Data Controller
The Data Controller is:
Sid Valley Memory Cafe
Twyford House
Coburg Road
Sidmouth
EX10 8NF
To enquire about any aspect of this document or your associated data protection rights please contact the Management Committee/ Trustees at sidvalleymemorycafe@gmail.com.
General
Sid Valley Memory Cafe collects and processes personal data in to carry out its activities. We wish to be transparent about how we collect and use that data and are committed to meeting our data protection obligations.
Lawful reason for processing personal data
The processing of personal data for and on behalf of volunteers, members, link organisations and clients will be carried out to achieve the objectives set out in the Constitution.
The processing of personal data in respect of all parties who take part in events organised by Sid Valley Memory Cafe will be carried out for the performance of the contractual arrangements in order to manage said events.
Sid Valley Memory Cafe acts as the Data Controller in accordance with GDPR.
Categories of personal data collected by Sid Valley Memory Cafe
We collect and process a range of information about you, the ‘data subject’. This includes (but is not limited to):
- Name of data subject
- Address
- Phone Number/s
- Email Address
- Website
- Emergency contact numbers
The information held will depend upon the nature of the data subject and purpose for which the data has been collected. We may collect this information in a variety of ways. The data subject, representatives of the data subject or authorised third parties will supply most data.
Intended recipients of the personal data
The Trustees, Co-ordinator and Volunteers of Sid Valley Memory Cafe manage certain types of personal data and key personnel have all received data privacy training and signed relevant paperwork indicating their understanding of confidentiality. Limited data as recorded in minutes of Trustee meetings, is available to members.
Where Sid Valley Memory cafe uses non-member support when running events, certain information may be shared with the third parties who will be acting on behalf of Sid Valley Memory cafe, information is limited to the detail that is deemed necessary only.
Accounting records are subject to Independent Examination and are presented for review each year.
No information other than that available through the website is released to third parties.
Legitimate interest of the Data Controller
Processing of non-member personal data for any purposes other than to complete the original task for which the data was collected is not permitted. Where events are run on a repeat basis the data will be retained to allow direct marketing for that event only.
Retention period
Sid Valley Memory Cafe intends to hold all data for a period of up to 4 years following the completion of an event unless this is superseded by the requirement to retain records for insurance purposes in which case the data will be held for 6 years.
Data collected during the day-to-day running of the Memory Cafe is expected to be held on file while the member or volunteer attends the Memory Cafe.
What if you do not provide personal data (members / clients)?
You are under no statutory or contractual obligation to provide data to the Sid Valley Memory Cafe. However, if you do not provide the information, we may not be able to complete the processes to allow your participation in an event or to benefit from the services that we offer.
What if you do not provide personal data (volunteers)?
You are under no statutory or contractual obligation to provide data to Sid Valley Memory Cafe during the period that you volunteer with us. However, if you do not provide the information, we may not be able to complete the processes as set out within the Constitution.
Storage of information
All personal data is kept in a locked cupboard at Twyford .No personal information is left on display.
Information kept on computer is password protected. Information is deleted if membership ceases.
The computer is kept in locked home premises.
Your rights as data subject
Right of access – where Sid Valley Memory Cafe is processing or has processed your personal data you have rights as an individual to get a copy of the information that we hold about you. This is known as a subject access request.
For these to be managed effectively, subject access requests must be made in accordance with the guidance issued by the Information Commissioner’s Office (www.ico.org.uk/for-the-public/). All requests should be submitted to the Trustees. Failure to submit a subject access request in this format may result in the request being rejected.
The right to rectification – you have the right to request rectification of your personal data where errors have been identified. Any such request must be made by asking or by writing by post or via email to Sid Valley Memory Cafe and a response will be issued within one month of receipt. Please note that there may be instances where such requests cannot be fully satisfied and in such cases a full explanation will be provided within the response.
The right to erasure
You have the right to request erasure (also known as ‘the right to be forgotten’) of your personal data.
Any such request must be made by asking or by writing by post or via email to the Trustees and a response will be issued within one month of receipt. Please note that there may be instances where such requests cannot be fully satisfied and in such cases a full explanation will be provided within the response.
Right to restriction of processing – you have the right to obtain from us a restriction of processing where one of the following applies:
- You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data.
- The processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead.
- We no longer need the personal data for the purposes of processing, but you require us to retain the data for the establishment, exercise or defence of legal claims.
- You have raised an objection to the processing of personal data, for a period enabling us to consider whether your rights are overridden by our legitimate reasons to retain the data.
Right to data portability – where it is practicable to do so we will provide an active secure self-service system to provide your personal data held by us. Where it is not practicable to provide an active self-service system, upon receipt of a ‘right of access request’ information held will be made available via a secure self-service system and direct access will be granted to you.
Where possible the data will be provided in a suitable electronic format that complies with the GDPR guidelines on data portability. Where this is not possible this will be explained.
Please note that the right to obtain access to personal data through a remotely accessed secure system should not adversely affect the rights and freedoms of others.
The right to object – you have the right to object to:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing (including profiling); and
- Processing for purposes of scientific/historical research and statistics.
Sid Valley Memory Cafe will adhere to the guidelines set by the Information Commissioner’s Office upon receipt of an objection. The objection can be made by asking or by writing to the Trustees.
All processing will cease upon receipt of a relevant objection. Sid Valley Memory Cafe will issue a formal response to the objection within one month of receipt.
Automated decision making and profiling
Sid Valley Memory Cafe does not perform any tasks which rely solely on automated decision making or profiling.
Complaints or queries
Sid Valley Memory Cafe aims to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice has been drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Sid Valley Memory Cafe collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address above.
If you want to make a complaint about the way we have processed your personal information, in the first instance please contact the Chair of Trustees. If they are unable to satisfactorily deal with your complaint, or you are not satisfied with our response or believe our processing of your personal data is not in accordance with the law you can complain to the Information Commissioner.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.