Privacy and data processing policy
- This policy explains when and why we collect personal information about our members, staff, volunteers and therapists; how we keep it secure and your rights in relation to it.
- We may collect, use and store your personal data as described in this policy and as described when we collect data from you.
- We reserve the right to amend this policy from time to time without prior notice. You are advised to check our website harrowmscentre.co.uk or our Centre noticeboard regularly for any amendments (but amendments will not be made retrospectively).
- We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner. For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
- We can be contacted via the Centre Manager Lynn Hurst at the postal address, email address or phone number given on our contact web page.
- WHAT INFORMATION WE COLLECT AND WHY
|Type of information||Purposes||Legal basis of processing|
|The Member, staff volunteer or therapist’s name, address, telephone contact details and email address.||Managing the Harrow MS Therapy Centre. Issuing information for example newsletters, bulletins, blogs and information useful for our members from other sources, fundraising and events information. Managing staff employment, payroll, pensions, National Insurance and Income Tax. Managing therapist’s provision of services.||Performing our obligations with the Member, member of staff, volunteer or therapist. For the purposes of our legitimate interests in operating Harrow MS Therapy Centre.|
|Emergency contact details||Contacting next of kin in the event of emergency.||Protecting the Member, staff, volunteers and therapists vital interests.|
|Date of birth / age related information||Managing membership categories which are age related.||Performing Harrow MS Therapy Centre obligations with the Member.|
|Gender||Provision of adequate facilities for members, staff, volunteers and therapists.||For the purposes of our legitimate interests in making sure that we can provide sufficient and suitable facilities (including changing rooms and toilets) for each gender.|
|The Member, staff volunteer or therapist’s name and email address||Creating and managing Harrow MS Therapy Centre Membership, staff, volunteer and therapist’s database.||Consent. We will seek the Member, staff, volunteer and therapist’s consent on their application/joining forms. The Member, staff, volunteer and therapist may withdraw their consent at any time by contacting us by email or letter to tell us that they no longer wish their details to appear in the database as appropriate.|
|Bank account details of the member or other person making payment to Harrow MS Therapy Centre.||Managing the Member’s membership of the
Harrow MS Therapy Centre, the provision of services and events, donations and payments, staff payroll and payments to therapists or reimbursement of expenses to volunteers.
|Performing Harrow MS Therapy Centre obligations with the Member, staff member, volunteer and therapist.|
|Member’s name and email address||Passing to therapists in order to provide the benefits of treatments and therapies to members of Harrow MS Therapy Centre.||For the purposes of our legitimate interests in operating Harrow MS Therapy Centre and performing our obligations with members.|
|Therapist’s name, address, email addresses, phone numbers and relevant qualifications and/or experience.||Managing therapies at Harrow MS Therapy Centre.||For the purposes of our legitimate interests in ensuring that we can contact those offering therapies and provide details of therapists to members.|
|Health Data of members and staff and volunteers||Emergency treatment for members, staff and volunteers and providing therapies for members of Harrow MS Therapy Centre||Health details, used strictly and only in the event of an emergency and in connection with providing therapies for members and the welfare of members staff and volunteers|
- How we protect your personal data
- We will not transfer your personal data outside the UK without your consent.
- We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
- Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
- For any payments which we take from you online we will use a recognised online secure payment system.
- We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
- Who else has access to the information you provide us?
- We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where required to do so by law or as set out in the table above or paragraph 5.2 below.
- We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
- How long do we keep your information?
- We will hold your personal data on our systems for as long as you are a member of Harrow MS Therapy Centre and for as long afterwards as is necessary to comply with our legal obligations. e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defence of legal claims.
- We securely destroy all financial information once we have used it and are no longer required to keep it.
- Your rights
- You have rights under the GDPR: (a) to access your personal data; (b) to be provided with information about how your personal data is processed; (c) to have your personal data corrected; (d) to have your personal data erased in certain circumstances; (e) to object to or restrict how your personal data is processed; (f) to have your personal data transferred to yourself or to another business in certain circumstances.
- You have the right to take any complaints about how we process your personal data to the Information Commissioner, or call them on 0303 123 1113. Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF. For more details, please address any questions, comments and requests regarding our data processing practices to our Centre Manager Lynn Hurst.