via an enquiry form on the SI website, by direct request or at an event.
4.2 We will collect additional personal information in the course of job-related activities throughout the period of you volunteering for us.
5. HOW WE WILL USE INFORMATION ABOUT YOU
5.1 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
5.1.1 Where we need to comply with a legal obligation.
5.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
5.2 We may also use your personal information in the following situations, which are likely to be rare:
5.2.1 Where we need to protect your interests (or someone else's interests).
5.2.2 Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
5.3 We need all the categories of information in the list above (see the kind of information we hold about you) primarily to allow us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
5.4 Making a decision about your recruitment or appointment.
5.4.1 Determining the terms on which you volunteer for us.
5.4.2 Paying your expenses.
5.4.3 Business management and planning, including accounting and auditing.
5.4.4 Conducting reviews, managing performance and determining performance requirements.
5.4.5 Assessing suitability for a particular job or task.
5.4.6 Making decisions about your continued volunteering.
5.4.7 Making arrangements for the termination of our voluntary relationship.
5.4.8 Education, induction and ongoing training and development requirements (including shadowing other volunteers).
5.4.9 Dealing with legal disputes involving you, other volunteers, employees, workers and contractors, including accidents.
5.4.10 Ascertaining your fitness to volunteer.
5.4.11 Complying with health and safety obligations.
5.4.12 To prevent fraud.
5.4.13 To monitor your use of our information and communication systems to ensure compliance with our IT policies.
5.4.14 To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
5.4.15 To conduct data analytics studies to review and better understand retention and attrition rates.
5.4.16 Equal opportunities monitoring.
5.5 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
5.7 If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our other volunteers, employees and workers).
Change of purpose
5.7 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5.8 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
6.1 "Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
6.1.1 In limited circumstances, with your explicit written consent.
6.1.2 Where we need to carry out our legal obligations and in line with our Data Protection Policy.
6.1.3 Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our Data Protection Policy.
6.1.4 Where it is needed to assess your volunteering capacity on health grounds, subject to appropriate confidentiality safeguards.
6.2 Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
Our obligations
6.3 We will use your particularly sensitive personal information in the following way:
6.3.1 We will use information about your physical health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to volunteer.
Do we need your consent?
6.4 We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
7. INFORMATION ABOUT CRIMINAL CONVICTIONS
7.1 We do not envisage that we will hold information about criminal convictions.
8. AUTOMATED DECISION-MAKING
8.1 We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
9. DATA SHARING
9.1 We may have to share your data with third parties, including third-party service providers and other entities in the group.
9.2 We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the voluntary relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: IT services only.
How secure is my information with third-party service providers and other entities in our group?
9.3 All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with other entities in the group?
We don't share your personal information in this way.
What about other third parties?
9.4 We only share your personal information with a regulator or to otherwise comply with a legal obligation.
Transferring information outside the EU
9.5 We do not transfer the personal information we collect about you outside the EEA and will notify you in writing if this position changes.
10. DATA SECURITY
10. 1We have put in place measures to protect the security of your information. Details of these measures are available upon request.
10.2 Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
10.3 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
10.4 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
11. DATA RETENTION
How long will you use my information for?
11.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.
11.2 In most cases we delete volunteer records 12 months after the volunteer has ceased their arrangement with us. This is an automated process.
11.3 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a volunteer of the company we will retain and securely destroy your personal information in accordance with our Data Protection Policy.
12. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
12.1 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your volunteeting relationship with us.
Your rights in connection with personal information
12.2 Under certain circumstances, by law you have the right to:
12.2.1 Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
12.2.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
12.2.3 Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
12.2.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
12.2.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
12.2.6 Request the transfer of your personal information to another party.
12.3 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Company Secretary in writing.
No fee usually required
12.4 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
12.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
13. RIGHT TO WITHDRAW CONSENT
13.1 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Company Secretary. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
14. COMPANY SECRETARY
14.1 We have appointed the Company Secretary to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Company Secretary. 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.
15. EUROPEAN UNION
If you are in the European Union, you may address privacy-related inquiries to our EU representative pursuant to Article 27 GDPR:
EU-REP.Global GmbH, Attn: Shared Interest
Hopfenstr. 1d, 24114 Kiel, Germany
shared-interest@eu-rep.global
www.eu-rep.global
16. CHANGES TO THIS PRIVACY NOTICE
16.1 We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
16.2 If you have any questions about this privacy notice, please contact the Company Secretary at companysecretary@shared-interest.com or by telephone on 0191 233 9100.