Introduction
Kingston LGBT Forum (“we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you take part in our intergenerational letter writing project (the “Project”) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your involvement in the Project.
This Project is not intended for children and we do not knowingly collect data relation to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.
Data controller
Kingston LGBT Forum is the data controller (“Controller”) and responsible for your personal data.
We have appointed a data protection officer (“DPO”) who is responsible for answering questions in relation to this notice.
DPO contact details
If you have any questions about this notice, including any requests to exercise your legal rights, please contact our DPO by emailing charlie@kingstonlgbtforum.org.uk.
You have the right to make a complaint at any time to the Information Commissioner’s Office (the “ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to our privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on 14 December 2020.
It is important that the personal data we hold about you is accurate and current. Please tell us if your personal data changes during the project.
The data we collect about you
Personal data, or personal information, means any information about a person from which that person can be identified. It does not include data where the identity of the person has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, title and age.
- Contact Data includes postal address and email address.
- Project Information includes your explanation as to why you want to be involved in the project, how often you can commit to writing to other participants, and your hobbies and interests.
We do not 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, information about your health, and genetic and biometric data).
How we collect your personal data
We collect your personal data through our direct interactions with us. You may give us your Identity Data, Contact Data and Project Information by filling in forms or by corresponding with us by post, phone, email or otherwise.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data where it is necessary for our legitimate interests and your interests and your interests and fundamental rights do not override our interests.
Generally, we do not rely on consent as a legal basis for processing your personal data, although there may be some situations where we ask for your consent before processing your data. You have the right to withdraw consent, where given, at any time by contacting us.
Why we process your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data and what our legitimate interests are.
| Purpose or activity | Type of data | Basis of legitimate interest |
| To register you as a project participant and communicate with you | Identity Data and Contact Data | We have a legitimate interest in processing your Identity Data to discern you from other participants and your Contact Data to communicate with you to enable you to participate in the project. |
| Participant matching | Identity Data and Project Information | We have a legitimate interest in processing your Identity Data and Project information to match you appropriately and intelligently with other participants in the project. |
Change of purpose
We will only use your personal data 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. Please contact us if you would like an explanation as to how the processing for the new purpose is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose we will notify you and explain the legal basis that allows us to do so.
We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with External Third Parties for the purposes in the table above.
We require all third parties to respect the security of our 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.
International transfers
We do not transfer your personal data outside of the United Kingdom or European Economic Area (“EEA”).
Data security
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 trustees, volunteers, 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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data.
In some circumstances we will 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, which are to:
- Request access to your personal data;
- Request correction of your personal data;
- Request erasure of your personal data;
- Object to processing your personal data;
- Request restriction of processing your personal data; and
- Request transfer of your personal data.
If you wish to exercise any of these rights please contact our DPO.
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 could 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 could 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.
Glossary
Legitimate Interest means the interest of our charity in conducting and managing our activities to enable us to give you the best service and the best and most secure experience. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
External Third Parties are service providers acting as data processors, based in the United Kingdom and the EEA who provide IT, communications and system administration services.
Your legal rights
You have the right to:
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:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- 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; and
- 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.