PVMCENTRE GDPR Privacy Policy
General Information
PVMCENTRE (PVMC) is committed to protecting the rights and privacy of individuals in accordance with the new General Data Protection Regulations (GDPR which comes into effect on Friday 25th May and will replace the Data Protection Act 1998). PVMC processes information about its staff, students and other individuals it has dealings with for a range of administrative purposes (e.g. to recruit and pay staff, administer programmes of activities and comply with legal obligations to funding bodies and government). In order to comply with the law, information about individuals must be collected and used fairly, stored safely and securely and not disclosed to any third party unlawfully. PVMCENTRE does not authorise any employee, volunteer or agent of Hackney Quest to hold or process any personal data on its behalf except as stated in task descriptions. Users of personal data on or off premises (e.g. pc at home or laptop) should consider the legal position before attempting to process personal data.
Our data protection officer is Fiona Sowole (fiona@pvmcentre.org).
Personal data we hold
Personal data that we may collect, use, store and share (when appropriate) includes, but is not restricted to:
- Contact details, contact preferences, date of birth, identification documents
- Characteristics, such as ethnic background, or special educational needs
- Exclusion information
- Details of any medical conditions, including physical and mental health
- Attendance information
- Safeguarding information
- Details of any support received, including care packages, plans and support providers
- Photographs
We may also hold data that we have received from other organisations, including schools, local authorities and other organisations.
Why we use this data
We use this data to:
- Support people
- Monitor and report on progress
- Provide appropriate pastoral care
- Protect welfare
- Assess the quality of our services
- Carry out research
- Comply with the law regarding data sharing
Our legal basis for using this data
We only collect and use personal data when the law allows us to. Most commonly, we process it where:
- We need to comply with a legal obligation
- We need it to perform an official task in the public interest (in our case, supporting young people)
Less commonly, we may also process personal data in situations where:
- We have obtained consent to use it in a certain way
- We need to protect the individual’s vital interests (or someone else’s interests)
Where we have obtained consent to use personal data, this consent can be withdrawn at any
time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.
Some of the reasons listed above for collecting and using personal data overlap, and there may
be several grounds, which justify our use of this data.
Collecting this information
While the majority of information we collect is mandatory, there is some information that can be
provided voluntarily.
Whenever we seek to collect information from you, we make it clear whether providing it is
mandatory or optional. If it is mandatory, we will explain the possible consequences of not
complying.
How we store this data
We keep personal information in both electronic and paper formats. We may also keep it beyond
attendance at our Head Office if this is necessary in order to comply with our legal obligations.
Data sharing
We do not share information with any third party without consent unless the law and our policies
allow us to do so.
Where we transfer personal data to a country or territory outside the European Economic Area, we
will do so in accordance with data protection law.
Rights regarding personal data
All Volunteers/staff have the right to make a ‘subject access request’ to gain access to personal
information that the charity holds about them. If you make this request, we will:
- Give you a description of it
- Tell you why we are holding and processing it, and how long we will keep it for
- Explain where we got it from, if not from you or your child
- Tell you who it has been, or will be, shared with
- Let you know whether any automated decision-making is being applied to the data, and any
consequences of this
- Give you a copy of the information in an intelligible form
Individuals also have the right for their personal information to be transmitted electronically to
another organisation in certain circumstances.
If you would like to make a request please contact our data protection officer, Fiona Sowole
Other rights
Under data protection law, individuals have certain rights regarding how their personal data is used
and kept safe, including the right to:
- Object to the use of personal data if it would cause, or is causing, damage or distress
- Prevent it being used to send direct marketing
- Object to decisions being taken by automated means (by a computer or machine, rather than by a person)
- In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
- Claim compensation for damages caused by a breach of the data protection regulations
To exercise any of these rights, please contact our data protection officer.
Complaints
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading or inappropriate,
or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact our data protection officer, Fioan Sowole (Fioan@pvmcentre.org)
Alternatively, you can make a complaint to the Information Commissioner’s Office:
- Report a concern online at https://ico.org.uk/concerns/
- Call 0303 123 1113
- Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Other information
Only appropriate information will be requested from Volunteers/staff and the maintenance of
records will aim to be factual, if an opinion is recorded we will aim to back that up with evidence,
we will aim to only record information we would be happy for the data subject to see.
All confidential records will be disposed of safely e.g. shredded.
You should not disclose personal data to colleagues unless they have a legitimate interest in the
data concerned. As there is no definition as to what a “legitimate interest” is, it will have to be a
matter of judgment in each case. As a rule you should consider whether or not the information is
necessary to allow your colleague to perform their task and the level of detail necessary.
References must contain factually correct information, sensitive data will not be disclosed without
the explicit consent of the volunteer where opinions about a person’s suitability are disclosed they
must be defensible and justifiable on reasonable grounds.
If we are unable or unwilling to give a reference, such a refusal must be communicated carefully,
without, in effect, implying a negative reference and thus disclosing personal data.
All confidential paper information, should ideally be cross shred onsite, bulk files will be shredded
using an independent company and security certificate obtained.
For confidential, electronic information:
DVDs/CDs should be shredded and then put into the recycling stream
Computer hard drives and external storage media (such as USB sticks) should be wiped with a
suitable software tool. No unencrypted data should be left on these types of media before reusing/
recycling/disposal.
Media that cannot be wiped initially will need to be sufficiently protected before being overwritten
e.g locked filling cabinet.
Responsibility of Head of Service