Home-Start Blackmore Vale
There for parents when they need us most, because childhood can't wait
Home-Start Blackmore Vale 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 Blackmore Vale has registered with the Information Commissioners Office (ICO) under registration reference Z236351X.
Our Commitment
Home-Start Blackmore Vale are 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 Blackmore Vale are dedicated to safeguarding the personal information and in delivering a data protection regime that is effective, fit for purpose and demonstrates an understanding of the Regulations. Our 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.
Information Audit
We 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. We complete Data Protection Impact Assessments (DPIA) to ensure stringent appropriate procedures are in place. 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). This is an ongoing activity aided by the Trustee Audit process
Policies and procedures
Our data protection policies and procedures meet the requirements and standards of GDPR including data protection, IT security, data retention and erasure, data breaches and third-party transfers and disclosures.
Home-Start Blackmore Vale has a designated Trustee lead for Data Protection and the Scheme Manager as our Data Protection Officer. There is consistent and ongoing awareness of GDPR across the organization to enable us to effectively assess our compliance, identify any gaps and implement new policies, procedures, and measures.
Home-Start Blackmore Vale 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)
Our SAR procedures accommodate the one-month timeframe for providing the requested information and for making this provision free of charge. Our 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
Our Privacy Statement(s) 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
Our consent mechanisms for obtaining personal data ensure that individuals understand what data they are providing and why and how we use it. We provide clear, defined ways to consent to us processing their information. Home-Start Blackmore Vale 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 Blackmore Vale 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 Blackmore Vale will share personal information with law enforcement or other authorities if required by applicable law and in line with our Safeguarding policies (where there are concerns about the safety or wellbeing of a child or adult at risk and disclosure is considered necessary for their welfare and protection).
Home-Start Blackmore Vale 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 which ensure that individuals can enforce their data protection rights, we provide easy to access information via the office, during induction etc. 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 office@homestartblackmorevale.org.uk or 01258 473038
If you have any questions about our preparation for the GDPR, please contact our Data Protection Officer, Chelsey Gowen: Tel: 01258 473038 Email: office@homestartblackmorevale.org.uk
Information Security Measures (I.T.)
Home-Start Blackmore Vale takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: –
Encryption & Data Access
Home-Start Blackmore Vale supports encryption method to protect the transition of data over both trusted and untrusted networks. Various technical security measures are also used including firewalls. The organisation obtains destruction certificates when hard drives containing personal data are destroyed.
Backups (off-site)
All information on our office computers is automatically saved to Microsoft’s secure digital cloud. Nothing is stored on the computer hard drive therefore no back up is required.
Managing vulnerabilities
Home-Start Blackmore Vale tests, discover, investigate and fix vulnerabilities and perform regular vulnerability tests.
Access control (IT)
Employees are required to sign Confidentially Statements (HR contract) upon joining Home-Start Blackmore Vale and are required to undertake annual training. Access to data is highly restricted and is governed by access rights approved by managers.
Decommissioning
When a data storage device has reached the end of its useful life, Home-Start Blackmore Vale destroys data as part of a decommissioning process. All devices are destroyed in accordance with industry-standard practices.
Compliance certifications
Third-party certifications and audits are an important component of any mature security program.
Password Policy
A password policy requires staff to change passwords regularly. There are also rules about the complexity of passwords.
Monitoring & Evaluation System Home-Start (Charitylog)
Home-Start Blackmore Vale use an internal data capture system to track outcomes based around the work local Home-Starts undertake with families they are supporting. With some personal data included Home-Start Blackmore Vale take the following measures to ensure a high level of security within the system.
Access control
Access to data within Charitylog is governed by access rights. Privileges can be configured and managed to define multi-level access rights.
Authentication
Users are authenticated through username and password which is cross checked against an SQL (Structured Query Language) table within which the data is encrypted.
Auto logout
After 60 minutes of inactivity a user is automatically logged out of Charitylog.
Layered Security
Charitylog has multi-level access procedures including an organisation access and personal access. (2-level username and password protection process)
Password
Complexity rules are issued and validated – users MUST use 8-15 characters, at least one uppercase and one lowercase letter of the alphabet and one numerical digit.
Lockouts
Failed authentication lock-outs are embedded. After 3 failed attempts the system administrator will be alerted to unlock the account. After 3 failed attempts users are locked out of Charitylog for 30 minutes after which the system re-sets.
Forgotten username or password
Home-Start Blackmore Vale has configurable built-in support to enable local administrators to enable and reset sub-user credentials and give limited access and exclusion to local staff and Trustees. Administrators can control number of users but administrator rights are maintained and secured by Home-Start UK.
3rd Party Usage
All data collected by Charitylog is consented to an anonymization process in order for 3rd party statistical analysis. 3rd parties are mandated to provide their own signed GDPR compliance statements and privacy policies.
Development
The Charitylog system undergoes 3 major updates a year for development and maintenance. This is done remotely, and users are notified of all updates. The system update schedule can be viewed through the online manual available on the system.
Implementation
On completion of testing, users are informed of planned system maintenance and scheduled release dates which are issued to them via Home-Start UK’s intranet.
FUNDRAISING & WEBSITE
The full Home-Start Blackmore Vale Privacy Statement on our website:
https://homestartblackmorevale.org.uk/privacy/
We are committed to safeguarding the privacy of our website visitors. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
Payments
Home-Start Blackmore Vale will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
Financial Donations
All Home-Start’s website financial transactions are handled through our payment services provider page. You can review the provider’s privacy policy at CAF Donate online at https://cafdonate.cafonline.org/18542#!/DonationDetails
Direct Debits
Direct Debits are handled through Home-Start Blackmore Vale. You can review the provider’s privacy policy at CAF Bank on line.
Disclosing personal information
Home-Start Blackmore Vale may disclose your personal information to any of our employees insofar as reasonably necessary to the extent that we are required to do so by law, in connection with any ongoing or prospective legal proceedings, in order to establish, exercise or defend our legal rights.
Retention
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes to the extent that we are required to do so by law.
Cookies
Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website. We use both session and persistent cookies on our website and Google Analytics to analyse the use of our website which generates statistical and other information about website use by means of cookies.
HUMAN RESOURCES
HR records
Records are held in line with the Data Protection policy and retention schedule.
Office Security
The Home-Start Blackmore Vale office is secured by a locked office within a secure building and hold minimum paper files in locked filing cabinets.
Access
All staff have keys to the building and there is a designated open up and lock up procedure.
Office Maintenance
The offices are managed by Stour Management and cannot access without permission.
Employment
Employee files and the data within are kept in lockable cabinets at the Home-Start Blackmore Vale offices at Office 2, The Exchange, Old Market Hill, Sturminster Newton, DT10 1FH. They can only be accessed by the designated keyholders. And on our Charitylog Data System.
Right to be Forgotten/Subject Access Request
We have a right to erasure process. If you wish to be erased, or to withdraw processing consent, or delete/correct info then please contact please contact Home-Start Blackmore Vale via office@homestartblackmorevale.org.uk or 01258 473038 for our Subject Access Request information.
Breach Notification
We have a notification process in place for any breach. For further details on this, please contact Home-Start Blackmore Vale via office@homestartblackmorevale.org.uk or 01258 473038 for our breach information and procedures.