This statement describes:
- what personal information we collect about you
- how we obtain your personal information
- how we use your personal information
- on what basis we use your personal information
- how long we keep your personal information
- who we share your personal information with
- how we protect your personal information
- which countries we transfer your personal information to
- your rights regarding your personal information
Personal information which we collect and process
We may collect personal information from you in the course of our business, including when you engage our services (such as requesting we provide advice to you, or assist you with housing, or invite you to participate in one of our groups), as a result of your relationship with one or more of our staff , clients or volunteers.
The personal information that we may collect and process includes:
- Basic information, such as your name and your relationship to other people (for example members of your family)
- Sensitive information, such as information regarding your ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership
- Contact information (for example your email address)
- Financial information (for example details of the benefits you receive)
- Any other information relating to you which you may provide to us
We understand that additional care may be needed when we collect and process the personal information of vulnerable people. In recognition of this, we observe good practice guideline in our interactions with vulnerable people.
How we obtain your personal information
- We collect information from you and members of your family
- We collect information from other agencies (for example the Home Office and other UK government agencies and entities, other charities, and overseas government agencies)
- We collect information from agencies from whom you have consented to us collecting information (for example in any consent you gave us when we first agreed to provide advice to you)
How we use your personal information
We process and use your personal information in order to provide you with our services.
We use your information:
To provide our services to you and to our clients (for example to provide appropriate advice to a client of our advice services)
To monitor and improve our performance (for example by conducting internal reviews)
To procure funding and other support (for example by preparing and submitting grant requests to various charitable foundations)
To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims
For the purposes of recruitment and employment (for example by reviewing and considering your CV if you apply for a paid or volunteer position with us and, if you work for us, in connection with your volunteering or paid employment)
Advice, casework and group work
We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients. We will process identification and background information as part of our finance and administration processes. We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work, and in accordance with any consent you have given us. This processing and disclosure may include the processing and disclosure of sensitive information where reasonably required in connection with the assistance we have been asked to provide.
The basis on which we use your personal information
We use your personal information on the following bases:
- For the establishment, exercise or defence of legal claims or proceedings
- To comply with legal and regulatory obligations
- To protect your vital interests (for example where we reasonably think that there is a risk of very serious harm to you)
- In accordance with any consent you have granted
- Where we have a legitimate interest in that use
How long we keep your personal information
Your personal information will be retained in accordance with our data retention policy, which categorises all of the information held by us and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.
Although the period varies as set out above, in general we retain personal information for at least seven years from the date of our last contact with a person. This period reflects guidance from the ICO and the Office of the Immigration Services Commissioner.
Who we share your personal information with
We may share your personal information with any agency in accordance with any consent you have given us to do so.
We may share your personal information with certain trusted third parties including:
- Our agencies involved in the provision of services or advice to you (for example local councils, other charities)
- Our professional advisers and auditors
- Our IT service providers (for example the IT services company that provides and maintains the software for our online database)
Where necessary, or for the reasons set out in our policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
If in the future we re-organise, merge, or transfer all or part of our business, we may need to transfer your information to new entities or to third parties through which our business will be carried out.
We do not sell, rent or otherwise make personal information commercially available to any third party.
How we protect your personal information
We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
Which countries we transfer your personal information to
In general we do not, and do not allow our service providers to, transfer your personal data outside the European Economic Area (the “EEA”). We may however transfer your personal data outside the EEA with your consent. The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.
Your rights regarding your personal information
The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for data subjects.
You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. You may also have the right to lodge a complaint in relation to our processing of your personal information with the Information Commissioner’s Office.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above or that you may not be able to make use of the services offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
The controller of your data held by SLRA is SLRA
We may amend this statement when necessary. This statement is current as of June 2018.