Companions

Companions Privacy Statement - May 2018

Introduction

Emmaus Oxford ("We") promises to respect and keep safe any personal data you share with us.  We aim to be clear about how we will use your data and not do anything you wouldn’t reasonably expect from us.

For the purpose of the General Data Protection Regulation and the Data Protection Act 1998 the data controller is Emmaus Oxford of 171 Oxford Road, Cowley, OX4 2ES, a registered charity with Charity Number: 1066618.

 

What information will we collect?

If you join an Emmaus community we will usually collect the following information about you:

  •  Name
  •  Date of birth
  •  Nationality
  •  National insurance number
  •  Housing situation and housing history
  •  Support records
  •  Needs and Risk assessments
  •  Bank details

We may also collect, store and use the following "special categories" of more sensitive personal information:

  •  Health (including history of drug and alcohol use and details of additional support needs)
  •  Eligibility to claim benefits
  •  Racial or ethnic origin
  •  Political opinions
  •  Religious of philosophical beliefs
  •  Sex life and sexual orientation

 

How is your personal information collected?

We collect information:

  • When you apply to join an Emmaus community and provide information in your application form.
  •  When we carry out a risk assessment as part of the process of joining a community.
  •  When we record details of support sessions and interventions carried out during your time at Emmaus.

 

Why do we collect your information?

We need all the categories of information in the list above primarily to allow us to provide support to you during your time living at Emmaus Oxford. The legal basis for processing your personal data is to protect your vital interests. The situations in which we will process your personal information are listed below: 

  • Defending and Exercising Legal Rights
  • Providing a Housing and Support service
  • Processing of welfare benefit claims [eg. Housing Benefit]
  • Risk management and Health and Safety
  • Processing of allowances and companion expenses
  • Processing of information in respect of Housing and employment applications
  •  Other Legitimate Business interests [eg. we may ask for your permission to use personal data in a news story or newsletter]

 

How we use particularly sensitive personal information

 "Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. Our legal basis for processing special categories of personal data is that such processing is carried out in the course of our legitimate activities as a charity with appropriate safeguards in place.

We will use your particularly sensitive personal information in the following ways: 

  • Defending and Exercising Legal Rights
  • Risk Management and risk assessment
  • Providing a Housing and Support service
  • Processing of information in respect of Housing and employment applications

 

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legitimate activities as a charity. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your staying with us that you agree to any request for consent from us.

 

Information about criminal convictions

We may only use information relating to criminal convictions (e.g. sex offender registration and unspent criminal convictions) where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions and we will use information about criminal convictions and offences in the following ways: 

  •  Defending and Exercising Legal Rights
  •  Risk Management and risk assessment
  •  Providing a Housing and Support service
  •  Processing of information in respect of Housing and employment applications

 

Accessing information from other sources

We may gain access to your information from other third party organisations, when you when you give them permission to do so or if the information is available publicly. This information will only be recorded if it is beneficial in order to provide you with support during your time at Emmaus.

 

Data Sharing

Should you move from one Emmaus community to another, we will transfer your support record to the new community, to allow consistency of support during your time at Emmaus.

We will not share your personal details with third parties. 

 

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. This includes the Inform Support system.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the General Manager.

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.

 

Your rights in connection with personal information

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

 

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to 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.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us on 01865 590591 or by email or send a description of the information you want to see and proof of your identity by post to: Eddie Blaze, Emmaus Oxford, 171 Oxford Road, Cowley, Oxford, OX4 2ES.

 

No fee usually required

You will not have to pay a fee to access your personal information (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.

 

What we may need from you

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.

 

How long we will retain your information for

We will retain your personal information for the duration of your time at Emmaus and for 24 months after you leave. At that point all information we hold about you will be securely disposed of.

 

Keeping our records up to date

 It is your responsibility to inform us of any changes to your personal details.

We may change this Privacy Policy from time to time.  If we make any significant changes in the way we treat your personal information we will make this clear by contacting you directly.

If you have any questions, comments or suggestions, please let us know by contacting us at Emmaus Oxford, 171 Oxford Road, Cowley, Oxford, OX4 2ES or by email

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