INTRODUCTION
This Policy sets out the basis on which The Accessible Guide C.I.C Registered in England & Wales No 10542190 processes and shares personal data we receive.
We strive to conform with UK and European Data Protection laws and as such we comply with the provisions of the Data Protection Act 1998 (“DPA”) and GDPR guidelines 2018.
In the UK, for the purposes of the DPA, the Data Controller is The Accessible Guide C.I.C of 72 Storrington Avenue, Liverpool, L11 9AT. We will only collect, process or retain any personal information about you, where it is necessary for us to do so in order to provide our services to you.
Our privacy policies will be over ridden if we are required to do so by law, in which circumstances we will cooperate with police and government authorities in the necessary manner.
Information We Collect
If you contact us we may collect certain information including:
- Names & Address
- Company Names & Contact Person
- Email Address & Phone Number
- Credit or Debit Card details
- Bank Account Details
- Ethnic Origin*
- Disability or Health Condition*
- Personal Access Requirement
*This is “sensitive” personal data, as defined in the DPA. Please see the section on Sensitive Personal Data below for information on how we treat this data. We also collect and use information collected about you through using cookies. Please see our separate Cookies policy for information on this.
HOW WE USE PERSONAL INFORMATION
We will use your personal information in order to provide our products and services to you. Any personal information collected about you will be stored securely. We respect the principle under the DPA that personal data should not be kept longer than is necessary for the purpose for which it is kept. We therefore take measures to ensure that your personal data is destroyed or erased from our systems when it is no longer required.
We may use the information we hold about you for some or all of the following purposes:
- Provide The Accessible Guide and/or any products and services to you;
- Correspondence with you about other goods and services of The Accessible Guide that may be of interest to you
- To notify you of any changes to our products and services;
- Providing you with information for administration, health and safety, welfare and security reasons;
- Payment of costs, fees and expenses associated with any service or product purchased
- Monitoring and promoting equality of opportunities
- Marketing purposes
Third Parties
Where we engage third party contractors to perform services for us, we may need to disclose your personal information to those third party contractors in order to facilitate the provision of our services to you. Under these circumstances, we take steps in compliance with the DPA to ensure that those third party contractors who process personal data on our behalf do so in a way which safeguards the information, ensures that it is used for the purposes for which it was supplied and is processed in accordance with the DPA.
We will not disclose your personal information to any third parties unless we have your consent or we have a legal basis to do so (for example to progress our legitimate interests or to fulfil a contract we have with you) or disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
We may share information about you with the following parties:
- Our staff, agents or contractors who need your information for administrative or safeguarding purposes associated with the provision of services or products.
- Financial and payment providers to facilitate the payment of costs and fees to suppliers and the receipt of monies from customers, consumers and other third party organisations.
- Your next of kin should you be hospitalised, taken ill or for any other issue of significant concern whilst you are attending any training.
- Third parties if it is necessary to protect the vital interests of you or others;
- Third parties if we are legally required to do so (for example if you commit a criminal offence or are a witness to any commission of an offence). We may need to provide information to governmental authorities, law enforcement agencies, the police and child protection agencies and in some circumstances we may be required to disclose information relating to you in response to third party requests made to us under the DPA);
- Our insurers and legal and professional advisors.
SENSITIVE PERSONAL DATA
Some of your personal data processed by us may be classified as “sensitive” under the DPA. This includes your racial or ethnic origin, any disabilities and any associated medical conditions that you have chosen to declare to us.
We may also collect sensitive information from you in relation to any applications you submit for employment or volunteer work or for safeguarding purposes. Sensitive personal information about you may also be provided to us in some circumstances by others (for example; referees).
If you disclose sensitive personal information to us, we will use that information for the purpose(s) given to you at the time the information was collected. We will also collect and use your sensitive personal information where there is a legal basis to do so without your consent such as for protection of your or another’s vital interests or to comply with court or law enforcement orders compelling disclosure.
We May:
Use information you provide to us relating to a medical condition, disability or additional needs you may have for the purposes of evaluating what suitable support may be available to you and may be required, or whether you may be required to obtain additional insurance to participate in a programme or activity and to share this information with our staff and third parties who are directly involved in the application process or the provision of our services to you.
Use information you provide to assist in funding applications. The information would not identify and individual and would only for a generic assessment.
Other disclosures of sensitive personal data without your consent will be rare and include circumstances where it is vital to protect the interests of you or others (for example, where you or another person is perceived to be at significant risk, particularly in the case of children or adults at risk), it is necessary for the prevention of fraud or the exercise of legal rights or if we are under a legal obligation.
Security of Information
Personal information collected by us and our websites is stored in secure operating environments that are not available to the public. We will protect your personal information no matter where we process or store your data.
Trans-Border Data flows
The information that we collect from you may be transferred to, and stored at, a destination both inside and outside the European Economic Area (“EEA”), including the United States of America.
Changes to Our Policy
From time to time, it may be necessary for us to review and revise this Policy. We reserve the right to change our Policy at any time and should this occur, the amendment Policy would be available on our website.
Access to Your Information
The DPA gives you the right to access information held about you. Your right of access can be exercised in accordance with the DPA. Any access request will be subject to a fee of GBP £10 to meet our costs in providing you with details of the information we hold about you.
Status of this Policy
For some of the uses of your information described above there is a basis under the DPA for us to use the information without your consent. Where this is the case, this notice fulfils our duty to process information fairly, which includes giving you appropriate notice and explanation of the way in which your information will be used.
Where your consent is required to the use of your information, by submitting your information to us, you agree that it will be processed in accordance with the terms set out in this Privacy Policy. As explained elsewhere in the Policy, you can request access to any personal information held by us and ask for more information about the basis on which we collect and use that information by writing to our Data Protection Officer (see contact details below).
Contacting Us
If you have any questions, concerns, comments or requests regarding this Privacy Policy, or would like to update any details or information we hold about you, or wish to access the information we hold about you, please contact the Data Protection Officer at [email protected] or write to us at:
Data Protection Officer The Accessible Guide, 72 Storrington Avenue, Liverpool, L11 9AT.