Praxis Community Projects Data Protection and Privacy Policy

Introduction

This policy describes:

What personal information we collect about you
How we obtain your personal information
How we use your personal information
On what basis we use your personal information
How long we keep your personal information
Who we share your personal information with
How we protect your personal information
Which countries we transfer your personal information to
Your rights regarding your personal information

The Appendix (Extract from staff handbook) sets out an extract from the Praxis Community Projects staff handbook regarding the protection of confidential information (including personal information).

Personal information which we collect and process

We may collect personal information from you in the course of our business, including when you engage our services (such as requesting we provide advice to you, or assist you with housing, or allow you to participate in one of our community groups), as a result of your relationship with one or more of our staff and clients, or through our website or other marketing activities.

The personal information that we may collect and process includes:

Basic information, such as your name and your relationship to other people (for example members of your family)
Sensitive information, such as information regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership
Contact information (for example your email address)
Financial information (for example details of the benefits you receive)
Any other information relating to you which you may provide to us

We understand that additional care may be needed when we collect and process the personal information of vulnerable people. In recognition of this, we observe good practice guideline in our interactions with vulnerable people.

How we obtain your personal information

We collect information from you and members of your family

We collect information from other entities (for example the Home Office and other UK government agencies and entities, other charities, and overseas government agencies)

We collect information from entities from whom you have consented to us collecting information (for example in any consent you gave us when we first agreed to provide advice to you)

Cookies

This website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Squarespace cookies

This website is built on the Squarespace platform. Squarespace may use cookies which are necessary for the proper operation of their system (such as attributing a comment on a blog post, or putting a product into your shopping cart), and to track the usage of this website in order to help us understand how the site is being used – and ultimately provide an improved user experience. You can read more about these cookies here. You can read the Squarespace privacy policy here.

By accepting the Cookie Notification message, you consent to the use of such cookies from Squarespace. If you choose not to accept the Cookie Notification message, or if you subsequently delete or block cookies, you won't have access to certain features that make your experience more efficient, and certain parts of this website may not function properly.

Google Analytics and Advertising cookies

Our website uses cookies collected through Google Analytics. We use cookies on Praxis website as follows:

To allow us to collect statistical and performance data about how the website is used. We may collect geolocation data about your geographic location, the mobile device that is used and to confirm what browser you are using, and computer operating systems that are being used. This data doesn’t contain any identifiable information about individuals. We use this data to improve the functionality of our website and ensure you have a good experience when browsing it. You can opt out from Google Analytics for the web here.
To deliver adverts that are relevant to you and your interests. For this purpose, we may also collect demographic and interest-based data. This website has implemented Google Analytics in conjunction with Google Ads. Advertising cookies are used to limit the number of times you see an advertisement, to select advertising based on what’s relevant to you and to help measure the effectiveness of the advertising campaign. They are placed by Google with our permission. You can choose whether to allow these cookies, opt-out of this feature and manage your settings for this cookie using the Ads Settings.

You can find out more about the cookies used by Google here.

We will make sure that we do not use data about individuals that is clearly intended to be private or collect information in a privacy intrusive manner that would not reasonably be expected by you.

How we use your personal information

We process and use your personal information in the provision of services by us. We use that information:

To provide our services to you and to our clients (for example to provide appropriate housing to a client of our housing service)

To promote our services (for example updates on our work and details of our events)

To send correspondence and communicate with you.

To personalise our communications (for example pre-filling forms on our website with information you have provided previously)

To monitor and improve our performance (for example by conducting internal reviews, and by providing reports on our work to our funders and other stakeholders)

To procure funding and other support (for example by preparing and submitting grant requests to various charitable foundations)

To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims

For the purposes of recruitment and employment (for example by reviewing and considering your CV if you apply for a paid or volunteer position with us and, if you work for us, in connection with your volunteering or paid employment)

To better understand those who support our work through campaigning and fundraising, and tailor communication and requests appropriately.

Advice, housing and group work

We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients. We will process identification and background information as part of our finance, administration and marketing processes. We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work, and in accordance with any consent you have given us. This processing and disclosure may include the processing and disclosure of sensitive information where reasonably required in connection with the assistance we have been asked to provide.

Marketing and other emails

We use personal information to understand whether you read the emails and other materials (for example email newsletters) that we send to you, click on the links to the information that we include in them and whether and how you visit our website after you click on that link (immediately and on future visits). If you have opted to receive email communications, we may use your email address on third party websites such as Facebook and Google to optimise our ads based on profiling of existing supporters to target and exclude where appropriate.

If you receive marketing communications from us and no longer wish to do so, you may unsubscribe at any time by selecting the link in the email or by emailing us at communications@praxis.org.uk.

Meetings, events and seminars

We will collect and process personal information about you in relation to your attendance at our offices or at an event or seminar organised by us or our partners. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organising or hosting the relevant event.

The basis on which we use your personal information

We use your personal information on the following bases:

To perform a contract (for example a licence to occupy any of the houses we provide)
For the establishment, exercise or defence of legal claims or proceedings
To comply with legal and regulatory obligations
To protect your vital interests (for example where we reasonably think that there is a risk of very serious harm to you)
In accordance with any consent you have granted
Where we have a legitimate interest in that use

How long we keep your personal information

Your personal information will be retained in accordance with our data retention policy, which categorises all of the information held by us and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.

Although the period varies as set out above, in general we retain personal information for at least seven years from the date of our last contact with a person. This period reflects guidance from the Office of the Immigration Services Commissioner.

Who we share your personal information with

We may share your personal information with any entity in accordance with any consent you have given us to do so.

We may share your personal information with certain trusted third parties including:

Our entities involved in the provision of services or advice to you (for example local councils, other charities)
Our professional advisers and auditors
Our IT service providers (for example the IT services company that provides and maintains the software for our internal database)
Third parties involved in hosting or organising events or seminars, or facilitating online fundraising or campaigning activities (such as Impact Stack)

Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.

If in the future we re-organise, merge, or transfer all or part of our business, we may need to transfer your information to new entities or to third parties through which our business will be carried out.

We use social media sites such as Facebook, LinkedIn and Twitter. If you use these services, you should review their privacy policy for more information on how they deal with your personal information.

We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior consent.

How we protect your personal information

We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.

Which countries we transfer your personal information to

In general we do not, and do not allow our service providers to, transfer your personal data outside the European Economic Area (the “EEA”). We may however transfer your personal data outside the EEA with your consent. The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.

Your rights regarding your personal information

The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for data subjects.

You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. You may also have the right to lodge a complaint in relation to our processing of your personal information with the Information Commissioner’s Office.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above or that you may not be able to make use of the services offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

If you wish to exercise any of the rights set out in this section please email admin@praxis.org.uk

Data controller

The controller of your data held by Praxis Community Projects is Praxis Community Projects.

Amendments

We may amend this policy from time to time. This version is current as at 8 January 2021.