Privacy and Cookie Policy SCVS Privacy & Cookies Policy INTRODUCTION This privacy notice provides you with details of how we collect and process your personal data. SWANSEA COUNCIL FOR VOLUNTARY SERVICE are the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). Our email address is [email protected] Our postal address is SCVS, Voluntary Action Centre, 7 Walter Road, Swansea. SA1 5NF If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected] or calling us on 01792 544000. In addition to this overarching privacy and cookie policy, where an SCVS Project or Service has a different lawful basis for processing your data, different retention periods or gathers sensitive personal data, this is covered by a specific Privacy Notice, as follows: Swansea Volunteer Centre SCVS Privacy Notice for Job Applicants Health, Social Care & Wellbeing Facilitator Involve Volunteering Project Swansea Youth Bank Regional Health Social Care & Wellbeing Grant Scheme Swansea Dementia and Carer Project Penderi Young People’s Wellbeing Project Our Neighbourhood Project SCVS Cluster Grant Schemes Swansea Poverty Truth Commission Sensitive Data For the majority of organisational support services, we do not need to collect sensitive data from you, however; If you are applying to become a volunteer with one of our projects, using the services of the Swansea Volunteer Centre, or applying for a paid position at the organisation, we need to collect the following sensitive data about you in order to provide the service and fulfil funder monitoring requirements. This data will only be passed on as anonymous statistical information, which will not be connected to your identity: Race or ethnicity Sexual orientation Information about your health Criminal convictions or offences We require your explicit consent for processing sensitive data and we will request your signature for this consent. Where sensitive data is required by an SCVS project, this will be covered by a separate Privacy statement. 2. HOW WE USE YOUR PERSONAL DATA We will only use your personal data when legally permitted. The most common uses of your personal data are: Where we need to perform the contract between us. 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. Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending information communications to you via email or hardcopy. You have the right to withdraw consent to information communications at any time by emailing us at [email protected] Purposes for processing your personal data Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant. We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. SCVS run a number of projects / services where the specific personal data collected may differ from the list below. Please contact the project you are involved with to request a copy of their Privacy Policy if it is not available on their project page on the SCVS website, or listed at the beginning of this policy. Purpose/Activity Type of data Lawful basis for processing To register you as a new SCVS Member organisation (a) Identity (b) Contact (c) Legal structure Performance of a contract with you To record your organisation on the TSSW Third Sector Support Wales (http://thirdsectorsupport.wales/) CRM system (a) Identity (b) Contact/s (c) Legal structure (d) Record interactions Necessary for our legitimate interests to fulfil our role as the umbrella support organisation for the Third Sector in C&C Swansea Necessary for our legitimate interests to comply with the TSSW governance agreement between TSSW and Welsh Government This agreement is governed by an MoU, and a detailed privacy statement, which can be found at http://thirdsectorsupport.wales/privacy/ To process and deliver services to you, including: (a) Manage payments, fees and charges; collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Asking you to be part of sector specific groups, relevant to the mission of your organisation (d) Informing you of news of relevance to the local Third Sector (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to fulfil our role as the umbrella support organisation for the Third Sector in C&C Swansea To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy. Please see ‘Cookie Usage’ section, below To make suggestions and recommendations to you about services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Necessary for our legitimate interests to develop our products/services, grow our business and inform the sector Sector specific communications You will receive sector specific communications from us if you have: requested information from us or purchased services from us (for example, training); or if you provided us with your details and positively opted in at the point of entry of your details for us to send you sector specific communications; and in each case, you have not opted out of receiving that sector specific communication. Where the communications were requested on an ‘opt in’, consent basis, you can ask us to stop sending you messages at any time by emailing us at [email protected]. Where you opt out of receiving our sector specific communications, this will not apply to personal data provided to us as a result of a service purchase, support request, monitoring report or other transactions. 3. DISCLOSURES OF YOUR PERSONAL DATA We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above: Service providers who provide IT and system administration services (Including BCC IT, Survey Monkey, Raising IT, 3EV). Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services (Including Bevan & Buckland). HM Revenue & Customs, the Charity Commission, the Fundraising Regulator, other regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances. Funders who may require data for monitoring purposes (this is usually provided on a statistical basis. If we are required to disclose personal, identifiable data, we will ask for your permission). This includes Swansea Council, WCVA (Wales Council for Voluntary Action), Big Lottery, Welsh Government, and other project / service specific funders. Via the TSSW CRM system – this is used by the 19 CVCs across Wales as well as WCVA. Its use is governed by a Memorandum of Understanding, which is fully compliant with the requirements of GDPR. A comprehensive Privacy Policy covers the TSSW partnership database, and is available here http://thirdsectorsupport.wales/privacy/ We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. 6. INTERNATIONAL TRANSFERS We do not transfer your personal data outside the European Economic Area (EEA). 7. DATA SECURITY We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality, and a memorandum of understanding governing the data use. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 8. COOKIE USAGE About cookies A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server 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 may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically 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. Cookies that we use We use cookies for the following purposes: (a) authentication - we use cookies to identify you when you visit our website and as you navigate our website (b) status - we use cookies to help us to determine if you are logged into our website (c) personalisation - we use cookies to store information about your preferences and to personalise the website for you (d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (e) analysis - we use cookies to help us to analyse the use and performance of our website and services (f) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (Please see ‘Table 1 – Cookies used by www.scvs.org.uk‘ at the end of this document for full information). Cookies used by our service providers Our service providers use cookies and those cookies may be stored on your computer when you visit our website. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy Managing cookies Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/kb/PH21411 (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website. DATA RETENTION We will only retain your personal data 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 / contractual requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: Request access to your personal data. Request correction of your personal data. Request erasure of your personal data. Object to processing of your personal data. Request restriction of processing your personal data. Request transfer of your personal data. Right to withdraw consent. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. If you wish to exercise any of the rights set out above, please email us at [email protected]. You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ Table 1 – Cookies used by www.scvs.org.uk 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 IDE, DSID, _ct_rmm Doubleclick.net These cookies are managed by DoubleClick, an advertising platform we use to display adverts. They help us identify which visitors to our website have seen or clicked one of our adverts. 2 years from set/update __cfduid CloudFlare Identify individual clients behind a shared IP address and apply security settings on a per-client basis 365 days Credit – The Cookie element of this policy was created using a template from SEQ Legal (http://www.seqlegal.com). Issue Date - 15th May 2018 Manage Cookie Preferences