privacy

Recording Customer Details for NHS Track and Trace

To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.


By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.


As a customer/visitor of Poulshot Village Hall you will be asked to provide some basic information and contact details.

The following information will be collected:

  • the names of all customers or visitors, or if it is a group of people, the name of one member of the group
  • a contact phone number for each customer or visitor, or for the lead member of a group of people
  • date of visit and arrival time and departure time


The venue/establishment as the data controllers for the collection of your personal data, will be responsible for compliance with data protection legislation for the period of time it holds the information. When that information is requested by the NHS Test and Trace service, the service would at this point be responsible for compliance with data protection legislation for that period of time.


The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from the venue/establishment, that it holds from loss, misuse, and unauthorised access, disclosure, alteration and destruction.


NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period. We will only share information with NHS Test and Trace if it is specifically requested by them. For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (for example, this may be all customers who visited on a particular day or time-band, or over a 2-day period).


We will require you to pre-book appointments unless you are visiting as part of another organised event or party. In these cases, your host will be legally responsible for collecting the above data and coordinating with NHS Track and Trace. Poulshot Village Hall will, in these instances, only collect the details of the host.


Under government guidance, the information we collect may include information which we would not ordinarily collect from you and which we therefore collect only for the purpose of contact tracing. Information of this type will not be used for other purposes, and NHS Test and Trace will not disclose this information to any third party unless required to do so by law (for example, as a result of receiving a court order). In addition, where the information is only collected for the purpose of contact tracing, it will be destroyed by us 21 days after the date of your visit


However, the government guidance may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you (perhaps, for example, your name, date of birth and phone number). Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to. Your information will always be stored and used in compliance with the relevant data protection legislation. The use of your information is covered by the General Data Protection Regulations Article 6 (1) (c) – a legal obligation to which we as a venue/establishment are subject to. The legal obligation to which we’re subject, means that we’re mandated by law, by a set of new regulations from the government, to co-operate with the NHS Test and Trace service, in order to help maintain a safe operating environment and to help fight any local outbreak of corona virus.


By law, you have a number of rights as a data subject, such as the right to be informed, the right to access information held about you and the right to rectification of any inaccurate data that we hold about you. You have the right to request that we erase personal data about you that we hold (although this is not an absolute right).

You have the right to request that we restrict processing of personal data about you that we hold in certain circumstances. You have the right to object to processing of personal data about you on grounds relating to your particular situation (also again this right is not absolute).


If you are unhappy or wish to complain about how your information is used, you should contact a member of staff in the first instance to resolve your issue.


If you are still not satisfied, you can complain to the Information Commissioner’s Office. Their website address is www.ico.org.uk.


We keep our privacy notice under regular review, and we will make new versions available on our privacy notice page on poulshotvh.com. This part of the privacy notice was last updated on 16 September 2020.


For your general privacy rights, please read our standard policy below.



Privacy Policy  

1. PURPOSE OF THIS NOTICE

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. ABOUT US

Poulshot Village Hall Trust (“we”, “us”, “our” and “ours”) is a UK registered Charity offering rental services of a Village Hall in Poulshot, Wiltshire. We are registered in England and Wales as a charity under number: 280765 and our registered office is at 72 The Green, Devizes, Wiltshire, SN10 1RT. For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

 Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain personal data about you, for example, when:

· you request a proposal from us in respect of the services we provide;

· you OR your employer OR our clients engages us to provide our services and also during the provision of those services;

· you contact us by email, telephone, post or social media (for example when you have a query about our services); or

· from third parties and/or publicly available resources (for example, from your employer or from Companies House).

4. THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include the following:

· your personal details (such as your name and/or address, email address, date of birth, financial details including bank details, technical information such as IP address and any other information obtained in our dealings with you);

· details of contact we have had with you in relation to the provision, or the proposed provision, of our services;

· details of any services you have received from us;

· our correspondence and communications with you;

· information about any complaints and enquiries you make to us;

· information from research, surveys, and marketing activities;

· Information we receive from other sources, such as publicly available information, information provided by your employer OR our clients.

5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary for the performance of our contract with you OR your employer OR our clients and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

· carry out our obligations arising from any agreements entered into between you OR your employer OR our clients and us (which will most usually be for the provision of our services);

· carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;

· provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;

· seek your thoughts and opinions on the services we provide; and

· notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

· the requirements of our business and the services provided;

· any statutory or legal obligations;

· the purposes for which we originally collected the personal data;

· the lawful grounds on which we based our processing;

· the types of personal data we have collected;

· the amount and categories of your personal data; and

· whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6. DATA SHARING

Why might you share my 
personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal data with other third parties, for example in the context of add-on or assistance services in the execution of our core business.

7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Where we use cloud based accounting software to maintain our financial records and cloud based storage for documentation supporting the services we undertake with you, personal data may be transferred and stored on servers in the following countries:

United States of America.

There is an adequacy decision by the European Commission in relation to these countries therefore they will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation. Where we contract these services directly with a provider outside of the EEA we will seek a Data Protection Agreement (DPA). Where we contract these services through a provider within the EEA who subsequently uses services outside of the EEA, we will rely on their due process (and will seek to ensure, where possible, they have conformed to GDPR)

Should you require further information about these protective measures, please contact us using the contact details outlined below.

8. DATA SECURITY

We have put in place commercially reasonable and 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, members, 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

· Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.

· Request correction of the personal data that we hold about you.

· 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 exercised your right to object to processing (see below).

· 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 basis. 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 data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

· Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our data protection point of contact: bookings@mypoulshot.com

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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.

10. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact: bookings@mypoulshot.com

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

11. CHANGES TO THIS NOTICE

Any changes we may make to our privacy notice in the future will be provided via an update on our website.

This privacy notice was last updated on 25th May 2018.

12. CONTACT US

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact at: bookings@mypoulshot.com or telephone our office on 01380 828206

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' , which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We use a tool which is based on the Snowplow Analytics  technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.

Use of script libraries (Google Web Fonts)

In order to present our contents correctly and make them graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts ( https://www.google.com/webfonts ) on this website. Google Web Fonts are transferred to your browser's cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font. 
  • Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible – but currently also unclear whether and, if so, for what purposes – that operators of corresponding libraries collect data.

  • The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy .

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at bookings@mypoulshot.com
Share by: