Smart Works Privacy and Cookies Policy
Last updated 2020
- Who we are
- How we collect information about you
- Information we collect and why we use it
- Legal basis for using your information
- Sharing your Information
- Keeping your information safe
- How long we hold your information for
- Your rights
1. Who we are
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 [email protected]
2. How we collect information about you
Everything we do, we do to ensure that we can support unemployed women on their journey back to work. We want to make sure you receive the communications that are most relevant to you, be it through visiting our website or receiving emails, or phone calls. We want to make sure you receive the best possible experience when you attend an appointment, book on an event, become a supporter or make a donation.
We collect information from you in the following ways:
When you interact with us directly: This could be if you refer someone to us, are booked in for an appointment, ask us about our activities, register with us for an event, make a donation to us, ask a question about Smart Works, purchase something online, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, send us an email, visit our website or get in touch through the post, or in person.
When you interact with us through third parties: This could be if you provide a donation through a third party supplier such as Just Giving or one of the other third parties that we work with and provide your consent for your personal information to be shared with us.
When you visit our website: We gather general information which might include which pages you visit most using cookies. We may also track which pages of the Smart Works website (www.smartworks.org.uk) you visit when you click on links in emails from us. We also use “cookies” to help our site run effectively. There are more details below – see ‘Cookies’.
We use this information to make improvements to our website and to ensure we provide the best service and experience for you. Wherever possible we use anonymous information which does not identify individual visitors to our website.
3. Information we collect and why we use it
Personal information we collect includes details such as your name, age, email address, postal address, telephone number, as well as information you provide in any communications between us. You will have given us this information whilst booking a Smart Works appointment, organising a meeting, making a donation, registering for an event, placing an order on our website or interacting with us in another way.
We will mainly use this information:
- To enable the delivery our core dressing and interview coaching service
- To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
- To provide the services or goods that you have requested.
- To update you with important administrative messages about your donation, an event or services or goods you have requested.
- To keep a record of your relationship with us.
- Where you volunteer with us, to administer the volunteering arrangement.
If you do not provide this information, we will not be able to process your donation, sign you up for a particular event, deal with your enquiry or provide goods and services you have requested.
We may also use your personal information:
- To contact you about our work and how you can support Smart Works
- To organise additional support sessions, for example our Second Dressings
Sensitive Personal Information
Data Protection Law recognises that some categories of personal information are more sensitive than others (this is called ‘special category’ or ‘sensitive’ personal data). An example of this is information about ethnic origin. If we collect personal information that is ‘special category’ or ‘sensitive’ then we will only use this information to identify trends and we will not use or share this information without your explicit consent.
4. Legal basis for using your information
We will only use your personal information where we have one or more of the following legal basis for doing so:
- Where we have your freely given, specific, informed and unambiguous consent to use this information for a particular purpose;
- Because we need to use it in order to enter into or fulfil a contract with you (for example, because you have placed an order on our website);
- To protect yours or someone else’s vital interests (e.g. a medical emergency);
- For us to comply with a legal obligation; and/or
- Where use of that information is necessary in Smart Works’ ‘legitimate interests’ to help us to administer and achieve our work as a charity. Whenever we process your personal information under the ‘legitimate interest’ lawful basis, we make sure that we balance our interests against your legal rights and interests as an individual. In particular, we will not process your personal information in a manner that is privacy intrusive.
We may contact you about our work and how you can support Smart Works by phone, email or text message but we will only send direct marketing communications by email or text to individuals at their own personal address where we have their consent or if they have made a purchase and we are sending information about similar products or services, but you can stop us sending you these communication at any time by contacting [email protected] or clicking the unsubscribe link at the bottom of the relevant communication.
6. Sharing your Information
The personal information we collect about you will be used by our staff (and volunteers) at Smart Works so that they can support you or deal with a request or transaction we are entering into with you.
We may disclose your personal information:
- to companies and/or organisations that act as our service providers, who handle information on our behalf and in accordance with our instructions (called “data processors”). These data processors include IT suppliers, data hosting providers, or payment processors;
- if we are under a duty to disclose or share your personal information to comply with any legal obligation (e.g. where we have a duty to provide data to the police or courts);
- to enforce or comply with any agreements you have made with us, for example, where we have to pass personal information to a party who is contracted to provide a service to you or to our legal representatives;
- to protect the rights or safety of Smart Works or others we deal with. This includes exchanging information with external agencies for the purpose of protecting ourselves against fraud or safeguarding ourselves (or others) from criminal activity.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
Each local Smart Works is an independent Charity and affiliated to Smart Works Charity through a licensing agreement. On occasions we will share your personal information with local Smart Works but we will only do this when there is a reason to do so, for example when Smart Works Charity is required to report on the performance of all centres.
7. Keeping your information safe
We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our website.
Our website may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or websites that have links on our website may collect personally identifiable information about you. This privacy statement does not cover the information practices of those other websites or advertisers.
Any debit or credit card details which we receive on our website are collected securely by Paypal our payment processing partner, according to the Payment Card Industry Data Security Standards. We never store any payment card information ourselves.
8. How long we hold your information for
We only keep your personal information only for as long as is reasonable and necessary for the relevant activity we collected it for, or which may necessary to fulfil statutory obligations (for example, the collection of Gift Aid).
Smart Works has a data retention policy that sets out the different periods we retain personal information for in accordance with our duties under Data Protection Law. The criteria we use for determining relevant data retention periods are based on:
- various legislative requirements (for example, duties to hold transaction details for tax/accounting purposes);
- the purpose for which we collected that personal information and where we have identified a continued legitimate need to hold that information to serve such purpose; and
- guidance issued by relevant regulatory authorities including, but not limited to, the UK Information Commissioner’s Office (ICO).
Personal information that we no longer need to hold is securely disposed of and/or anonymised so you can no longer be identified from it.
9. Your rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting [email protected] or calling 0207 288 1770. If you are not satisfied with our response, you can also make a complaint to the UK data protection supervisory authority, the Information Commissioner’s Office (ICO), see – https://ico.org.uk/:
- Access to your personal information:You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge, unless a request is manifestly unfounded or unreasonable. Please make all requests for access in writing, and provide us with evidence of your identity.
- Right to object:You can object to our processing of your personal information 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 ground. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
- Consent:If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
- Rectification:You can ask us to correct or complete any inaccurate or incomplete personal information held about you.
- Erasure:You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
- Portability:if we have collected your personal information on the basis of having your consent or under a contract, you can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
- Restriction:You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request due to legal exemptions. We may also need you to verify your identity before we can fully comply with a request.
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