CLWY Log

Privacy Policy

Who we are

Our website address is: https://clwy.org.uk.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

If you provide your name and email address for use on our “community voice” project these details will only be used for the stated purposes of contacting you relating to your comments, these will not be shared with partner organisations. However if there is a criminal or safeguarding issue identified, we may be required by law to provide all the data we have to law enforcement agencies such as the police, to aid their investigations

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Personal data such as names and email addresses collected on our forms will be retained for 3 years and then will be deleted.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.

Our Data Protection Policy:

Data Protection Policy

Introduction 

Kinda Communities CIC (The organisation Providing the website and related services) is committed to being transparent about how it collects and uses personal data, and to meeting its data protection obligations. This policy sets out the organisation’s commitment to data protection and individual rights and obligations in relation to personal data.

The organisation has appointed the Chair of Trustees as the person with responsibility for data protection compliance within the organisation. He can be contacted at info@kinda.org.uk Questions about this policy, or requests for further information, should be directed to him.

Definitions:

  • “Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
  • “Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
  • “Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.

Data protection principles

The organisation processes personal data in accordance with the following data protection principles:

  • The organisation processes personal data lawfully, fairly and in a transparent manner.
  • The organisation collects personal data only for specified, explicit and legitimate purposes.
  • The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of the processing.
  • The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
  • The organisation keeps personal data only for the period necessary for processing.#
  • The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

The organisation tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process the personal data of individuals for other reasons. Where the organisation relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

Where the organisation processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.

The organisation will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.

The organisation keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell him/her:

  •  whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual
  • for how long his/her personal data is stored (or how that period is decided);
  • his/her rights to rectification or erasure of data, or to restrict or object to processing;
  • his/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights; and
  • whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making.

The organisation will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically unless he/she agrees otherwise.

In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.

If a subject access request is manifestly unfounded or excessive, the organisation is not obliged to comply with it. Alternatively, the organisation can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the organisation has already responded. If an individual submits a request that is unfounded or excessive, the organisation will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require the organisation to:

  • rectify inaccurate data;
  • stop processing or erase data that is no longer necessary for the purposes of processing;
  • stop processing or erase data if the individual’s interests override the organisation’s legitimate grounds for processing data (where the organisation relies on its legitimate interests as a reason for processing data);
  • stop processing or erase data if processing is unlawful; and
  • stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the organisation’s legitimate grounds for processing data.

To ask the organisation to take any of these steps, the individual should send the request to info@kinda.org.uk

Data security 

The organisation takes the security of personal data seriously. The organisation has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. Where the organisation engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Impact assessments

Some of the processing that the organisation carries out may result in risks to privacy. Where processing would result in a high risk to an individual’s rights and freedoms, the organisation will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data breaches

If the organisation discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information commissioner within 72 hours of discovery. The organisation will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

International data transfers

The organisation will not transfer personal data to countries outside the EEA.

Individual Responsibilities

Individuals are responsible for helping the organisation keep their personal data up to date. Individuals should let the organisation know if data provided to the organisation changes, for example, if an individual moves house or changes his/her bank details.

Individuals who have access to personal data are required:

  • to access only data that they have authority to access and only for authorised purposes;
  • not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;
  • to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
  • not to remove personal data, or devices containing or that can be used to access personal data, from the organisation’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
  • not to store personal data on local drives or on personal devices that are used for work purposes; and
  • to report data breaches of which they become aware to [name of individual/the data protection officer] immediately.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

Training

The organisation will provide training to all individuals about their data protection responsibilities as part of the induction process and at regular intervals thereafter.

Law relating to this document 

  • General Data Protection Regulation (2016/679 EU)
  • Data Protection Bill