Data Protection

This privacy notice describes how we collect and use personal information about you during and after your working, voluntary or contract for service relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all employees, workers and contractors. 

Responsibilities 

PVCSE Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. 

This notice applies to current and former employees, workers, volunteers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. 

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. 

Privacy notice 

Our GDPR Owner and data protection representatives can be contacted directly here: 

PVCSE Trustee, 01752 395131 

PVCSE, Devonport, Guildhall, Ker Street, Plymouth, PL1 4EL 

Data protection principles 

We will comply with data protection law. This says that the personal information we hold about you must be: 

1. Used lawfully, fairly and in a transparent way. 

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 

3. Relevant to the purposes we have told you about and limited only to those purposes. 

4. Accurate and kept up to date. 

5. Kept only as long as necessary for the purposes we have told you about. 

6. Kept securely. 

Your Personal Data 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We will collect, store, and use the following categories of personal information about you: 

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email and IP addresses. 

  • Any personal and employment information included in a CV or cover letter or as part of the application process. 

  • Historic employment records (including job titles, work history, working hours, training records and professional memberships). 

  • Historic employment details (including salary and compensation history from previous employers.) 

  • Pre-employment checks applicable to the position including Right to Work documentation, References, Education and Qualification records, Credit checks, Disclosure and Barring checks, DVLA records, and any other performance, training information you provide from previous employers or clients. 

  • Interview and selection material (including but not limited to interview notes, assessment material, psychometric reports, assessment tests) 

  • Contract for Service agreements or an Recruitment decision letters and emails 

  • Procurement Information 

  • Contracts and Service level Agreements 

  • Date of birth. 

  • Gender. 

  • Next of kin and emergency contact information. 

  • National Insurance number, Bank account details, payroll records and tax status information. 

  • Salary, annual leave, pension and benefits information. 

  • Start date, Location of employment or workplace. 

  • Copy of driving licence and/or passport. 

  • Employment records (including job titles, work history, working hours, training records and professional memberships). 

  • Compensation history. 

  • Performance information. 

  • Disciplinary and grievance information. 

  • CCTV footage and other information obtained through electronic means such as swipecard records. 

  • Information about your use of our information and communications systems. 

  • Photographs. 

Special Categories 

There are “special categories” of more sensitive personal data which require a higher level of protection. We may also collect, store and use the following “special categories” of more sensitive personal information: 

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions, trade union membership. 

  • Information about your health, including any medical condition, health and sickness records. 

  • Information about criminal convictions and offences. 

Collection of data 

We collect personal information about employees and volunteers through the application and selection process directly from candidates and volunteers. We may sometimes collect additional information from third parties including former employers, the DVLA, credit reference agencies or other background check agencies, employment agencies and third-party providers of psychometric evaluation for selection purposes.  We may collect personal information about associates (contractors) from third parties to facilitate and maintain the contract for service. 

We will collect additional personal information about you in the course of job, volunteering period or during the contract for service related activities throughout the period of you engaged for us.  

How we will use information about you 

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 

  1. Where we need to fulfil the contract that we have entered into with you. 

  1. Where we need to comply with a legal obligation to perform such processing 

  1. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.  

  1. Where it is necessary to carry out our obligations under employment law. 

  1. Where it is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity. 

We may also use your personal information in the following situations, which are likely to be rare: 

  • Where we need to protect your interests (or someone else’s interests). 

  • Where it is needed in the public interest or for official purposes. 

Use of your personal information 

We need all the categories of information in the list above primarily to allow us to perform our contract [1] with you and to enable us to comply with legal obligations [2]. In some cases we may use your personal information to pursue legitimate interests [3] of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated by [number] the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.  

Making a decision about your recruitment or appointment as a volunteer, employee  or service provider. (1)(2)(3)(4)(5) 

Determining the terms on which you work for us. (1)(2)(4) 

Checking you are legally entitled to work in the UK. (2)(4) 

Paying you and, if you are an employee, deducting tax and National Insurance contributions. (1)(2)(3)(4)(5) 

Provide benefits to you and to support work related social events.  (3) 

Liaising with your pension provider NEST. (2)(3)(4) 

Administering the contract we have entered into with you. (1)(2)(3)(4)(5) 

Business management and planning, including accounting and auditing. (3)(5) 

Conducting performance reviews, managing performance and determining performance requirements. (2)(3)(5) 

Making decisions about salary reviews and compensation. (1)(2)(3)(4)(5) 

Assessing qualifications for a particular job or task, including decisions about promotions. (1)(2)(3)(5) 

Gathering evidence for possible grievance or disciplinary hearings. (2)(3)(4)(5) 

Making decisions about your continued employment or engagement as a service provider. (1)(2)(3) 

Making arrangements for the termination of our working relationship. (1)(2)(3)(4)(5) 

Education, training and development requirements. (2)(3)(4)(5) 

Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work. (2)(3)(4)(5) 

Ascertaining your fitness to work. Managing sickness absence. (2)(3)(4)(5) 

Complying with health and safety obligations. (2)(3)(4)(5) 

To prevent fraud. (2)(3)(5) 

To monitor your use of our information and communication systems to ensure compliance with our IT policies. (3)(5) 

To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. (3)(5) 

To conduct data analytics studies to review and better understand employee retention and attrition rates. (3) 

Equal opportunities monitoring. (3) 

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.  

If you fail to provide personal information 

If you fail to provide certain information when requested, we may not be able to enter into a contract or perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers). We may be prevented from allowing you to volunteer or work for us in whatever capacity. 

Change of purpose 

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Sensitive personal information  

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances: 

  • In limited circumstances, with your explicit written consent. 

  • Where we need to carry out our legal obligations and in line with our data protection policy. 

  • Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our data protection policy. 

  • Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards. 

  • Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.  

  • We may also process such information about employee / workers / volunteers / contractors or former employees/workers/volunteers/contractors in the course of legitimate business activities with the appropriate safeguards. 

Our obligations 

We will use your particularly sensitive personal information in the following ways: 

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws. 

  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits. 

  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual identity, to ensure meaningful equal opportunity monitoring and reporting.  

  • We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations. 

Consent 

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.  

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data.  

If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us. 

Information about criminal convictions 

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our General Data Protection Policy  

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.  

We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards. 

We envisage that we will hold information about criminal convictions. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so or where it is necessary for the legitimate interests pursued by data controller (or those of a third party) and your interests and fundamental rights do not override those interests.  

Where appropriate, we will collect information about criminal convictions as part of the recruitment process, as part of any changes to responsibilities and positions during employment or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways: 

Making a decision about your recruitment or appointment as a service provider or volunteer. 

Checking you are legally entitled to work in the UK. 

Making decisions about your continued employment or engagement as a service provider or volunteer. 

Making arrangements for the termination of our working, volunteering or contractual relationship. 

Complying with any Safer Recruitment obligations 

Complying with health and safety obligations. 

Where the position is exempt from the Rehabilitations of Offenders Act 

To prevent fraud. 

We are allowed to use your personal information in this way to carry out our obligations where posts involve a far greater degree of contact with children or vulnerable adults or groups such as the elderly or those experiencing mental illness or where there is significant financial responsibility as part of the employee’s responsibilities. 

Automated decision-making 

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances: 

Where we have notified you of the decision and given you 21 days to request a reconsideration. 

Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. 

In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. 

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. 

We do not envisage that you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you, however we will notify you in writing if this position changes. 

Data sharing 

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU. 

If we do, you can expect a similar degree of protection in respect of your personal information. 

Sharing personal data with third parties 

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.  

Which third-party service providers process my personal information? 

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes:  

Names of Providers 

Activities carried out 

St Luke’s HR Team 

HR Consultancy support 

Nest 

Pension Provider 

HMRC 

Tax and National Insurance purposes 

Chas Shaw 

Payroll purposes 

Charities Commission 

Registration of Organisation and those on Governing Body 

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. 

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data. 

What about other third parties? 

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law. 

Transferring information outside the EU 

On a limited, infrequent non-repetitive basis we will transfer personal information we collect about you to countries outside the EU if your role involves supporting our customers with commission of equipment and machinery, training, maintenance or breakdown support. There may not be adequacy decisions by the European Commission in respect of some of the countries. This means that some of the countries to which we transfer your data too are not deemed to provide an adequate level of protection for your personal information.  

Therefore, we will only transfer your personal details with your explicit consent after having been made aware of risks. 

We will only transfer the minimum amount of personal data required to enable your safe travel, stay and to enable you to undertake your work related to the contract at the customers premises whilst in the third-party country, or should the situation arise to, protect your vital interests whilst working in the third-party county.  

This will; include your name, passport details, mobile phone number, email details, training and qualification records. No personal bank details or financial information will be transferred.  

In addition, the transfer of personal data to a third country or an international organisation will only take place only if the transfer is not repetitive, concerns only a limited number of data subjects, is necessary for the purposes of a compelling legitimate interests pursued by the controller which does not override the interests or rights and freedoms of the employee.  

Data security 

We have put in place measures to protect the security of your information. Details of these measures are available upon request from the PVCSE Trustee. 

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.  

They will only process your personal information on our instructions and they are subject to a duty of confidentiality.  

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

Data retention 

How long will you use my information for? 

We will only retain your personal information 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.  

Details of retention periods for different aspects of your personal information are available by contacting the PVCSE Trustee. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.  

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations. 

Rights of access, correction, erasure, and restriction  

Your duty to inform us of changes 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.  

Your rights in connection with personal information 

Under certain circumstances, by law you have the right to: 

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 

  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 

  • Object to processing of your personal information 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 information for direct marketing purposes. 

  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 

  • Request the transfer of your personal information to another party.  

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the PVCSE Trustee in writing.  

No fee usually required 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. 

Right to withdraw consent 

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the PVCSE Trustee. 

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. 

Data protection officer 

We have not appointed a data protection officer (DPO) to oversee compliance with this privacy statement. 

Concerns 

If you have any questions about this privacy notice or how we handle your personal information, please contact the PVCSE Trustee. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. 

Changes to this privacy notice 

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.  

If you have any questions about this privacy notice, please contact  

PVCSE Trustee, 01752 395131 

PVCSE, Devonport, Guildhall, Ker Street, Plymouth, PL1 4EL 

Scope

PVCSE is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your time as a member or supporter of our organisation, in accordance with the General Data Protection Regulation (GDPR). It applies to all “members”  and supporters (data subjects) of our organisation.

Responsibilities

PVCSE is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to future, current and former data subjects who wish to be involved in our organisation.

This notice does not form part of any contract to provide ours services.

We may update this notice at any time. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Privacy Notice

Our GDPR Owner and data protection representatives can be contacted directly here:

PVCSE Trustee, 01752 395131

PVCSE, Devonport, Guildhall, Ker Street, Plymouth, PL1 4EL

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

Your Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, telephone numbers, and email addresses.
  • Start and end dates of any relationship or engagement with our activities or organisation
  • Documentation created and related to any activities you undertake, support or are involved with.
  • Emergency contact details
  • Records of any formal complaints
  • Photographs

Special Categories

There are “special categories” of more sensitive personal data which require a higher level of protection. We may on very limited occasions (risk assessments to support any reasonable adjustments required by members) also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions,
  • Information about your health, including any medical condition.
  • Information about criminal convictions and offences.

Collection of data

We collect personal information about data subjects to provide the services, support and advice we offer or from members and supporters who are interested in or who support and engage with our activities.

We will also use the personal details to personalise the communication and improve the experience of all data subjects involved.

We may collect additional personal information throughout the period of your time with our organisation.

Communication (Marketing)

We will also use your personal data to enable us to keep in touch about things that may be of interest to you or about up and coming events. Members and our other supporters (Data subjects) whom we contact will on every occasion be allowed to withdraw consent or update or change their details.

How we will use information about you

We will only use your personal information when the law allows us to or where it is necessary for our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those interests. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to comply with a legal obligation.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those interests.
  3. Where it is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

We may also use your personal information in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest.

Use of your personal information

We need all the categories of information in the list above to pursue legitimate interests (1) of our own or those of third parties, primarily to allow us to enter into contracts with companies, to take steps to enter into contracts or potential contracts and to administer the contracts entered into. We will also use the personal details to personalise the communication and improve the experience of all data subjects involved.

We may also need all the categories of information in the list above to enable us to comply with legal obligations [2]. The situations in which we will process your personal information are listed below. We have indicated by [number] the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.

For registration, enrolment and to administer the membership or supporter relationship during and after a member or supporters time with the organisation. (1)(2)(3)

To personalised communication during your time with the organisation (1)(2)

To communicate about our activities and events you might be interested to get involved with. (1)(2)

For general management and planning, including accounting and auditing. (1)(2)(3)

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information, we may not be able to pursue our legitimate interests, enter into relationships with you as a member or supporter or take the steps to enter into that relationship or we may be prevented from complying with our legal obligations.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis or legitimate interest which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law or our legitimate interests and where your interests and fundamental rights or freedoms do not override those interests.

Data sharing

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

If we do, you can expect a similar degree of protection in respect of your personal information.

Sharing personal data with third parties

We will share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.

All categories of third-party recipients and service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale, transfer or restructuring of the organisation. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the EU

We will only transfer the personal information we collect about you between the UK and a non-EU country for limited reasons, including if it is stored on a cloud based data storage system or in order to pursue our legitimate interests where your interests or fundamental rights and freedoms are not overridden.

Non EU countries may not have adequacy decisions by the European Commission in respect to the protection of personal data. This means that some of the countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request from the PVCSE Trustee with GDPR compliance responsibility.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal information to those employees, agents, contractors, members and supporters and any other third parties who have a genuine need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available from the PVCSE Trustee. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a member of our organisation we will retain and securely destroy your personal information in accordance with our data retention periods or applicable laws and regulations.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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 information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the PVCSE Trustee in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the PVCSE Trustee. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Where your personal data is used for communication (direct marketing) you will on every occasion be allowed to withdraw consent or update or change your details.

Concerns

If you have any questions about this privacy notice or how we handle your personal information, please contact the PVCSE Trustee. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the PVCSE Trustee.

PVCSE Trustee, 01752 395131

PVCSE, Devonport, Guildhall, Ker Street, Plymouth, PL1 4EL

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