1.1 Introduction
Compass Support Services Ltd (03506460), is a registered charity (1068324) and the charitable arm of the Pioneer Group. Compass Support Services provides a range of community focused services including community centre, social and recreational activities in the interests of social welfare, poverty relief, advancing education, attainment, and employability skills to Castle Vale, Birmingham, and the surrounding areas. We bring together community groups, businesses, public agencies and other supportive entities and we collaborate with a range of different fund providers to deliver our services and new community-based projects.
To deliver our services and provide project reports back to our partners and fund providers we need to collect some information from you when you register for any of our services. This makes us the legal Data Controller of the personal data that you provide to us.
This Privacy Policy explains what personal information we collect from you, how we collect it and what we use it for. It also explains how we protect your right to information security and the measures that you can take should you have a concern about how we hold, store, share, handle or otherwise process your information. We are committed to protecting your privacy and upholding your information rights.
1.1 Details about Us
Address: Compass Support Services Ltd (03506460), The Sanctuary, Tangmere Drive, Castle Vale, Birmingham B35 7PX
Data Protection Officer for the Pioneer Group: The Pioneer Group, 11 High Street, Castle Vale, Birmingham B35 7PX. [DPO email address]
2. Information we collect about you
2.1 What information about you do we collect?
Compass Support Services only collects, stores, and processes the personal data we need from you to deliver our services and to report back to our partners and the individual fund providers who are supporting the specific project.
The type of information that we collect from you and the purposes that we collect the information for, will depend on the specific project that you have signed up to. We will endeavour to highlight, at the point of registration, why we need the information from you and the purposes that we need your information for. If you sign up, register, or make a referral to a range of different services or projects, we may need collect additional information about you relating to those services and projects.
We will also collect information about you when you voluntarily complete customer surveys, provide feedback, through general correspondence with us or what may be collated from your interactions and engagement with specific projects.
The information we may process about you will be made clear to you at the point of completing the registration form for a specific project, but may also include:
- Full name
- Address
- Telephone
- Date of birth
- Race or Ethnicity
- Religion
- Health indicators
- National Insurance
- Employment status
- Support needs
- Benefits
- Work experience
- Household status
- Life goals
- Training needs
- Learning requirements
- Equal opportunity monitoring
- Education attainment
- Education needs or goals
- Dietary requirements
- Medical information
- Engagement and interactions
- Photographs
- CCTV footage from installed security cameras
- Information from accidents or incidents whilst attending a project
- Call recordings and general correspondence with you
- Complaint made by or about you
- GP’s name and contact details
- School or College
2.1 Why do we collect your information?
We collect the majority of the information contained on your application or referral to join or take part in any of our services directly from you for the purpose of assessing suitability for the project or service, service delivery, managing your expectations, handling queries and complaints, progression and interaction with the project and for your health and safety whilst attending a projected. Some of the information collected from you will also be used to report back to our partners and funding providers under specific obligations relating to the funding award. Where this involves the provision of your personal details, where you are directly or indirectly identified, this will be brought to your attention by way of a privacy statement on the project application.
Information is also collected for the purpose of equal opportunities monitoring. We will endeavour to make clear the form that captures this information, that the purpose of the information collection is for Equal Opportunity monitoring and where applicable, that such information will be kept in an unidentifiable format.
We may also receive additional information about you from referrals that we receive from other organisations including:
- Local schools, colleagues and Further and Higher Education establishments
- Local authorities
- Local social help and welfare charities
2.3 How we will use your information
The information that we collect on you may be used in the following ways:
- To assess your suitability for a project or service offering
- To manage your relationship with us
- To highlight new projects and opportunities that may be of interest to you
- To support you through the project that you have registered for, to engage and interact with you to ensure your needs are met
- To investigate and manage any complaints, accidents or incidents and prevent reoccurrences
- To provide information to our staff to enable them to provide and deliver the services that you have registered for or have shown an interest in
- To deal with any medical or other emergencies and meet your religious or cultural wishes
- To act in your best interests where health or wealth concerns arise.
- To ensure fair and equal access for all to our services
- To help us plan and improve our services and to personalise our service to you
- To provide care, support and welfare services to you and to work with other organisations who provide care and support to you
- To meet our obligations to fund providers and our partners who support us with our service delivery
- To monitor service delivery and use
- To provide you with information about us, including our newsletter
- To prevent and detect crime
- To comply with legal obligations and child protection measures
2.4 Who will we share your information with?
Where your information is used for the purposes listed above, we may need to share the information about you and the people you live with to other organisations that are supporting our work. This information is shared with our partners and fund providers for their own monitoring purposes. Where it is possible to do so, the information that we will share will not contain any details that could identify you. This means that we will, where possible, remove your name, address, contact details and other bits of information that could make you identifiable. This process means that we have removed your identity from your information before it is shared and ensures that your privacy is protected.
Some fund providers, such as the European Social Fund (ESF), require information to be shared with them in a way that they can identify you as an individual. They require this for their own monitoring and evaluation process and may contact you for feedback as to your involvement with the project and to learn from your experience. We will endeavour to highlight to you at the time that you register for a project that it is funded by the European Social Fund, and of this requirement, as we are obliged to report back to them in this way.
We may also share some of your information with organisations/suppliers that we work with, or who work on our behalf, to deliver our services to you. These organisations/suppliers operate under strict agreements and support our work through the provision of:
- Print and mailing services
- Email communication software
- Information technology software and services
There may also be times where we are legally obliged to share information that we hold about you with relevant authorities such as:
- Legal advisors, the courts or the police where we have concerns about possible criminal activity or anti-social behaviour
- Local authorities, adult and child protection and social services where we have concerns about a person’s health or welfare.
- Referral of child protection concerns to safeguarding authorities such as the Children and Families Directorate.
2.5 How long we will keep your information for?
We will hold your information for the length of time required to provide you with the services or support that you require or have requested from us. We may be required to hold your information for a period of time after you have completed a project to meet our legal obligations, for monitoring and reporting purposes, to provide reports to our partners and funders and for resolving any follow up issues.
We maintain a data retention schedule which is a table that sets out how long we keep certain types of personal information for, why and what happens to your information at the end of the retention period. You can contact our Data Protection Officer for more information regarding how long we keep your information for and why.
2.6 Lawful basis for processing
The processing of personal information must be lawful and have a relevant basis within Data Protection rules. We will therefore process your personal information under the following grounds:
- Legitimate Interest: The processing of your information is for a legitimate purpose. For example, it is a legitimate purpose to process your personal information when you register for one of our projects and to support you with your personal needs, goals or aims and achievements. It is also within our legitimate interest to appropriately account for the funds we receive and to report back to our fund providers and partners.
- Legal Obligation: The processing of your information may be necessary to meet a legal responsibility. For example, we are obliged to process your information and inform the relevant authorities where we have a concern regarding an individual’s welfare or safeguarding requirements.
- Explicit consent: We may process your sensitive information where you have provided your explicit consent for us to do so. Where processing is based on your explicit consent, you have the right to remove that consent at any time. Where we are required to obtain your explicit consent, this will be made clear to you before you provide your personal details.
- Social security and social protection: We may process your sensitive information for the social security and protection purposes. For example, we may provide sensitive information about your health to the relevant authorities where we feel there are welfare or safeguarding concerns.
- Statistical purposes: We may process your sensitive information for statistical purposes to understand more about the individuals who use our services and to ensure that our service meets equality requirements. Your information used for statistical purposes, where possible, will have information that identifies you as an individual removed to protect your right to privacy and confidentiality.
You can contact our Data Protection Officer for more information on the lawful and relevant basis for processing your personal information.
We do not transfer any of your information to countries outside of Europe and any data transferred to and from the Europe is by specific agreement to protect your rights to privacy and information security. You can contact our Data Protection Officer for more information regarding our suppliers that may operate from within Europe or America and the types of agreements and safeguards in place to ensure that your information is appropriately protected.
2.7 Security of information
We take your rights to information security and privacy seriously and have implemented a range of ICT technical measures and organisational controls to safeguard and protect your information whilst under our care. These measures include, but not limited to:
- Limiting access to your information to only those who need access.
- Providing training and awareness to staff to ensure that they know how to handle your information correctly.
- Ensuring that your information is protected from harm by keeping our ICT systems up to date and supported by security measures that protect against cyber related crimes.
- Ensuring that any paper documents are held in lockable filing cabinets.
- When your information is used or shared it is done in a secure and compliant manner.
- When we delete\or destroy personal data we will do it in secure manner, in compliance with current Data Protection Regulations.
2.8 Your Rights
You have the following rights concerning your personal data. You can exercise your rights at any time by contacting our Data Protection Officer.
