Boring but important
Acorns and Oaks promotes and shares information on intergenerational groups in settings for the elderly - Supported Living, Residential and Care homes.
Most groups are set up by a local Group Leader and members are recruited via word of mouth and Facebook.
Acorns and Oaks is committed to protecting the privacy, personal information and confidentiality of the children, parents, group leaders, elderly residents and staff involved, including any person who contacts our website (collectively referred to as participants in this privacy notice).
This policy sets out how we collect and use the personal information that you provide whether that is online, by email, letter, by phone or other correspondence.
We promise to keep safe any personal data you share with us, or that we get from other organisations. When we collect data from you we aim to be clear and transparent with how we use that data.
By using our website and social media platforms or providing us with any personal information we will assume you are agreeing to your information being used and disclosed in the ways described in this policy.
1. About Us
Acorns and Oaks promotes and shares information on organised and guided play sessions with children, their parents and the elderly in supported living, residential and care homes. We aim to promote learning through play for children and the therapeutic benefits of play and interaction with pre-school children for the elderly.
For the purposes of data protection legislation, Acorns and Oaks is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice makes you aware of how and why your personal data will be used, namely for the purposes of our dealings with you as a participant , and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (GDPR).
Our directors are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Our full details are:
Company name: Acorns ‘n Oaks CIC
For the attention of: The Directors
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. Data Protection Act and the GDPR
In carrying out our day to day activities we process and store personal information relating to people who contact our website, play session leaders, and staff in residential settings. We are therefore required to adhere to the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR), which came into force in the UK on 25 May 2018.
We take our responsibilities under this act very seriously. We ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.
Under the Data Protection Act 2018 and the EU General Data Protection Regulation (to come into force in May 2018), we will ensure that personal data is:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
3. What personal information do we collect?
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 may collect, use, store and transfer different kinds of personal data about you and your child/children which we have grouped together follows:
Identity Data includes first name, maiden name, last name, social media username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes home address, email address, telephone numbers.
Membership Data includes details about your membership of a group including information about the play sessions you have taken part in and photographs and videos taken in the play sessions and information about your skills, interests or experience working with children or the elderly (if you give us this information when contacting our website).
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We collect personal information about you when you register with us to receive communications, ask about our activities and events, engage with our social media or online forums, or otherwise give us personal information ).
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Membership Data to record how many members of a particular group take part in play sessions and how many participants take part in intergenerational activities overall. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
In most circumstances, we do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and biometric data). Nor do we collect any information about criminal convictions and offences.
We do not need to collect information regarding your health or fitness (which may be considered information falling within a Special Category of Personal Data) because this is not relevant to our purposes. We will only process information relating to your health or fitness at your specific request.
4. How your personal information is collected and how we may use it
How we collect your information
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Membership Data by corresponding with us by post, phone, email, social media, or otherwise. This includes personal data you provide when you:
request information about membership of an intergenerational group;
fill in a form on our website;
subscribe to our service or newsletter;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
How we may use your information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to comply with a legal or regulatory obligation.
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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience possible. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We will use the personal information we collect about you to:
Process and respond to your enquiries;
Keep records related to our activities.
We may contact you for marketing purposes by e-mail, telephone, social media or social messaging, text messaging or by mail.
We may send you communications about our company via e-mail, social media or social messaging.
The type of communications and information you receive about our company can be chosen by you. You can change your mind about your communications preferences at any time by contacting us.
5. Information sharing and disclosure
We will not sell or swap your information with any third party.
We may share your information with our data processors or trusted partner organisations, including, but not limited to, local NHS and social services departments, and professional advisers acting as processors or joint controllers including consultants, lawyers and insurers based in the United Kingdom who provide consultancy, legal and insurance services.
We may disclose your personal information to third parties if we are required to do so through a legal obligation - for example to the police or a government body; to enable us to enforce or apply our terms and conditions or rights under an agreement; or to protect us, for example, in the case of suspected fraud or defamation.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not envisage that your information will be transferred or processed outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
6. The accuracy of your information
We are committed to ensuring that all information we hold about you is accurate and, where necessary, kept up to date.
If any of the information we hold about you is inaccurate and either you advise us or we become otherwise aware, we will amend and update that information as soon as possible.
7. Storing your information
The information you provide is processed and stored securely in accordance with UK legislation. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will keep your information for as long as it is required to enable us to operate our services but we will not keep your information for any longer than is necessary. 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.
When we no longer need to retain your information we will ensure it is securely disposed of.
In some circumstances you can ask us to delete your data (see section “Request erasure” below for further information).
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Children under the age of 16
We only store and process data about children under the age of 16 years old with the consent of the parent or guardian.
9. Vulnerable circumstances policy
We understand the importance of protecting our participants who may be vulnerable and work with social services and support works to ensure that anyone using our services is in a position to make a free and informed decision.
10. Changes to the policy
This policy is correct as of July 2019.
We will regularly review and update this policy and Data Protection Statement and will update, modify, amend or remove sections at our discretion.
Any changes will be notified to you through an announcement on our website.
Your continued use of our website, our services and the continued provision of personal information after we have posted changes to these terms will be taken to mean you are in agreement with those changes.
11. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Reminder – how to contact us
Our full details are:
Company name: Acorns ‘n Oaks CIC
For the attention of: The Directors