(Where the words 'BAY Centre', 'us' or 'we' are used it will mean the registered charity known as the 'Burnham Area Youth Centre', registration number 304500.)
This Policy explains, in more detail, what lawful Basis the BAY Centre uses for processing personal data.
The EU General Data Protection Regulation 2016 says that we must have a valid lawful basis (legal reason) in order to process your personal data.
There are six available lawful bases for processing -
1. Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
2. Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
3. Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
4. Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
5. Vital interests: the processing is necessary to protect someone’s life.
6. Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
Number 5, Vital Interests, and 6, Public tasks, don’t apply to us.
(‘The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract’ - from ICO Guidelines.)
This basis is used for -
◆Hirers who enter into a contract with the BAY Centre to hire a room. We feel that the act of us offering a room for hire and a Hirer accepting the Terms and Conditions and subsequently paying for the room constitutes a contract between the BAY Centre and a Hirer. We feel that collecting and using a name and contact data (i.e. one or more of - an email address, phone number or postal address) is necessary for us to administer the contract.
◆Vendors who enter into a contract with the BAY Centre to provide their service. We feel that the act of us employing the services of a Vendor, accepting their Terms and Conditions and subsequently paying for the service constitutes a contract between the BAY Centre and a Vendor. We feel that collecting a contact name, email address, phone number is necessary for us to administer the contract. We feel that if we are paying the Vendor by cheque that the collecting and using a postal address is necessary for us to administer the contract.
◆Employees who enter into an employment contract with the BAY Centre. We feel that the act of us employing someone to give us their time and work and to whom we pay a wage constitutes a contract between the BAY Centre and an Employee. We feel that collecting a name and contact data (email address or phone number) is necessary for us to administer the contract.
(‘The individual has given clear consent for you to process their personal data for a specific purpose’ - from ICO Guidelines.)
This basis is used for -
◆ Volunteers, to communicate with them. We ask Volunteers when initially volunteering to fill in a registration form along with a consent form asking for consent to collect and use their name and contact data (one or more of - an email address, phone number or postal address).
◆ Donors & Grantors who have consented to publicise their donation or grant on the BAY Centre’s websites or 3rd party news outlets. We ask Donors or Grantors to fill in a consent form if they wish their donation or grant to be publicised.
◆ Donors & Grantors who have consented to us keeping them informed about their gift and the purpose to which their gift is being used and progress reports when that gift is used for a specific purpose, e.g. painting the hallway.
◆ Volunteers, Recording the names of Trustees and Volunteers in the BAY Centre minutes of both general meetings and AGMs and making the minutes available to all Trustees. Consent is asked for in the initial Volunteers consent form.
◆ Hirers who wish to show their personal contact data on the BAY Centre’s websites. When a Hirer initially hires a room they are asked to fill in a form asking for their consent if they wish their contact details to be displayed on our main website.
◆ Individuals whose personal data is used in a publicity article on the BAY Centre’s websites or 3rd party news outlets. When taking pictures for publicity or news articles to be published on our websites, individuals will either be asked to fill in an online form or asked verbally to give their consent for us to use either their photo and/or name in the publicity or news article. They will also be asked, separately, whether they agree that their photo or name can be forwarded to 3rd party news outlets.
◆ Employees who wish their wages to be paid by bank payments. If an employee wishes their wages to be paid directly into their bank accounts we ask them to fill in a form granting their consent for us to collect and pass this information onto our current Bank.
◆ Hirers, Vendors, Employees, Volunteers, Donors and Grantors who have consented to us contacting them by email to ask for future consents that may arise.
(‘The processing is necessary for you to comply with the law (not including contractual obligations’ - from ICO Guidelines.)
This basis is used for Donors, Grantors, Hirers, Vendors, Volunteers and Employees where the BAY Centre has to comply with any legal obligations through statutory or regulatory requirements. It will also be used as the basis for keeping documents for the specified length of time e.g. charity minutes have to be kept as long as the charity is a registered charity.
This basis is also used to collect and keep Data Protection records of any requests to access and control personal data.
(‘The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests’ - from ICO Guidelines.)
This basis is used for the following processing -
◆ CCTV; collecting images for the prevention and detection of crime. Our specific Legitimate Interest is -
‘The Legitimate Interest is to use CCTV cameras to detect and prevent crime, to identify health and safety problems and provide a safe and reassuring Centre for the community.’
We feel that, as the BAY Centre is unmanned, recording CCTV images along with our alarm system give us a chance to detect and prevent crime and to safeguard the volunteers and the many people using the Centre.
We feel that the targeted use of a CCTV camera in our hallway and exteriors would not be unexpected nowadays.
We feel that this Legitimate Interest along with an individual’s right to object to the capture of their image would have a minimal privacy impact.
April 2018 Document initially published. The policy is one of a series of policy documents that replace all previous policy documents that existed in a variety of different formats, some electronic, some paper and some verbal. >>Back to Top
