YMCA Sutton Coldfield (formerly Sutton Coldfield YMCA) is committed to complying with the EU General Data Protection Regulation, May 2018 and to collect and use personal information fairly and transparently.
As well as the information we collect and how we use this information, this policy also explains the lawful basis for processing this data and our data retention periods.
YMCA Sutton Coldfield is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
“Service User” is the person who is accessing, attending or using our services. “Service User” may also refer to the parent or guardian if the person accessing our services is under the age of 18.
Alternatively, you can contact us using the information provided below:
Name of organisation: Sutton Coldfield Young Men’s Christian Association
Address: George Williams House, Watson Close, Sutton Coldfield, B72 1LE, England
Telephone number: 0121 354 5614
Registered Charity Number: 100875
2. The information we collect, why we collect it, and the grounds for processing it
Personal data means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer (Service User) Data that includes data relating to the provision of our services to you as a service user or as the parent or guardian of a young person accessing our services. Such data includes your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. We use the following Social Media websites: Facebook, Linked In, Instagram and Twitter. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
- We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
Special Category Data (known as Sensitive Personal Data under the 1998 Data Protection Act)
Special Category Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
As a charity providing services to children and young people, we need to collect sensitive data to enable the fulfilment of our service provision or our duty of care obligations. This sensitive data is collected only in relation to our Service Users or anyone accessing our services e.g. Disability, Accommodation, Young Carers, Youth Clubs, Holiday Clubs.
This policy explains both the lawful basis for processing this data as well as the specific condition that must be specified under Article 9 of the GDPR.
We may collect the following Special Category Data:
- Medical, health and personal care information that includes important medical and GP information relating to young people in our care on programmes such as our holiday Club or youth clubs and / or health conditions and disabilities affecting Service Users and their families (where this information is required in order to fulfil the service provision). Examples include, the nature of a disability for Service Users of our Disability Services, a medical or health condition affecting a resident in our accommodation, the health condition of a Young Carer’s family member, details of a food allergy. We process this information in order to fulfil our service provision and offer the appropriate support to the individuals accessing our services. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. The specific condition for processing this data under Article 9 of the GDPR is that processing is necessary for the provision of social care.
- Ethnicity: we may ask for ethnicity in order to fulfil reports that are required by the organisation funding one of our projects or services. Our lawful ground for this processing is our legitimate interests which in this case are to fulfil the requirements of a funding organisation that has funded one of our charitable projects. The specific condition for processing this data under Article 9 of the GDPR is that processing is necessary for the provision of social care.
We require your explicit consent for processing sensitive data which you provide on submission of these details as part of an application or referral to use our services.
Criminal Offence Data
The GDPR sets out separate safeguards for personal data relating to criminal convictions and offences, or related security measures.
We may ask for information in relation to criminal convictions, offences or details of statutory supervision as part of our housing application process. Our lawful ground for this processing is our legitimate interests which in this case are to safeguard other residents. In compliance with article 10 of the GDPR, the processing of personal criminal offence data is authorised by Union or Member State Law providing for appropriate safeguards for the rights and freedoms of data subjects.
We will only use your data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com.
In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law. We do not carry out automated decision making or any type of automated profiling.
3. How we collect your personal data
We may collect data about you by you providing the data directly to us (for example by filling in a booking form, an application form or a referral form, a contact form on our website or an online booking form or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
4. Direct Marketing and Communications
Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent (YMCA Sutton Coldfield has never shared personal data in the past and have no plans to do so in the future).
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at firstname.lastname@example.org at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as bookings, applications to use our services, contracts etc.
5. Disclosure of your personal data
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services
- Professional advisors including lawyers, accountants, bankers, auditors and insurers
- Government bodies that require us to report processing activities
- Funding organisations that require us to report processing activities
- Third parties to whom we sell, transfer, or merge parts of our business or our assets
- The YMCA Sutton Coldfield Board of Trustees that require us to report processing activities
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instruction and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. As a registered charity, under the Charities Act 2011, we are required to retain this information for at least 6 years.
For accounting purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights here.
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10. Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.