Home-Start Winchester and Districts

The leading family support charity

Privacy Policy

Home-Start Winchester & Districts General Data Protection Regulations compliance statement

About Home-Start

Home-Start is one of the leading family support charities in the UK. Home-Start volunteers help families with young children deal with the challenges they face. We support parents as they learn to cope, improve their confidence and build better lives for their children.

Information Commissioners Office (ICO) Registration

Home-Start Winchester & Districtshas registered with the Information Commissioners Office (ICO) under registration reference Z1262519.

Our Commitment

Home-Start Winchester & Districts is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We recognise our obligations in updating and expanding this program to meet the demands of the GDPR.

Home-Start Winchester & Districts is dedicated to safeguarding the personal information and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

How we are preparing for the GDPR

Home-Start Winchester & Districts already has a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018.

Our preparation includes:

Information Audit

We will regularly carry out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed. Data Protection Impact Assessments (DPIA) have helped us develop stringent procedures and assessment templates for carrying out impact. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).

Policies and procedures

We have revised our data protection policies and procedures to meet the requirements and standards of the GDPR including data protection, IT security, data retention and erasure, data breaches and third party transfers and disclosures.

Home-Start Winchester & Districts has designated Sue Barham as our Data Protection Officer and we have prompted awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

Home-Start Winchester & Districts understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans, induction and annual training program. Staff will be given annual GDPR updates as a Quality Assurance requirement.

Subject Access Request (SAR)

We have introduced SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.

Privacy Statement/Policy

We have revised our Privacy Statement(s)to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.

Data Transfer Statement

We have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. Home-Start Winchester & Districts will at times, on an anonymised basis, use personal information to demonstrate the impact of our services. Any case study information shared, will always be on an anonymised basis unless we have further explicit consent from individuals.

Home-Start Winchester & Districts may use data for specific purposes of statistical analysis and the promotion of our work nationally as well as any reporting requirements for funders who support the network on a national level.

Home-Start Winchester & Districts will share personal information with law enforcement or other authorities if required by applicable law (including, in line with our Safeguarding and Promoting the Welfare of Children/Safeguarding Adults at risks policies, where there are concerns about the safety or wellbeing of a child or adult at risk and it is considered necessary for their welfare and protection).

Home-Start Winchester & Districts will not share your personal information with any other third party without first obtaining your explicit consent.

Direct Marketing/Fundraising

We have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions. This includes a clear method for opting out and providing unsubscribe features on all subsequent marketing materials.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information on our website of from our office of an individual’s right to access any personal information that Home-Start UK processes about them and to request information about:

  • What personal data we hold about them
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from them, information about the source
  • The right to have incomplete/inaccurate data corrected or completed and the process for requesting this
  • The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
  • The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Right to be Forgotten/Subject Access Request

We have a right to erasure process. If you wish to be erased, please contact us via sue.barham@home-startwinchester.org.uk or 01962 851177 for our Subject Access Request information.

If you have any questions about our preparation for the GDPR, please contact our Data Protection Officers Carolyn Beech or Martin Tomsett Tel: 01962 851177 Email: carolyn.beech@home-startwinchester.org.uk or martin.tomsett@home-startwinchester.org.uk