At Southend in Sight, we take your right to privacy very seriously. Please take the time to read this Privacy Notice carefully. If you do not understand something mentioned contact our office on 01702 342131 for clarification.
- About Us
- In this Privacy Notice, references to “we”, “us” or “our” are to “Southend in Sight”. “Southend in Sight” is the Community Services Division of Southend Blind Welfare Organisation, 117 Hamlet Court Road, Westcliff on Sea, Essex SS0 7ES. Registered charity number: 1069765.
- We are the “controller” for any personal data processed as set out in this Privacy Notice.
- Our data protection practices are regulated by a supervisory authority. The UK Supervisory Authority under the General Data Protection Regulation (“GDPR”) is the Information Commissioner’s Office (“ICO”). As a UK-based charity processing the personal data of individuals based in the UK, our supervisory authority is the ICO.
2. Southend in Sight Membership
- This Privacy Notice applies to your membership with Southend in Sight including the benefits you receive as part of your membership and the consequential processes of being a new or existing member.
- Trusted suppliers or partner organisations who provide services or support to Southend in Sight members may also gather information and will have their own Data Protection Policies and Privacy Notices. They are not covered by Southend in Sight’s Privacy Notice and you should refer to the other parties’ Privacy Policies as applicable.
- Collection of Information
- When you apply for or renew membership to Southend in Sight; access any area of https://Southend in Sight.org.uk; access any member benefits; attend events organised by Southend in Sight; receive support from Southend in Sight staff whether in person, over the phone or by email; respond to communications from Southend in Sight’s team; participate in surveys; request support on the phone or by email; or cancel your membership; we may collect, store and use your personal information in line with this notice.
- For individuals booking onto events organised by Southend in Sight we ask for the attendee’s first name, surname, contact number, email address, accessibility requirements and dietary requirements. This is the minimum information necessary needed to communicate information about the event and deliver an event in a way that is safe and accessible for an attendee. If members are booking transport via Southend in Sight, name and address of the individual will be passed to a third party taxi/transport firm for the purpose of travelling to our event.
- Individuals who have agreed to receive newsletters from Southend in Sight can choose which communications they wish to receive. We also ask to confirm that they wish to be opted into our newsletter communications and ask which format they would like to receive the newsletter in.
- When an individual contacts us or receives support from a Southend in Sight staff member, we may keep a record of these interactions and the content of that interaction whether by phone, email or in person. This may contain information relating to individuals. Recording this information is important to us to be able to provide good quality support and measure our outputs and outcomes.
- When individuals attend events, we often take videos and photos. At each event, you will be asked if you opt in to consenting to your image being captured. For certain events we will make this clear to you at the point of booking. If individuals have photos taken regularly at our Centre or social activities, they will be asked to sign a photo consent form which allows the impage to be used in print and or social media. All members have the right to request their photo be withdrawn at any time.
- Use of Your Information
By signing your organisation up to become a member of Southend in Sight you agree that your personal information may be collected, stored, used for any of the following purposes:
- to be able to provide an effective, high quality service to you
- to provide you with a user-friendly browsing experience when using https://Southend in Sight.org.uk and to keep our website free from malicious attacks;
- to ensure the safety, inclusion and convenience of attendees at events facilitated by Southend in Sight;
- if you have paid to take part in an event, to be able to process this payment;
- if you have provided a service to us, to be able to process your request for payment and ensure timely payment;
- if you have requested support from Southend in Sight, submitted a complaint or query, to be able to address these and provide you with a timely and appropriate response and to learn from these experiences to improve our organisation’s offering to members;
- to send you notifications and updates with information relevant or beneficial to you or events that you have signed up to;
- to send you newsletters that you have opted in to receiving;
- to put you in touch with our partners or trusted suppliers at your request;
- to comply with legal and regulatory requirements such as Health and Safety incident recording for the HSE or accounting records for HMRC;
- to contact you occasionally in order to invite you to share your opinions and experiences of being a Southend in Sight member and to develop case studies for the benefit of other members;
- to allow Southend in Sight to monitor and evaluate the services we provide and to support our monitoring processes.
- to notify you of updates to our Privacy Notice;
- to process termination of your membership;
- to uphold any of your rights under GDPR or as part of an effort to protect your privacy.
- Storage of Information
5.1 Wherever possible, we aim to minimise the amount of data held as a hard copy by using electronic systems as the default option for most processes. Where it is not possible to do this or where an individual has preferred to give us their personal data through a hard copy, we keep hard copies of personal data in a locked office at Southend in Sight, 117 Hamlet Court Road, Westcliff on Sea, Essex SS0 7ES where Southend in Sight is registered to. Only Southend in Sight staff and authorised admin volunteers have access to these records.
5.2 Where we have sought your consent, for example for us to send you newsletters, we will keep a record of this on our SalesForce database along with the time, the method of consent and what you consented to. We will also keep a record of any changes or updates to your consent. We are required to do this by law as of 25 May 2018.
5.3 Personal information relating to membership, communication preferences, access requirements, interactions with our members and events is stored on our SalesForce database on secure SalesForce servers based within the European Economic Area (“EEA”). Only Southend in Sight staff members have access to this database. Staff are forced by the system to change their passwords regularly and use two-factor authentication when accessing the database from a new device.
5.6 Occasionally we will store records such as grant contracts which may contain personal data on our shared drive. This shared drive is on Google Suite. We use a combination of password protection and folder permissions to restrict access to the folders where this information is stored. Only staff have access to Google Suite shared drive.
5.7 Financial information is processed by Southend in Sight. Any personal information relating to finances is stored on Google Suite and is password protected with permissions to restrict access. Only the Finance Officer and CEO have access. Hard copies of financial data is kept in a locked office at Southed in Sight, 117 Hamlet Court Road. All computer support across Google Suite is managed by
Cloud Support Limited. Registered in England and Wales. Company Number 7855127. VAT Registration Number 126 7320 28.
5.8 If at any point we become aware of a breach of data, we will risk assess the severity of the situation. If we determine that the breach is likely to result in high risk to your rights and freedoms, we will communicate the breach to you without undue delay and report the breach to the ICO as part of our legal obligation. Any data processors that we have arrangements with will be required by contract to inform us of any breaches they become aware of that relate to your personal data, as soon as they become aware.
- Legal Basis for Processing Your Information
- Our legal basis for collecting and using the personal information described in Section 5 will depend on the personal information concerned and the specific context in which we collect it. We will collect personal information from you only (i) where we have your consent to do so, (ii) where we need the personal information to perform a contract with you (iii) where the processing is in our legitimate interests and not overridden by your rights, or (iv) where we have a legal obligation to do so.
- If you have provided a service to us, we will use your data as necessary to fulfil our contractual obligations, including to be able to process your request for payment and ensure timely payment.
- In order to provide services to individuals associated with your organisation as part of the Southend in Sight membership you have purchased and to ensure you have access to the full range of member benefits, we will use your data as necessary to fulfil our contractual obligations, including to deliver personalised support by email, phone and in person.
- If you have opted in to receiving any of the Southend in Sight Briefings (including Southend in Sight Fortnightly Briefings, Southend in Sight Special Briefings and Southend in Sight Trustee Briefings), we will use your data to provide these communications based on your opt-in consent. You can withdraw consent at any point. You will not be eligible to receive these communications if you are not associated with an existing Southend in Sight member.
- If you are associated with a Southend in Sight member or are enquiring about membership, we use data about your access requirements including your preferred format in or order to provide an accessible service and meet our legal obligations under the Equality Act 2010.
- If you are attending an event facilitated by Southend in Sight, we will use data about your dietary and access requirements to meet our legal obligations to be compliant with the Health and Safety Executive.
- If you are associated with a Southend in Sight member organisation, we may collate personal information for example recording support interactions or survey responses, under our legitimate interests, enabling us to provide an effective and continuous service to you, improve our services in future and monitor our impact.
- If you are associated with a Southend in Sight member organisation and then leave that organisation, we may still keep your personal information for up to three years after you have left under our legitimate interests. We wish to provide a quality membership experience which includes consideration of your remaining colleagues receiving a continuous service, particularly in the case of staff and trustee transitioning support. We always weigh the consideration of our legitimate interests against your privacy rights to ensure your rights are not overridden.
- Disclosure of Your Information
- We may disclose your personal information to third parties if we are under a duty to disclose your information to comply with a legal obligation or to protect the safety of our property, our staff, other members or members of the public.
- Other than the third parties named in the Privacy Notice or for the reasons noted at paragraph 7.1 above, we will not disclose your personal information to any other third party unless we have obtained your consent first.
- Data Retention
- We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
- When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- In the event of a person leaving an organisation which has Southend in Sight membership, we will delete the contact information along with access and dietary requirements for that person immediately upon being made aware of that person’s departure, or the day after their final day with that organisation if we know in advance. We will retain that person’s name, position, association with the organisation and any interactions with that person for five years to ensure continuity and quality of support to our members as our support to members includes support with staff and trustee transitioning. After five years, the information will be permanently deleted from our database.
- If an organisation ceases to become a member of Southend in Sight and therefore terminates Southend in Sight’s contract with that organisation to provide a membership service, we will delete any personal contact information relating to individual along with any access or dietary requirements. We will retain individuals’ names, positions, associations with the organisation and any interactions with those individuals relating to their time with the Southend in Sight member organisation for three years. This is to aid the continuity and quality of support if an organisation wishes to resume membership with Southend in Sight at a later date. After three years, the information will be permanently deleted from our database.
- When an organisation terminates its membership with Southend in Sight, or in the case where Southend in Sight has terminated the membership contract because the organisation has violated the ‘Member Expectations Policy’ any individuals associated with that organisation cease to have access to Southend in Sight member benefits, which includes all Southend in Sight Briefings. Anyone who has consented to receive Southend in Sight Briefings will be removed permanently from the electronic mailing list and will no longer receive these communications.
- Your Rights
Under the General Data Protection Regulation, you have the following data protection rights:
Right to be informed. We will strive to be transparent in how we collect and use personal data. This Privacy Notice sets out how we do that and is publicly available. We are happy to receive questions or comments about any information contained in this Notice.Right of access. If we store your personal data, you have the right to make a subject access request. We are required by law to make this information available to you within a month, unless the request is complex or there are numerous requests. This information will be supplied to you electronically in a format that is accessible to you. This will be free of charge.
Right to rectification. If you become aware that we hold incorrect or incomplete information about you, you can contact us using the details in Section 12 to provide us with the correct information. We have a duty to keep up to date information and so we ask the lead contacts to confirm or update their information at the point of member renewal which takes place every year.
Right to erasure (otherwise known as the ‘right to be forgotten’). If you withdraw your consent and it is our only legal basis for keeping your information, your personal information will be deleted upon your request. If we no longer have a legitimate interest for keeping your data or the reason for keeping the information at the time you provided it is no longer applicable, we will delete your information upon request. There may however be situations where it is not possible, for example where we are required to by law. In these cases we will explain to you why it is not possible to fulfil your request completely, however we will work with you to minimise any processing of that data.
Right to restrict processing. At this request, we will continue to store your data but will restrict any further processing. Decisions to restrict will be based on assessing whether legitimate grounds override individual rights or not.
Right to data portability. You have the right to request that we move your data from one IT environment to another. This would be between different organisations. Whilst we will do our best to format our information in a way that another organisation could use it without it being corrupted, we cannot guarantee that systems will be readily compatible.
Right to object. You have the right to object to any direct marketing. Southend in Sight’s direct marketing is done through our email briefings which we seek your consent for. If you withdraw consent, we will cease this marketing immediately. You also 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, or for purposes of scientific/historical research and statistics. At this point we will consider the weight of the legitimate need to process data against the individual’s privacy rights.
Rights regarding automated decision making and profiling. This is not applicable as Southend in Sight does not currently automate decision making nor carry out any profiling.
If you feel that we have not respected your privacy rights, you are entitled to make a complaint to the ICO. Further information on how to do this can be found on the ICO website: https://ico.org.uk/concerns/ However, before making a complaint direct to the ICO, we advise that you contact Southend in Sight first to try to resolve the matter in accordance with ICO’s guidance.
We strongly believe in protecting the privacy of children. We do not knowingly collect or maintain personal information from persons under 13 years of age. Any person applying for membership of Southend in Sight must be of 18 years or over in order to enter into such an arrangement. No part of the https://Southend in Sight.org.uk is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access our website. We will take appropriate steps to delete any personal information of persons less than 13 years of age.
We may update or amend this Privacy Notice from time to time, to comply with law or to meet our changing business needs or reporting requirements. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. At a minimum, any updates or amendments will be posted on https://Southend in Sight.org.uk and communicated through the Fortnightly Southend in Sight Briefing.
- Contacting Southend in Sight
If you have any questions, comments or complaints about this Privacy Notice, please contact us using the details below:
FAO: Southend in Sight Data (GDPR)
117 Hamlet Court Road
Westcliff on Sea
Essex, SS0 7ES
This Privacy Notice was last updated on 16 January 2019.
Southend in Sight is the Community Services Division of Southend Blind Welfare Organisation. Southend Blind Welfare Organisation is an independent charity providing practical support and advice to those living with visual impairment and blindness in the Southend-on-Sea area. Registered Charity No: 1069765