Cavalier Centre Ltd is committed to protecting and respecting your privacy, so this policy explains when and why we collect personal information, how we use it, when and why we might share it and how we keep it secure. It also details your rights in relation to your personal information. The policy will be updated from time to time so please check this page occasionally. Should you have any questions about this policy or your rights regarding your personal information, or if you would like to update your contact preferences, please use the following contact details:
Cavalier Centre RDA Limited
The Cavalier Centre
Telephone 01952 983200
email [email protected]
Who are we?
Cavalier Centre RDA Ltd is a Registered Charity (1163030) and a Company Ltd by Guarantee (08737154) with activities based at the Cavalier Centre
How do we collect personal information?
We collect information when someone registers as a volunteer or participant, uses our website to contacts us, register for an event, register for our newsletter or make a donation. We also collect your information via email, over the phone, in person, office or at an event organised by us or somebody else. Information might be provided in digital form, verbally or in writing, and be received directly from you or from a third-party you have permitted to do so.
What personal information do we collect?
We would normally collect your title, name, address, occupation, email address, date of birth, phone numbers, emergency contact details, specific needs and access requirements or bank or card details to set up a single or regular payment.
When do we collect information
We collect information about you when you complete the Participant or Volunteer forms for us. We keep your contact details, information about your areas of interest and the donations you have made.
When making a payment on our website, your payment is collected by a third-party processor, who specialise in secure online processing of transactions. When visiting our website, we will also record your IP address, and information regarding the pages you access. We use small files known as cookies to monitor usage of our website including visitor numbers and page views.
If you visit one of our pages that includes external content (e.g. YouTube), you may be presented with cookies from these websites; you should check these third-party websites for more information about their cookies. You can disable cookies when using our website, though some of the functionality may be affected. We use Google Analytics to understand how people use our website so we can make it more effective. Google Analytics collects anonymous information about activity on our website using cookies.
We also collect information from activities and their participants including outcomes and achievements
Why do we collect personal information?
1 We only collect the minimum amount of personal information required to fulfil the purpose for which it is collected. You may decide not to provide us with your information or to request that we stop processing your information at a later date, though this may affect your ability to participate in or benefit from some of the activities undertaken by Cavalier Centre home of the Cavalier Centre RDA Ltd.
2 Personal information which we collect from you may be used in a number of ways including, but not limited to:-
• Replying to an enquiry you have made to Cavalier Centre RDA Ltd via phone, text, email or post
· Monitor and improve the services offered by the charity
· Volunteer progress, training and development
• Safeguarding and protection
• Health and safety
• Teaching and development of individuals
• Creating a record of a donation you have made or processing a regular gift
• Completing an order for something you have purchased from our online shop
• Reclaiming Gift Aid on donations from HM Revenue and Customs
• Registering you to participate in a fundraising activity
• Sending you information about the charity, our activities and our fundraising events
• Carrying out our obligations arising from any contracts entered in to by you and us
• Processing entries into a competition or raffle
• Seeking your views/comments on the services we provide or activities we undertake
• Notifying you of changes to our services, events or activities
• Sending communications to you via email promoting the work of Cavalier Centre Ltd and ways in which you can support us
• Cavalier Centre RDA Limited will only process your personal data where we have a legal basis for doing so as stipulated by current data protection and privacy legislation, namely:
• Where we have your explicit consent (see below)
• In order to comply with a legal obligation
• When performing official functions or tasks in the public interest
• If it is in your or somebody else’s vital interests
• To fulfil a contractual requirement
• When to do so is in our legitimate interests (see below)
Consent means offering you a real opportunity to state whether or not you wish to allow the processing of your personal information. When processing your information based on consent, we will ensure you are fully aware of what you are consenting to and only use your information for that purpose. You can withdraw your consent at any time using the contact details above. We have determined that processing your personal information on the basis of consent is lawful and legitimate when:
Cavalier Centre RDA Ltd may undertake data processing in pursuit of our legitimate interests, where to do so will not infringe your rights or interests as the data subject. To ensure this is correctly assessed, we undertake a balancing exercise to ensure that our processing does not adversely impact you. In the case of the following data processing activities, we have determined that the processing of your information for these purposes is lawful and legitimate:
• Sending communication to you via the post about our work and ways you can support us
• Registering you for a fundraising event in which you wish to take part
• Processing any of your information received from a third-party (e.g. JustGiving)
• Maintaining your information on our secure database to record your support
• Recording your contact details to enable collections/deliveries to the address you provide
You have the right to object to the processing of your personal information on the grounds of legitimate interests as detailed below in ‘Right to object’.
Who do we share personal information with?
Cavalier Centre RDA Ltd will not share your information with third parties for marketing purposes and will not sell or rent your information to third parties. If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your credit card details securely to our payment processing partner as part of the payment process in accordance with the Payment Card Industry Standard. Our payment processing partners are Payment Card Industry Data Security Standard (PCI DSS) compliant and do not retain your personal details. Cavalier Centre home of Cavalier Centre RDA Ltd may share your personal information with third parties outside of the European Economic Area if any of the exemptions detailed in the General Data Protection Regulation are met. In the case of data processors in the USA, only those certified under the U.S. Privacy Shield framework regarding the collection, storage, transfer, use and other processing of personal data will be utilised.
How do we protect personal information?
We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary. Any payment card, bank or direct debit details we receive on our website are passed securely to our payment processing provider according to the Payment Card Industry Security Standards, and all online financial transactions are encrypted using SSL (Secure Sockets Layer).
How long do we keep personal information?
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example the collection of Gift Aid). We will hold your personal information on our systems for as long as is necessary for the original purpose, or as long as is set out in any relevant contract you hold with us. Once you are no longer involved with the Cavalier Centre, we will securely retain your data for 3 years for adults and 3 years after a child reaches the age of 18.
What are your rights regarding your personal information?
Right to be informed
Right of access
You may obtain a copy of the personal information we hold about you by submitting your request to the contact details above. We will reply within one month of receipt of your request unless there is a compelling reason to extend this response time. We may refuse a request in certain circumstances, in which our justification will be communicated to you.
Right to rectification
You have the right to have any inaccurate personal information that we may hold for you rectified (corrected) and to request that any incomplete information be completed. You can make your request using the contact details above. If we accept that your information should be rectified, we will do so within one month. In certain circumstances, we may refuse a request if we consider the request to be unfounded or excessively repetitive.
Right to erasure
You can request that the information we hold about you be deleted by contacting us using the details above and we will respond within one month. The right to erasure applies if:
• we no longer need your information for the purpose for which we collected it
• our processing of your information is based on consent, and you withdraw that consent
• processing of your information is based on legitimate interests, and you successfully object
• you object to the use of your personal information for direct marketing purposes
• your information has been processed unlawfully
• we have a legal obligation to remove your personal information
In certain circumstances, we may refuse a request for erasure if we consider the request to be unfounded or excessively repetitive, or if any of the specific provisions of the current data protection legislation apply. If we have shared your personal information with any third parties and accept your request for erasure, we will contact them accordingly so they can erase your information as well.
Right to restrict processing
You can make a request for information we hold about you to be suppressed (in other words to be stored but not used) in the following circumstances:
• you have contested the accuracy of the information we hold, and we are investigating
• your information has been unlawfully processed but you want to restrict it, not erase it
• you want us to keep your information after we need it in support of a legal dispute
• you have objected to our processing of your information and we are investigating
You can make your request using the contact details above and we will respond within one month. In certain circumstances, we may refuse a request to restrict processing of your information if we consider the request to be unfounded or excessively repetitive.
Right to data portability
The right to data portability gives you the right to receive the personal information you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transfer it directly to another controller. This only applies to information stored electronically, provided directly by you and which we process based on your consent.
Right to object
You have the right to object to the processing of your personal data in certain circumstances. In the case of direct marketing, this is an absolute right. In other circumstances, we may continue the processing if there is a compelling reason for doing so, or if we consider the request to be unfounded or excessively repetitive. You can make your request using the contact details above and we will respond within one month.
Rights related to automated decisions and profiling
Cavalier Centre RDA Ltd does not conduct any automated decision making or automated processing/profiling.
What should you do if you have a complaint?
If you have a complaint concerning Cavalier Centre RDA Ltd processing of your personal data, you can contact us using the information above. Data Protection legislation also gives you the right to lodge a complaint with a supervisory authority. More information can be found on the Information Commissioner’s Office website at www.ico.org.uk.
There are many occasions when staff, volunteers or carers will want to take photographs of people. The intention of this policy is to set out clear guidelines which will balance the use of photography as a source of pleasure and pride with the need to safeguard clients and stakeholders of Cavalier Centre RDA and protect the rights of the individual.
This policy sets out to ensure that:
Images are only used for the purpose intended
Settings use of images is facilitated
Personal family photography is allowed where possible
Individual rights are respected, and child protection issues considered
Individuals are given the right to opt out.
The term ‘images’ refers to photographic prints or slides, digital images, videos or moving images. The images may be distributed via print, DVDs, the internet or other technologies.
The welfare and protection of our clients is paramount, and consideration should always be given to whether the use of photography will place our clients at risk. Images may be used to harm pupils, for example as a preliminary to ‘grooming’, radicalisation or by displaying them inappropriately on the internet, particularly social networking sites.
For this reason, consent is always sought when photographing clients and additional consideration given to photographing vulnerable clients, particularly Looked After Children or those known to be fleeing domestic violence. Consent must be sought from those with parental responsibility (this may include the Local Authority in the case of Looked After Children). Prior to clients joining the Cavalier Centre RDA, the individuals or carers are asked to consent to photographs being taken and images used. Where consent is not given images are not used by Cavalier Centre RDA.
As part of the rider application, the individual or parents/carers will be asked to complete a consent form indicating their agreement or objection regarding the use of images. A list of clients for whom consent has been refused will be maintained by Cavalier Centre RDA and every effort will be made by staff/volunteers not to include these pupils in photographs or video footage. The list will be updated regularly.
Storage of Images
Images taken by Staff or Volunteers should be stored on the Cavalier Centre shared drive. These will not be used other than for their original purpose, unless permission is obtained from the individual or carer.
Images should be destroyed or deleted from databases once they are no longer required for the purpose for which they were taken. Images taken for publicity and promotional purposes should be retained for a maximum of two years.
Carer and supporter Photography
In many cases, images taken at the Cavalier Centre are by carers or supporters. Everything possible will be done to ensure that this tradition continues. Carers or supporters are welcome to take images of their own children with the permission of the Centre Manager. However, care must be taken not to interfere with the smooth running of the event, breach commercial copyright laws or compromise health and safety. Parents and supporters will ensure that:
They will respect Cavalier Centre RDA’s decision to prohibit photography of certain pupils or a particular event.
Any images taken are for personal use only.
Images including children or individuals other than their own, must not be sold or put on the internet; if they are, Data Protection legislation may be contravened, and they will be asked to remove them.
They will not use any images of individuals so as to cause offence or harm.
Use of Images for Media
Any images of clients intended for use in the press should receive verbal permission for the specific use in addition to the written consent as detailed above. If the images are not of a client, then an image consent form must be signed.