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Privacy Policy
Last Updated: June 2023
Who are Smart Works?
Smart Works is a dynamic and fast-growing UK charity that dresses and coaches unemployed women for success at their job interview. We empower each woman by giving her the clothes and the confidence she needs to succeed.
The Smart Works service is delivered in London, Manchester, Glasgow, Edinburgh, Birmingham, Newcastle, Reading and Leeds. It is our mission that any woman who needs our service should be able to find her way to a Smart Works centre.
Smart Works & Privacy
Smart Works are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner in accordance with applicable laws governing protection and privacy of personal data (“Data Protection Law”).
For further information about our privacy practices, please contact us by:
Writing to Smart Works, Unit 1 Canonbury Yard, 202-208 New North Road, London, N1 7BJ
Calling us on 0207 288 1770
Emailing to gdpr@smartworks.org.uk
References to “we”, “us”, or “our” in this Privacy Policy are references to Smart Works, a company limited by guarantee registered in England and Wales, registered company number: 3870671; and a charity registered in England and Wales, registered charity number: 1080609. It also refers to our licensed Smart Works centres in Birmingham (‘Smart Works Birmingham’ registered company number: 10098116; and a charity registered in England and Wales, registered charity number: 1168264), Scotland (‘Smart Works Scotland’ registered company number: CS001342; and a charity registered in Scotland, registered charity number: SC044520), Manchester (‘Smart Works Greater Manchester’ registered company number: 09425123; and a charity registered in England and Wales, registered charity number: 1163594), Newcastle (‘Smart Works Newcastle’ registered company number: 11115960; and a charity registered in England and Wales, registered charity number: 1176547), Reading (‘Smart Works Reading’ registered company number: 09626510; and a charity registered in England and Wales, registered charity number: 1164723) and Leeds (‘Smart Works Leeds’ registered company number: 12059540; and a charity registered in England and Wales, registered charity number: 1184676) Each local Smart Works is an independent Charity and affiliated to Smart Works Charity through a licensing agreement. On occasion we will share your personal information between Smart Works centres but we will only do this when there is a legitimate reason to do so, for example when Smart Works Charity is required to report on the performance of all centres.
The type of personal information we collect
Smart Works may collect the following personal data:
- Identity Data – this may include first name, last name, home address and pictures that include yourself. Such data may be obtained through a direct ask or via submission of other material for example, a CV.
- Contact Data – this may include billing address, delivery address, email address, telephone numbers and social media handles. Such data may be obtained through a direct ask or via submission of other material for example, a CV.
- Diversity Data – this includes data you provide to Smart Works relating to your demographic characteristics which may include characteristics like your age, ethnicity, or parental status. Providing this data is explicitly optional and is asked via a questionnaire for instance during your Smart Works appointment or when applying to work at Smart Works.
- Profile Data – this includes data you have provided about yourself through interactions with Smart Works. This may include attendance at appointments or events, feedback, survey responses and clothing sizes.
- Communications Data – this includes communication and marketing preferences and records of the information we have provided to you.
- Financial Data – this includes data from the payment details you share with third party transaction provides, e.g. Zettle, when purchasing goods or services provided by Smart Works or making a financial donation to Smart Works.
- Transaction Data – includes details about payments to and from you and other details of donations made to by you, and any products you have purchased from us.
- Disclosure and Barring Service (DBS Check Data) – this refers to data processed after an individual undergoes a DBS check at Smart Works’ request.
- Criminal Offence Data – as Smart Works accepts client referrals from prison service, and organisations that support those with criminal histories, data relating to an individual’s criminal history is collected by Smart Works on occasion. Smart Works takes its responsibility over this sensitive data seriously and only collects Criminal Offence data when necessary to fulfil our charitable aims.
- Recruitment data – for those applying to work, or become a Trustee, at Smart Works we collect specific data to aid us with the hiring process. This includes details relating to references, work history, qualifications, notice period, working preferences and information provided in response to interview questions.
How we get personal information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- You have been referred to Smart Works for an appointment.
- You are a client attending an appointment with Smart Works.
- You are a contact making a referral to Smart Works.
- You are fundraising for or donating to Smart Works.
- You are taking part in an event run by Smart Works.
- You are volunteering at Smart Works.
- You are applying to become an employee or a Trustee at Smart Works.
We use your personal information for the purposes described in the overview below. Please choose the most appropriate section depending on the nature of your relationship with us:
| Our clients’ data | |
| What data do we process? | Identity Data, Contact Data, Profile Data, Communications Data, Diversity Data, Criminal offence data |
| Who does this apply to? | When we refer to “clients” this includes anyone who has used, or has been referred to use, the Smart Works service. |
| Why we process your data? | Collecting the data of our clients is fundamental to the facilitation of the Smart Works service. We use the data provided to log client referrals, arrange appointments, monitor our activity, evaluate the outcomes of our service and process client feedback.
With the consent of our clients, we may use personal data to contact clients about further opportunities to engage with Smart Works. On occasion, and if applicable, Smart Works may process criminal offence data in the form of accepting client referrals from organisations that support those with criminal histories. Smart Works processes only the connection between the organisation and the client. We collect Diversity Data to monitor the reach of our services. Clients are not obliged to provide Diversity data. |
| When is this information shared with a third party? | At Smart Works, we prioritise the security and privacy of your personal data. Smart Works will not share or sell your personal data with any third party for their promotional purposes. You will not receive any marketing communications from any other organisations, besides Smart Works, as a result of us processing your data and we do not allow third parties to pass your data on to other organisations.
Smart Works will only share personal data with third parties deemed to enable the charity’s operation or growth. Third parties are only allowed to process your data for specified purposes, in accordance with instructions provided by us, and we strive to minimise the amount of personal data we share where possible. This data may be shared with a third party in the instance that a trusted external provider has access to our cloud-based servers including those who provide IT support. With consent, we may share personal data for the purpose of promoting our charitable aims, for example through sharing client case studies. We may also share aggregated data, relating to clients, with Referral Agencies. On occasion, and if relevant, we may also share personal data with the Smart Works centres local to you or to our charity HQ. |
| What legal basis do we have to process your data? | We rely on legitimate interests for the facilitation of our service including to receive referral data, provide and analyse the effectiveness of services and to handle any complaints.
Data shared with third parties is done so as it is within our legitimate interests for example to ensure effective IT systems. Any data shared otherwise will be done so with consent unless anonymised. We rely on consent to process any criminal offence data supplied when the prison service (or organisation that supports those with criminal histories) is acting as a referring agent. |
| Is it obligatory to supply this data and what are the consequences of not supplying the data? | Without providing your contact and identity data we may be unable to arrange an appointment with you.
You are not obliged to provide further data collected during your appointment. |
| Will the data be used in any automated decision-making? | No. |
| Where do we store your data? | Physical files are kept in locked and fire-resistant locations within our centres. All client data that is not stored physically is stored digitally on cloud-based servers within Europe. |
| Our supporters’ data | |
| What data do we process? | Identity Data, Contact Data, Communications Preferences Data, Financial Data, Transactions Data. |
| Who does this apply to? | Our “supporters” includes anyone that donates, or registers to donate, to Smart Works. This could be a monetary donation, or a donation of clothes.
Donating, or registering interest, may also come through purchasing goods and services from, or attending an event hosted by, Smart Works. |
| Why we process your data? | We process the personal data of our supporters to process donations via our website, phone or post, process Gift Aid, provide information about fundraising or other events they are taking part in, provide information about our wider work, for example in newsletters, keep note of their interactions with us, and to build relationships with our supporters enabling the charity to grow. |
| What legal basis do we have to process your data? | We rely on legitimate interests to administer and manage supporter relations generally.
Our supporters may receive email marketing communications from us based on their consent. |
| When is this information shared with a third party? | At Smart Works, we prioritise the security and privacy of your personal data. Smart Works will not share or sell your personal data with any third party for their promotional purposes. You will not receive any marketing communications from any other organisations, besides Smart Works, as a result of us processing your data and we do not allow third parties to pass your data on to other organisations.
Smart Works will only share personal data with third parties deemed to enable the charity’s operation or growth. Third parties are only allowed to process your data for specified purposes, in accordance with instructions provided by us, and we strive to minimise the amount of personal data we share where possible. This data may be shared with a third party in the instance that a trusted external provider has access to our cloud-based servers including those who provide IT support. In line with legal obligations, we may be required to data relating to the processing of Gift Aid with HMRC. Smart Works uses provider MailChimp to send marketing and communications. If you have consented to receive email content from us, your data will be hosted on MailChimp. On occasion, and if relevant, we may also share personal data with the Smart Works centres local to you or to our charity HQ. |
| Is it obligatory to supply this data and what are the consequences of not supplying the data? | If a supporter withholds personal data Smart Works may be unable to receive a donation from or process a transaction with that supporter or communicate with them about our work and how their donation is helping Smart Works. |
| Will the data be used in any automated decision-making? | No. |
| Where do we store your data? | MailChimp servers, that host mailing lists on behalf of Smart Works, are based in the United States of America. MailChimp is authorised to hold personal data from UK controllers as it is certified to the EU-US Privacy Shield regime. You can learn more by reading MailChimp’s privacy notice.
All other supporter data that is not stored physically is stored digitally on cloud-based servers within Europe. Donation and Gift Aid forms may be stored physically in secure and fire-resistant locations within our centres. |
| Our volunteers’ data | |
| What data do we process? | Identity Data, Contact Data, Profile Data, Communications Data, DBS Data, Diversity Data. |
| Who does this apply to? | “Our volunteers” refers to anyone that donates their time to support Smart Works either as part of their organisation or on their own time. |
| Why we process your data? | We process the personal data of our supporters to so we can assess their suitability for the voluntary position, organise appointments, organise other events, receive feedback, ensure they are engaged with their volunteering role and to maintain relationships with our volunteers. We may collect Diversity data about our volunteers for monitoring purposes. |
| What legal basis do we have to process your data? | We rely on our legitimate interests to process the data of our volunteers for example, to ensure we can organise appointments and to share reports on client outcomes. |
| When is this information shared with a third party? | At Smart Works, we prioritise the security and privacy of your personal data. Smart Works will not share or sell your personal data with any third party for their promotional purposes. You will not receive any marketing communications from any other organisations, besides Smart Works, as a result of us processing your data and we do not allow third parties to pass your data on to other organisations.
Smart Works will only share personal data with third parties deemed to enable the charity’s operation or growth. Third parties are only allowed to process your data for specified purposes, in accordance with instructions provided by us, and we strive to minimise the amount of personal data we share where possible. This data may be shared with a third party in the instance that a trusted external provider has access to our cloud-based servers including those who provide IT support. On occasion, and if relevant, we may also share personal data with the Smart Works centres local to you or to our charity HQ. |
| Is it obligatory to supply this data and what are the consequences of not supplying the data? | If a supporter withholds their personal data Smart Works could be unable to arrange volunteer opportunities with that individual.
If an individual is unable to provide DBS data, Smart Works may be unable to let that individual volunteer. Volunteers are not obliged to provide Diversity data. |
| Will the data be used in any automated decision-making? | No. |
| Where do we store your data? | All volunteer data that is not stored physically is stored digitally on cloud-based servers within Europe. |
| Our referral contacts’ data | |
| What data do we process? | Identity Data, Contact Data, Communications Preferences Data, Profile Data. |
| Who does this apply to? | Our “referral contacts” are the individuals that interact with Smart Works through the process of referring a client. Referral contacts represent Referral Agencies that work in agreement with Smart Works. |
| Why we process your data? | We process the personal data of our referral contacts so we can facilitate the appointments of clients, build professional relationships, monitor the growth of our service, provide information about relevant opportunities and events related to Smart Works. |
| What legal basis do we have to process your data? | We rely on legitimate interests to administer and manage referral contact relations generally. |
| When is this information shared with a third party? | At Smart Works, we prioritise the security and privacy of your personal data. Smart Works will not share or sell your personal data with any third party for their promotional purposes. You will not receive any marketing communications from any other organisations, besides Smart Works, as a result of us processing your data and we do not allow third parties to pass your data on to other organisations.
Smart Works will only share personal data with third parties deemed to enable the charity’s operation or growth. Third parties are only allowed to process your data for specified purposes, in accordance with instructions provided by us, and we strive to minimise the amount of personal data we share where possible. This data may be shared with a third party in the instance that a trusted external provider has access to our cloud-based servers including those who provide IT support. On occasion, and if relevant, we may also share personal data with the Smart Works centres local to you or to our charity HQ. |
| Is it obligatory to supply this data and what are the consequences of not supplying the data? | If a referral contact withholds personal data Smart Works may be unable to liaise with them in order to facilitate the appointment of the client being referred, manage the relationship effectively, or contact their organisation regarding Smart Works’ services. |
| Will the data be used in any automated decision-making? | No. |
| Where do we store your data? | All referral contact data that is stored digitally on cloud-based servers within Europe. |
| Our applicants’ data | |
| What data do we process? | Identity Data, Contact Data, Profile Data, Diversity Data and Recruitment Data, DBS Check Data. |
| Who does this apply to? | “Our applicants” refers to anyone applying to become a member of staff or Trustee at Smart Works. |
| Why we process your data? | The data Smart Works processes this data to facilitate the application process. We may collect Diversity data about our applicants for monitoring purposes. |
| What legal basis do we have to process your data? | We process the personal data of our applicants as is necessary to our Legitimate Interest and to fulfil a contract with successful applicants.
In addition, we process Diversity data associated with applicants with their consent for monitoring purposes. |
| When is this information shared with a third party? | At Smart Works, we prioritise the security and privacy of your personal data. Smart Works will not share or sell your personal data with any third party for their promotional purposes. You will not receive any marketing communications from any other organisations, besides Smart Works, as a result of us processing your data and we do not allow third parties to pass your data on to other organisations.
Smart Works will only share personal data with third parties deemed to enable the charity’s operation or growth. Third parties are only allowed to process your data for specified purposes, in accordance with instructions provided by us, and we strive to minimise the amount of personal data we share where possible. This data may be shared with a third party in the instance that a trusted external provider has access to our cloud-based servers including those who provide IT support. On occasion, and if relevant, we may also share personal data with the Smart Works centres local to you or to our charity HQ. |
| Is it obligatory to supply this data and what are the consequences of not supplying the data? | Failure to provide Identity, Contact, DBS or Recruitment data may prevent Smart Works from being able to facilitate crucial stages of the application process.
Applicants are not obliged to provide Diversity data. |
| Will the data be used in any automated decision-making? | No. |
| Where do we store your data? | All applicant data is stored digitally on cloud-based servers within Europe. |
Data Retention
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
The criteria used to determine our retention periods include (i) the nature and length of time of our ongoing relationship (ii) whether there is any legal obligation to which we are subject (iii) whether we can achieve our purposes without continuing to hold the personal data. If you would like to know more about the retention periods, we apply please contact us on the details below.
Data Security
We seek to use reasonable organisational, technical, and administrative measures to protect Personal information within our organisation.
Cookies
We may collect personal information using cookies and similar technologies. Please see our cookies policy for more information.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at gdpr@smartworks.org.uk or on 020 7288 1770 if you wish to make a request related to your rights.
Children
We do not knowingly collect personal information from individuals under the age of 16 for the purposes outlined in this privacy notice.
How to contact us
Name: Smart Works
Address: Unit 1, Canonbury Yard, 202-208 New N Rd, London N1 7BJ
Phone Number: 020 7288 1770
E-mail: gdpr@smartworks.org.uk
If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details above. You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk