Brent Mencap Privacy and Cookies Policy
Brent Mencap has been active in Brent for over 40 years, enabling Brent residents of all ages with a learning disability to live as full and independent a life as possible. We enable (PWLD) to be more in control of their lives. We focus on improving health and well being through specialist information, advice and support; social activities; user involvement and engagement opportunities, anti-discriminatory work and campaigning for equal rights and real inclusion. Brent Mencap is committed to treating you with respect and openness and operating legally. We want everyone who supports us, or who comes to us for support, to feel confident and comfortable with how any personal data you share with us will be looked after or used. This Privacy Policy sets out how we collect, use and store your personal data (this means any data that identifies or could identify you).
The Brent Mencap Privacy Policy may change so please remember to check back from time to time, this version was updated in June 2018. If we make any changes to this Privacy Policy, we will make this clear on our website or contact you about any changes .Our policy contains several sections. The law says we have to tell you all this.
1. Who we are
2. How we collect data about you
3. Data we collect and why we use it
4. Profiling: making our work more unique to you
5. Legal basis for using your data
6. Marketing
7. Sharing your Data
8. Keeping your data safe
9. How long we hold your data for
10. Your rights
11. Cookies
12. Monitoring
1. Who we are
Brent Mencap has been active in Brent for over 40 years, enabling Brent residents of all ages with a learning disability to live as full and independent a life as possible. We enable people with a learning disability to be more in control of their lives. We focus on improving health and well being through specialist information, advice and support; social activities; user involvement, engagement opportunities, anti-discriminatory work and campaigning for equal rights and real inclusion.
At Brent Mencap Privacy and Cookies Policy
Brent Mencap, we are committed to protecting your personal data and making every effort to ensure that your personal data is processed in a fair, open and transparent manner.
We are a “data controller” for the purposes of the EU General Data Protection Regulation 2016/679 (“Data Protection Law”). This means that we are responsible for, and control the processing of, your and other people’s personal data. We are registered with the Information Commissioners Office (ICO)
For further information about our privacy practices, please contact our Data Protection Officer by:
• Writing to Brent Mencap 379-381 High Road, Willesden London NW10 2JR
• Calling us on 020 84515278
• Emailing info@brentmencap.org.uk
2. How we collect data about you
We want to ensure that Brent people with a learning disability, their carers, local service providers and partners get the support, information and respect they need from us. We want to make sure you receive the communications that are most relevant to you, through using our services, visiting our website or receiving emails, post or phone calls. We want to make sure you receive the best attention when you use our services, book on an event, become a member or make a donation.
We collect data about you at the following times:
When you interact with us directly: This could be
• if you ask us about our activities,
• register with us for training or an event,
• make a donation to us,
• ask a question about learning disability or local services
• apply for a job or volunteering opportunity.
• when you phone us,
• visit our website or social media sites,
• use our services,
• come to our events,
• get in touch through the post, or in person.
• or otherwise provide us with your personal data
When you interact with us through third parties: This could be
• if you provide a donation through a third party such as Just Giving
• From one of the other third parties that we work with such as Brent Council or other local advice agencies after you provide your consent for your personal data to be shared with us.
When you visit our website or social media: This could be
• your IP address
• which pages you visit most often
• which services, events or information are of most interest to you.
Brent Mencap Privacy and Cookies Policy
• which pages you visit when you click on links in emails from us. We also use “cookies” to help our site run effectively. There are more details below – see ‘Cookies’.
From other data that is available to the public: In order to tailor our communications with you to your background and interests we may collect data about you from publicly available sources
3. The Data we collect and why we use it
Personal Data
Personal data we may collect from you includes data such as
• your name,
• date of birth,
• email address,
• postal address,
• telephone number
• credit/debit card details (if you are making a room booking e or donation),
• Other data you provide in any communications between us.
• biometric data such as photos of you.
You will have given us this data whilst making a booking, donation, registering for a service or an event, or any of the other ways to interact with us.
Special Categories of Personal Data
Brent Mencap processes “special categories of personal data” provided by you if you use any of our services or apply to work or volunteer for us
We will ask for and process additional personal data including
• Your age
• race,
• faith,
• health and/or type of disability,
• other relevant personal data
• sexuality
• information needs and communication preferences
• Criminal Convictions
We will treat all sensitive personal data with extra care and confidentiality and always in accordance with this Privacy Policy. If you do not agree to provide the relevant data, we will not be able to process your donation, sign you up for a particular activity or provide the support, goods and services you have requested.
We will mainly use this data:
• To provide the information, services or support that you have requested.
• To update you with important administrative messages and information, about your donation, an event or services or support you have requested.
Brent Mencap Privacy and Cookies Policy
• To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission,
• To keep a record of your relationship with us and use of our services for funders.
• Where you volunteer with us, to administer the volunteering arrangement.
• To process your recruitment and employment with us
• To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
• To personalise the way our website is presented when you visit
• To make improvements and to ensure we provide the best service and experience for you.
We may also use your personal data:
• To contact you about our work and how you can support Brent Mencap (see section 8 on ‘Marketing’ below for further data).
• To invite you to participate in surveys or research.
• For the purposes of dealing with your enquiry, training, and quality monitoring or evaluating the services we provide.
• In exceptional circumstances where we believe that abuse is taking place or other behaviour poses a risk to self or others.
• Where you have given us your express consent or otherwise clearly indicated to us e.g. to refer you to another service or to give your service details to a customer
4. Profiling: making our work more unique to you
We want to improve how we talk to you and the data we provide through our website, services, products and information. To do this we may sometimes use profiling and screening methods so that we can better understand our supporters, your preferences and needs to provide a better experience for you.
5. Legal basis for using your data
In most cases, we will only use your personal data where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have booked a place at an event).
However, there are other lawful reasons that allow us to process your personal data and one of those is called ‘legitimate interests’. This means for Brent Mencap can process your data to help us to achieve our vision of ensuring that Brent People of all ages with a learning disability live as independent lives as possible. Whenever we process your Personal Data under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests and will not process your personal data if we feel that there is an imbalance.
We will share personal information with companies, organisations or individuals outside of Brent Mencap if we strongly believe that access, use, storing or sharing of the information is reasonably necessary to:
• protect against harm to the rights, property or safety of Brent Mencap, the people we support or the public, as required or permitted by law.
• meet any relevant law, regulation, legal process or lawful governmental request
• put in force relevant terms of service, including investigation of potential violations
• detect, prevent or otherwise address fraud, security or technical issues
Brent Mencap Privacy and Cookies Policy
Some examples of where we have a legitimate interest to process your Personal data are
• contacting you about our work via post, email, or social media
• use your personal data for data analytics,
• conducting research to better understand who our supporters are,
• improving our services,
• for our legal purposes (for example, dealing with complaints and claims),
• for complying with guidance from the Charity Commission.
6. Marketing
We will only contact you about our work and how you can support Brent Mencap by phone, email or text message, if you have agreed for us to contact you in this manner.
However, if you have provided us with your postal address we may send you data about our work and how you can support Brent Mencap by mail unless you have told us that you would prefer not to hear from us in that way.
You can update your choices or stop us sending you these communications at any time by contacting info@brentmencap.org.uk or the link at the bottom of the relevant communication.
7. Sharing your Data
We will never sell or share your personal data with organisations so that they can contact you for any marketing activities. Nor do we sell any data about your web browsing activity.
Brent Mencap may however share your data with our trusted partners and suppliers who work with us on or on our behalf to deliver our services, but processing of this data is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it and never use it for any other purposes. Some examples of where we may share your data are
• to refer you to another organisation to help you,
• with our partners who help us to process donations and claim Gift Aid
• to process salaries or to give references
We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your data.
Brent Mencap is an independent Charity and affiliated to Royal Mencap through a membership agreement. On occasions we may share your personal data with them to ensure that they are able to provide their services effectively, when there is a reason to do so we will only share your personal data with Royal Mencap with your consent.
Legal disclosure
We may disclose your data if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements.
8. Keeping your data safe
We take looking after your data very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal data we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately the transmission of data using the internet is not completely secure. Although we do our best to protect your personal data sent to us this way, we cannot guarantee the security of data transmitted to our site.
Our websites may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or Web sites that have links on our site may collect personally identifiable data about you. This privacy statement does not cover the data practices of those websites or advertisers.
9. How long we hold your data for
We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations in line with our Records Retention policy.
If you are a person with a learning disability who has used one of our services, a family carer or a person who has received advice or support from Brent Mencap we archive your personal data 7 years after your last contact with us. This is in line with NHS and Council guidelines We may retain that data indefinitely in a secure archive. This is to protect against harm to the rights, safety or property of the people we support, the public or Brent Mencap now and in the future.
We retain personal data about staff for 7 years after they have left our employment, We may then store a summary of staff personal data in a secure archive indefinitely.
This is to protect against harm to the rights, safety or property of the people we support, the public or Brent Mencap.
10. Your rights
You have various rights in respect of the personal data we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting Brent Mencap ; by email at info@brentmencap.org.uk and by phone on 020 84515278. You can also make a complaint to the data protection supervisory authority, the Data Commissioner’s Office, https://ico.org.uk/
• Access to your personal data: You have the right to request access to a copy of the personal data that we hold about you, along with data on what personal data we use, why we use it, who we share it with, and how long we keep it for. You can make a request for access free of charge. Please make all requests for access in writing, and provide us with evidence of your identity.
• Right to object: You can object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. Please contact us as noted above, providing details of your objection.
Brent Mencap Privacy and Cookies Policy
• Consent: If you have given us your consent to use personal data (for example, for marketing), you can withdraw your consent at any time.
• Rectification: You can ask us to change or complete any inaccurate or incomplete personal data held about you.
• Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
• Portability: You can ask us to provide you or a third party with some of the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
• Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.
• No automated-decision making: We do not currently carry out any automated decision-making.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
11. Cookies
‘Cookie‘ is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or tablet when you visit a website.
They let websites recognise your device, so that the sites can work more effectively, and also gather data about how you use the site. A cookie, by itself, can’t be used to identify you.
How do we use cookies?
We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you come to our website and also allows us to improve the user experience.
The cookies we use
We use the categorisation set out here https://cookiepedia.co.uk/classify-cookies
We use all four categories of cookies:
• Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account.
• Performance cookies collect anonymous data about how you use our site, like which pages are visited most.
• Functionality cookies collect anonymous data that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
• Targeting or advertising cookies collect data about your browsing habits in order to make advertising relevant to you and your interests. As such if you visit the Brent Mencap website you may then be more likely to see adverts about Brent Mencap’s work on other websites as your browsing suggests that this is an area of interest.
No cookies, please
You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.
But, if you choose to refuse all cookies, our website may not function for you as we would like it to.
If you have any questions about how we use cookies, please contact us.
12. Monitoring
Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.
To find out more about this policy and how we look after your personal data, contact Brent Mencap by email on info@brentmencap.org.uk ringing the office on 020 8451 5278 or writing to us at 379-381 High Road, Willesden NW10 2JR