Kingston LGBT Forum (“we”, “us”, “the Forum”) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your volunteering relationship with us, in accordance with the UK General Data Protection Regulation (“UK GDPR”).
This notice applies to all volunteers, except trustees.
The Forum is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection laws to notify you of the information contained in this privacy notice.
This notice applies to current and former volunteers, but not trustees. We may update this notice at any time but if we do so, we will provide you with an updated copy as soon as reasonably practical.
It is important that you read and keep this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using that information and what your rights are under data protection laws.
Data protection principles
We will comply with data protection law, which says that the personal information we hold about you must be:
- 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; and
- Kept securely.
The kind of information we hold 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 person’s identity has been removed (anonymous data).
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health, sexual orientation or criminal convictions.
We will collect, store and use the following categories of personal information about you:
- Your name;
- Your email address;
- Your telephone or mobile number;
- Your birthday;
- Your bank account details;
- A history of your expenses claims and payments;
- Any complaints you make to us;
- Any complaints we receive about you
- Your login details for our Office 365 and Microsoft environment;
- Information about your use of our information and communications systems; and
- Photographs taken of you at our events.
How is your personal information collected?
We collect personal information about volunteers through the application and recruitment process, directly from volunteers.
We will collect additional personal information in the course of volunteering-related activities throughout the period of you volunteer with us.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests);
- Where we need to comply with a legal obligation; and
- Where it is needed in the public interest.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- Paying you out-of-pocket expenses that you have reasonably incurred as part of your volunteering with us;
- Administering your involvement in our activities;
- Managing and planning your tasks;
- Making decisions about your volunteering relationship with us;
- Gathering evidence in order to respond to complaints from you, or about you;
- Training you;
- Dealing with any legal disputes involving you or other stakeholders of the Forum, including trustees, contractors and beneficiaries; and
- Ensuring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, you may not be able to volunteer with us; we may not be able to communicate with you; or we may not be able to pay your reasonably incurred out-of-pocket expenses.
Change of purpose
We will only use your personal information 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. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
Special categories of particularly sensitive personal information, such as information about your health, racial or ethnic origin or sexual orientation, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent;
- Where we need to carry out our legal obligations;
- Where it is needed in the public interest; and
- Where it is necessary to protect you or another person from harm.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Situations in which we will use your sensitive personal information
In general, we will not process particularly sensitive personal information about you unless it is necessary in the public interest to do so. We will process your particularly sensitive personal information if we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being.
Do we need your consent?
In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This is usually where that processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
We do not envisage that we will hold information about criminal convictions.
Data sharing
We may have to share your data with third parties, including third-party service providers.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might we share your personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the volunteering relationship with you or where we have another legitimate interest in doing so.
Which third party service providers process your personal information?
Third parties includes third-party service providers (including contractors and designated agents). The following third-party service providers process personal information about you for the following purposes:
Third party | Purpose |
Krystal Hosting Limited | Data storage |
The Rocket Science Group LLC | Communicating with you |
Meetup, Inc. | To facilitate your ability to host events |
Slack Technologies Limited | To communicate with you |
Unity Trust Bank plc | To enable us to pay your reasonably incurred out-of-pocket expenses |
How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.
Transferring information outside of the UK
We will transfer the personal information we collect about you to the following countries outside the UK in order to facilitate your volunteering with us:
- Ireland
- The United States of America
There are adequacy regulations in respect of Ireland. This means that Ireland is deemed to provide an adequate level of protection for your personal information.
However, to ensure that your personal information transferred to all countries receives an adequate level of protection, we have put in place standard contractual clauses, as approved by the European Data Protection Board, to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects UK law on data protection.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, we limit access to your personal information to those trustees, volunteers, agents, contractors and other third parties who have a need to know. They will only process your personal information on our instructions.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.
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.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use that information without further notice to you. Once you stop volunteeing with the Forum, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Your rights
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the data protection officer in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
Alternatively, we may refuse to comply with the 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the data protection officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data protection officer
We have appointed a data protection officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data protection officer. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) with respect to data protection issues.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the data protection officer.