GCPS Consulting is committed to protecting your personal data. Respect for your privacy is central to our ethical business commitments. Please read this policy carefully to understand how we collect, use and store your personal data.
WHO ARE WE?
The processing of personal data is carried out by or on behalf of Global Child Protection Services Ltd. (trading as GCPS Consulting). GCPS Fund is a registered company in England and Wales (6580763).
HOW CAN YOU CONTACT US?
Support Services Director
175 Rustlings Road
Sheffield S11 7AD
+44 (0)789 1135 143
By using our website, our social media pages (such as Facebook and Twitter), subscribing to our services, you agree that, unless you have set your computer’s browser to reject them, we can place the types of cookies set out below on your device and use that data in accordance with this policy.
HOW DO WE COLLECT YOUR INFORMATION?
We may collect information about you directly whenever you interact with us. For example, when you contact GCPS regarding our activities, register as a follower, send or receive information, or engage with our social media, you may provide us with your personal information.
WHAT INFORMATION DO WE COLLECT?
The information we collect from you directly or from third parties with whom we work, may include:
• email address,
• telephone number,
• contact preferences,
• date of birth or age to confirm you are over 18,
DO WE PROCESS ‘SENSITIVE’ PERSONAL INFORMATION?
Under data protection law, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs, and political opinions (‘sensitive personal data’). We may collect sensitive personal data about you but only if there is a clear reason for doing so, such as where we need this information to ensure that we provide appropriate support or services to you or where this is necessary for the conduct of our services.
HOW DO WE USE YOUR INFORMATION?
We may use your information in a number of ways, including:
• To provide you with information, products or services that you have requested from us or that we feel may be of interest to you;
• To provide you with information about our work or our activities;
• To invite you to participate in interactive features on our website;
• For administrative purposes (for example, we may contact you regarding an enquiry you may have made to us);
• For internal record keeping relating to any services, feedback, or complaints;
• To invite you to participate in voluntary surveys or research;
• To contact you where you have been identified as a contact person for an organisation (if we obtain your contact details in this way, we will only use them to contact you in your capacity as a representative of that organisation);
• To analyse and improve the content and operation of our website;
• To analyse and improve our internal business processes; and
• Where we are required by law to disclose or otherwise use your information.
If you have provided us with your postal address or telephone number, we may send you information about our work or other communications by email or contact you by telephone unless you have told us that you would prefer not to hear from us in this way. We provide information about how you can change your contact preferences below.
HOW WILL WE COMBINE AND ANALYSE THE INFORMATION WE COLLECT ABOUT YOU?
We do not combine and analyse information we may have about you. Any details we have are purely for the purpose of maintaining contact with you and providing services in the way described above.
HOW WILL WE DISCLOSE THE INFORMATION WE HAVE COLLECTED TO OUTSIDE PARTIES?
GCPS may provide your information to our service providers. Subject to your communication preferences and our internal policies and procedures, this would include providing your information to third parties that work with us to deliver our services, e.g. sub contractors.
We enter into contracts with all of these service providers that require them to comply with data protection laws and to ensure that they have appropriate controls in place to protect the security of your information.
We will never sell your details. We will only share your details with third parties who are service providers working at our direction as indicated in this Policy or if you have consented or we have another legal basis to do so.
We may disclose your personal information if we are requested or required to do so by a regulator or law enforcement or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect GCPS, for example in cases of suspected fraud or defamation, or in order to comply with any other applicable legal obligation.
HOW DO WE PROTECT YOUR 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.
Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk.
For financial and technical reasons, we may, on occasion, need to use the services of a service provider outside the European Economic Area (EEA) – this may include a country which does not have the same level of data protection as in the United Kingdom.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will keep and delete your information according to our internal policies and will keep it no longer than reasonably necessary for the purposes for which we hold it, taking into account relevant legal and regulatory retention requirements (e.g. tax or health and safety requirements) and operational considerations.
HOW CAN YOU CHANGE YOUR MARKETING PREFERENCES OR UPDATE THE INFORMATION WE HOLD ABOUT YOU?
If you do not wish us to use your personal data for marketing purposes as outlined above, you can use the link on any marketing email to change your preferences.
You can also change any of your marketing preferences at any time (including telling us that you don’t want us to contact you for marketing purposes) by:
• Indicating that you do not wish to receive our marketing emails by clicking the ‘unsubscribe’ link in at the end of our marketing emails;
• Contacting us by email at firstname.lastname@example.org, or by telephone at 07940 706322, or by writing to us at:
Support Services Director
If you have indicated that you do not wish to be contacted for marketing purposes, we will delete your details.
Similarly, if your contact details have changed or you think any information we have about you is incorrect or incomplete, you can always update or correct the information we hold about you by contacting us as explained above.
WHAT OTHER DATA PROTECTION RIGHTS DO YOU HAVE?
Under UK data protection law, you have certain rights over personal information that we hold about you. These rights are summarised below. Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances.
You can assert your rights, raise a concern, or make a complaint about how we process your personal data by contacting our Data Protection Officer or our Supporter Care team. It will assist us, if you explain your request or concern and describe the personal information you are referencing as specifically as possible. In order to action your request, we may need to request further information or request that you provide proof of identity.
Your rights in relation to our processing of your personal information, include:
• Right to object to the processing of your data – you have the right to object to our processing of your personal data in certain circumstances. If you object, please explain your objection and the reason for it. If you are objecting to the processing of your data for direct marketing purposes, you can tell us in any of the ways described in the section ‘How can you change your marketing preferences or update the information we hold about you?’ above and we will stop processing your data for those purposes as soon as reasonably possible.
• Right to have inaccurate or incomplete personal information corrected or completed – if you believe our records of your personal information are inaccurate or incomplete, you have the right to ask us to correct or complete those records. You can do this as described in this section or in the section ‘How can you change your marketing preferences or update the information we hold about you?’ above.
• Right to restrict processing – in certain circumstances, you have the right to ask us to stop making active use of the personal information that we retain in our records about you, if there is disagreement about its accuracy or legitimate usage.
• Right of erasure – in certain circumstances, you have the right to request that we delete your personal information from our records.
• Right of access – you can write to us to ask for confirmation of what information we hold relating to you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exceptions that apply.
• Right to receive your personal information in a portable format – in limited circumstances, where we are processing information you provided to us because you gave us your consent or because it is necessary for the performance of a contract and the processing is carried out by automated means, you may ask us to provide it to you in a portable format.
If you are not happy with how we have handled your request or complaint, you can contact the Office of the Information Commissioner, which oversees the protection of personal data in the UK.
Alternatively, you may choose to contact the Information Commissioner directly about your complaint, regardless of whether you have raised it with us first.
WHY ARE WE ALLOWED TO PROCESS YOUR PERSONAL INFORMATION?
Our Privacy and Cookie Policies take into account several laws, including:
• the Data Protection Act 2018
• the Privacy and Electronic Communications (EC Directive) Regulations 2003
• General Data Protection Regulation (EU) 2016/679
Generally, our processing of your personal information as described in this policy is allowed by these laws based on one or more lawful grounds, including:
• Where you have provided your consent to us using your personal information in a certain way. For example, we only use your information to send you marketing communications by email or text with your consent. We also may ask for your explicit consent if you share sensitive personal information with us.
• Where the processing is reasonably necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract. For example, we may rely on this basis where you apply to work for us.
• Where the processing is reasonably necessary to comply with a legal obligation to which we are subject. For example, we may rely on this basis where we are obliged to share your personal information with a regulator or HMRC.
• Where the processing is reasonably necessary for the purpose of a legitimate interest pursued by us or a third party and your privacy rights do not override the legitimate interest. Our “legitimate interests” include pursuing the aims of GCPS in safeguarding children and adults, through our work in the UK and globally. However, “legitimate interests” can also include your interests, such as when you have requested information from us, and those of third parties, such as our beneficiaries.
For example, we rely on legitimate interests for activities such as sending marketing communications by post or telephone unless you have told us that you would prefer not to hear from us in this way, contacting you as a representative of an organisation about partnerships or in order to organise an event, and analysing your interaction with us to improve our internal business processes.
In any event, where we are relying on legitimate interests to process your personal information, we will consider any potential impact on you (positive or negative), your rights under data protection laws, and will not use your personal information for activities where the impact on you overrides the legitimate interests in the processing.
Where we process sensitive personal data (as mentioned above), we will make sure that we only do so in accordance with one of the additional lawful grounds for processing that type of data, such as where we have your explicit consent or you have made that information manifestly public.
JOB AND VOLUNTEER APPLICANTS AND CURRENT AND FORMER EMPLOYEES
You will receive a separate Privacy Statement from us when providing information for these purposes.
We cannot be held responsible for the privacy of data collected by websites not owned or managed by GCPS, including those linked through our website.
Emails aren’t always secure, and they may be intercepted or changed after they’ve been sent. GCPS doesn’t accept liability if this happens. The contents of emails reflect their author’s views and not necessarily those of GCPS. Please do not send GCPS any financial data through email. The information in emails is confidential, so if you’ve received one by mistake, please delete it without copying, using, or telling anyone about its contents.