1. Introduction

Signposts (Luton), is committed to protecting your privacy and security. This statement explains how and why we use your personal data and to make sure you remain informed and in control of your information.

From the 24th of May 2018, anyone wanting to volunteer with Signposts, make donations, attend our events or generally support Signposts to "opt-in." This means you’ll have the choice as to whether you want to receive regular updates from us, such as the Signpost newsletter and join our update list.

You can also decide:

·       To stop receiving communications from us

·       To update information

·       To have your information removed from our systems

·       To request a summary of what information we hold on you

We are also committed to keeping you informed in the unlikely event of a data breach.

We also promise that:

·       We will not keep information for longer than ‘absolutely necessary’

·       That we hold a regular review of all data we process

·       That will we never sell your personal data

·       That we will only ever share data with organisations we work with where necessary and if its privacy and security are guaranteed

·       That we will supply you with a record of the information held on request.

You can decide not to receive communications or change how we contact you at any time.
If you wish to do so, please contact support:

- by email: info@signpostsso.org

- by letter: Data Control Officer, Signposts (Luton), 106 Old Bedford Road Luton LU2 7PD

- by phone: 01582 722629 ext. 2021 (lines open 10:30am - 4pm, Mon - Thurs)

Questions?

Any questions you have in relation to this policy or how we use your personal data should be sent to info@signpostsso.org or addressed as above.

2. About us

Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by Signposts Luton, company number 2914936 charity number 1040860 and data controller number Z9253271.

3. What information we collect

Personal data you provide

We collect data you provide to us. This includes information you give when joining or registering or communicating with us. For example:

·       personal details (name, email, address, telephone etc.) and circumstances (DBS information, medical conditions and general support needs)

·       financial information (payment information such as credit/debit card. Please see section 8 for more information on payment security)

Information from third parties

We sometimes receive personal data about individuals from third parties. For example, if we are partnering with another organisation (e.g. you provide your information to another organisation we’re collaborating with on a joint venture).

We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.

4. How we use information

We only ever use your personal data with your consent, or where it is necessary in order to:

·       enter into, or perform, a contract/service with you;

·       comply with a legal duty;

·       protect your vital interests;

·       for our own (or a third party’s) lawful interests, provided your rights don’t override these.

In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes):

Marketing

We use personal data to communicate with people, to promote Signposts services and activities. This includes keeping you up to date with our news, updates, campaigns.

For further information on this please see Section 6 (Marketing).

Administration

We use personal data for administrative purposes (i.e. to carry on our business activities). 

Internal research and analysis

We carry out research and analysis on our supporters to determine the success of campaigns and better understand behaviour and responses and identify patterns and trends.

This helps inform our approach towards understanding what can make Signposts (Luton) a more effective organisation. Understanding our supporters, their interests and what they care about also helps us provide a better experience (e.g. through more relevant communications).

5. Disclosing and sharing data

We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about our partners, or third-party products and services, but these communications will always come from Counselling Tutor and are usually incorporated into our own marketing materials (e.g. advertisements or newsletters).

Occasionally, where we partner with other organisations, we may also share information with them (for example, if you register to attend an event being jointly organised by us and another organisation). We’ll only share information when necessary and we’ll make sure to notify you first.

6. Marketing

From 24th May 2018 Signposts (Luton) will ask its supporters to “opt-in” for most communications. This includes all our marketing communications (the term marketing is broadly defined and, for instance, covers information about Signposts services and activities).

This means you’ll have the choice as to whether you want to receive these messages.

You can decide not to receive communications or change how we contact you at any time.
If you wish to do so, please contact support:

- by email: info@signpostsso.org

- by letter: Data Control Officer, Signposts (Luton), 106 Old Bedford Road Luton LU2 7PD

- by phone: 01582 722629 ext. 2021 (lines open 10:30am - 4pm, Mon - Thurs)

What does ‘marketing’ mean?

Marketing does not just mean offering things for sale, but also includes news and information about:

·       our organisation and its business activities

·       our role in educating the general public on the issues of homelessness.

·       working with us

·       Services and activities (our own, and those of third parties which may interest you)

Newsletters

The Signpost newsletter is provided as a benefit of supporters. We send these out to all our supporters (unless you specifically ask us not to) and you can choose to unsubscribe from general marketing communications.

7. Research and profiling

This section explains how and why we use personal data to build profiles which enable us to understand our supporters, improve our relationship with them, and provide a better supporter experience.

Anonymised data

We may aggregate and anonymise personal data so that it can no longer be linked to any particular person. This information can be used for a variety of purposes, such as recruiting new supporters, funding applications or to identify trends or patterns within our existing supporter base.  This information helps inform our actions and improve our campaigns, products/services and materials

8. How we protect data

We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to or use or disclosure of your personal information.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.

9. Storage

Where we store information

Signposts (Luton) operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we’ll only allow them to do if your data is adequately protected.

For example, some of our systems use Salesforce. As a US-based company, it may be that using their products result in personal data being transferred to or accessible from the US. However, we’ll allow this as we are certain personal data will still be adequately protected.

How long we store information

We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed).

We continually review what information we hold and delete what is no longer required. We never store payment card information.

10. Keeping you in control

We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:

·       the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as subject access request);

·       the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason);

·       the right to have inaccurate data rectified;

·       the right to object to your data being used for marketing or profiling; and

·       where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.

If you would like further information on your rights or wish to exercise them, please write to our Data Protection Officer at Signposts (Luton), 106 Old Bedford Road Luton LU2 7PD.

Complaints

You can complain to Signposts (Luton) directly by contacting our data protection officer using the details set out above. If wish to make a complaint (which does not directly relate to your data protection and privacy rights), you can do so in accordance with our organisation's complaints policy.

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk. 

11. Cookies and links to other sites

Cookies

Our website uses local storage (such as cookies) to provide you with the best possible experience and to allow you to make use of certain functionality.

Links to other sites

Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using the 'Contact us' link at the top of the page).

If an external website requests personal information from you (e.g. in connection with an order for goods or services), the information you provide will not be covered by Counselling Tutor's Privacy Policy. We suggest you read the privacy policy of any website before providing any personal information.

When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with Counselling Tutor.

12. Changes to this privacy policy

We’ll regularly review current legislation relating to data protection and amend this Privacy Policy to ensure it remains up-to-date and accurately reflects how and why we use your personal data. The current version of our Privacy Policy will always be posted on our website.

This Privacy Policy was last updated on the 22nd of May 2018.