Warwickshire Vision Support (WVS) is the operating name of Warwickshire Association for the Blind, a charity supporting adults with sight loss in Warwickshire.
We are a registered charity (1123220) and a company limited by guarantee (6511954). Our registered office is 5 Charles Court, Budbrooke Road, Warwick, CV34 5LZ
We are the “controller” for any personal data processed as set out in this Privacy Notice.
Our data protection practices are regulated by a supervisory authority. The UK Supervisory Authority under the General Data Protection Regulation (“GDPR”) is the Information Commissioner's Office (“ICO”). As a UK-based charity processing the personal data of individuals based in the UK, our supervisory authority is the ICO.
What information do we collect?
When you are referred to, and/or apply for a service from Warwickshire Vision Support; access any area of http://warwickshire.vision; access any member benefits; attend events organised by WVS; receive support from WVS staff or volunteers whether in person, over the phone or by email; respond to communications from our team; participate in surveys; request support from our helpline or central email; or cancel your membership; we may collect, store and use your personal information in line with this notice.
When you apply for a service, we ask for personal information relating to the applicant. We ask for the applicant’s first name, surname, address, contact number, email address and preferred method of communication. This is the minimum amount of information we need to be able to deal with a request for support.
We may also collect sensitive personal information relating to you and your circumstances if you receive a support service from us or ask us for very detailed advice. This might be information about your medical condition(s) for example. We need your consent to hold and use this information.
When an individual contacts us or receives support from a WVS staff member, we keep a record of these interactions and the content of that interaction whether by phone, email or in person. Recording this information is important to us to be able to provide good quality, continuous support and to help us monitor our outputs and outcomes.
People sometimes contact us providing personal information about a third party. We collect that information on the understanding that you have that third party’s permission to do so.
For individuals booking onto events organised by Warwickshire Vision Support we ask for the attendee’s first name, surname, contact number, email address, accessibility requirements and dietary requirements. This is the minimum information necessary needed to communicate information about the event and deliver an event in a way that is safe and accessible for an attendee.
When individuals attend events, we often take videos and photos. You will be asked if you opt in to consenting to your image being captured. We will make this clear to you at each and every event where your image may be captured. Any videos or photos may be used in Warwickshire Vision Support’s promotional literature; on our website http://warwickshire.vision; or social media through @WAB1911 Twitter; or through www.Facebook.com/Warwickshire.Vision.Support on Facebook. We will not associate any other personal data of yours including opinions or contact information alongside the video or photo unless you expressly consent to it. Wherever possible, we try not to make individuals identifiable through photos and videos.
When you apply to become a volunteer, we ask for personal information relating to the applicant. We ask for the applicant’s first name, surname, address, contact number, email address and preferred method of communication. We will also ask you for details of your emergency contact in the event of an accident. You will need to complete a DBS check – a copy of the front page of this document will be kept in our records.
We collect information from you for a variety of reasons, including:
- to respond to your enquiry
- to provide support or a service
- when you fill in a form on our website
- When you register your interest as a volunteer or supporter
- When you apply for a job with us
How do we use your information?
By becoming a member of Warwickshire Vision Support or by accessing WVS services or volunteering for us, you agree that your personal information may be collected, stored, used and shared by us, our partners, or third parties we work with, for any of the following purposes:
- to be able to provide an effective, high quality service to you and to be able to improve our service offering
- to provide you with a user-friendly browsing experience when using our website and to keep our website free from malicious attacks
- to ensure the safety, inclusion and convenience of attendees at events facilitated by WVS
- if you have provided a service to us, to be able to process your request for payment and ensure timely payment
- if you have requested support from WVS, submitted a complaint or query, to be able to address these and provide you with a timely and appropriate response and to learn from these experiences to improve our organisation’s offering to service users and volunteers
- Providing ‘signposting’ services to help meet an identified need
- Safeguarding vulnerable adults
- to send you email notifications and updates with information relevant or beneficial to you
- Supporting and managing our employees
- to send you newsletters that you have opted in to receiving;
- to provide you with information on how to renew your membership with WVS
- to put you in touch with our partners or trusted suppliers at your request
- to comply with legal and regulatory requirements such as Health and Safety incident recording for the HSE or accounting records for HMRC
- to contact you occasionally in order to invite you to share your opinions and experiences of being a WVS member or volunteer and to develop case studies for the benefit of other members
- to allow WVS to monitor and evaluate the services we provide and to support Impact and Evaluation research and reporting between WVS and Warwickshire County Council and our charitable donors
- to notify you of updates to our Privacy Notice;
- to process termination of your membership;
- to uphold any of your rights under GDPR or as part of an effort to protect your privacy.
We use the information to respond to you, to inform the future contact you have with WVS and to help us understand more about who is in touch with us and why.
We do analyse and report on data about the number and nature of contacts with the organisation. These reports do not contain information which enables you or other individuals to be identified.
We may from time to time use the experiences of our members and volunteers to explain the scope and impact of the support we provide. In these circumstances we will either anonymise any personal/identifying information or we will obtain full consent from you to use your information.
Storage of Information
Wherever possible, we aim to minimise the amount of data held as a hard copy by using electronic systems as the default option for most processes. In 2018 we will be migrating to a new database to reduce the amount of paper documents. Where it is not possible to do this or where an individual has preferred to give us their personal data through a hard copy, we keep hard copies of personal data in a locked cabinet at the WVS office. Only WVS staff have access to these records.
Where we have sought your consent, for example for us to capture your image through photos or videos, we will keep a record of this on our database along with the time, the method of consent and what you consented to. We will also keep a record of any changes or updates to your consent. We are required to do this by law as of 25 May 2018.
Personal information relating to referrals, membership, communication preferences, access requirements, interactions with our staff and events is stored on our database at the office and on secure servers based within the European Economic Area (“EEA”). Only WVS staff members have access to this database. Staff are forced by the system to change their passwords regularly and use two-factor authentication when accessing the database from a new device.
Our website is hosted on secure servers within the EEA. As it is possible that someone could access the website from outside the UK, we do not host personal information on the website in order to minimise transfer of personal data outside the EEA.
Financial information is processed internally by the WVS finance team.
If at any point we become aware of a breach of data, we will risk assess the severity of the situation. If we determine that the breach is likely to result in high risk to your rights and freedoms, we will communicate the breach to you without undue delay and report the breach to the ICO as part of our legal obligation. Any data processors that we have arrangements with will be required by contract to inform us of any breaches they become aware of that relate to your personal data, as soon as they become aware.
Legal Basis for Processing Your Information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will collect personal information from you only (i) where we have your consent to do so, (ii) where we need the personal information to deliver a service or fulfil a contract with you (iii) where the processing is in our legitimate interests and not overridden by your rights, or (iv) where we have a legal obligation to do so (2014 Care Act)
Our legal basis for holding your data on the Sight Register can be found in the Care Act 2014 and the Care and Support (Sight-Impaired and Severely Sight Impaired Adults) Regulations 2014
- Section 77(1) of the Care Act 2014 requires local authorities to establish and maintain a register of adults who are ordinarily resident in their area who are sight impaired or severely sight-impaired.
- Section 77(2) enables regulations to specify descriptions of persons who are, or are not, to be treated as being sight-impaired or severely sight-impaired for this purpose. The instrument makes provision accordingly.
If you are a WVS service user or volunteer, we may collate personal information for example recording support interactions or survey responses, under our legitimate interests, enabling us to provide an effective and continuous service to you, improve our services in future and monitor our impact.
If you have opted in to receiving any of the WVS publications and communications we will use your data to provide these communications based on your opt-in consent. You can withdraw consent at any point.
If you receive a service or enquire about our services, we use data about your access requirements including your preferred format in or order to provide an accessible service and meet our legal obligations under the Equality Act 2010.
If you are attending an event facilitated by WVS, we will use data about your dietary and access requirements to meet our legal obligations to be compliant with the Health and Safety Executive.
If you have provided a service to us, we will use your data as necessary to fulfil our contractual obligations, including to be able to process your request for payment and ensure timely payment.
Disclosure of Your Information
We may disclose your personal information to third parties if we are under a duty to disclose your information to comply with a legal obligation or to protect the safety of our property, our staff, other members or members of the public.
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
We may pass your information to our third party service providers, agents subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
On occasions we will provide personal data to external organisations who are working with us on a specific project or the delivery of specific services. If we have been asked by a local authority to provide a service for you, it is likely that we will be providing at least some of your information to them. We may also need to provide the information to a regulator such as Warwickshire County Council. This is done under strict agreements regarding the security and confidentiality of all personal data.
Other than the third parties named in the Privacy Notice or for the reasons noted at above, we will not disclose your personal information to any other third party unless we have obtained your consent first.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If you have consented to be placed on the Sight Register (managed on behalf of Warwickshire County Council) then we shall keep your records in line with Warwickshire County Council’s Social Care Retention Schedule details of which is available at https://apps.warwickshire.gov.uk/api/documents/WCCC-1073-374
Under the General Data Protection Regulation, you have the following data protection rights:
Right to be informed. We will strive to be transparent in how we collect and use personal data. This Privacy Notice sets out how we do that and is publicly available. We are happy to receive questions or comments about any information contained in this Notice.
Right of access. If we store your personal data, you have the right to make a subject access request. We are required by law to make this information available to you within a month, unless the request is complex or there are numerous requests. This information will be supplied to you electronically in a format that is accessible to you. This will be free of charge.
Right to rectification. If you become aware that we hold incorrect or incomplete information about you, you can contact us using the details at the end of this document to provide us with the correct information. We have a duty to keep up to date information and so we ask the contacts to confirm or update their information periodically.
Right to erasure (otherwise known as the ‘right to be forgotten’). If you withdraw your consent and it is our only legal basis for keeping your information, your personal information will be deleted upon your request. If we no longer have a legitimate interest for keeping your data or the reason for keeping the information at the time you provided it is no longer applicable, we will delete your information upon request. There may however be situations where it is not possible, for example where we are required to by law. In these cases we will explain to you why it is not possible to fulfil your request completely, however we will work with you to minimise any processing of that data.
Right to restrict processing. At this request, we will continue to store your data but will restrict any further processing. Decisions to restrict will be based on assessing whether legitimate grounds override individual rights or not.
Right to data portability. You have the right to request that we move your data from one IT environment to another. This would be between different organisations. Whilst we will do our best to format our information in a way that another organisation could use it without it being corrupted, we cannot guarantee that systems will be readily compatible.
Right to object. You have the right to object to any direct marketing. WVS’ direct marketing is done through email and mailers which we seek your consent for. If you withdraw consent, we will cease this marketing immediately. You also have the right to object to processing based on legitimate interests or the performance of a task in the public interest, exercise of official authority, or for purposes of scientific/historical research and statistics. At this point we will consider the weight of the legitimate need to process data again the individual’s privacy rights.
Rights regarding automated decision making and profiling. This is not applicable as WVS does not currently automate decision making nor carry out any profiling.
If you feel that we have not respected your privacy rights, you are entitled to make a complaint to the ICO. Further information on how to do this can be found on the ICO website: https://ico.org.uk/concerns/ However, before making a complaint direct to the ICO, we advise that you contact Warwickshire Vision Support first to try to resolve the matter in accordance with ICO’s guidance.
We will not contact people unless they have explicitly given consent to contact them for fundraising purposes, for example by making a donation or signing our consent form. We will act quickly on any requests to end contact, or get in touch less frequently or in a different way. If you are registered on the Telephone Preference Service we will only call you with your explicit permission. We will never sell your data.
If I am under 16, can I provide personal information to WVS?
If you are aged 16 or under, we will obtain your parent / guardian’s permission before you provide any personal information to Warwickshire Vision Support.
The only information we hold on children is those who have been certified Severely Sight Impaired or Sight Impaired and thereby qualify to be entered on the Sight Register.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
For any questions relating to this policy and our privacy practices, Please email firstname.lastname@example.org or write to us at 5 Charles Court, Budbrooke Road, Warwick CV34 5LZ. Alternatively you can call us on 01926 411331.
This policy was last reviewed on 24/05/2018