Cookies and Privacy Policy – General: updated January 2019

 

The information on this page sets out how we manage the personal information of the users of this website. If you are detained in Yarl's Wood IRC, please see our separate Privacy Policy for those who are detained.

 

Yarl’s Wood Befrienders (YWB) is a small, independent, local charity. We recruit and train volunteer Befrienders, who will visit an allocated person for as long as they are detained at Yarl’s Wood Immigration Removal Centre (‘the Centre’), to offer friendship and emotional support.

Cookies and Privacy Policy

General information relevant to all users


At YWB, we are committed to protecting your privacy. The purpose of this policy is to explain how YWB processes your data, whether you are using our service, interested in volunteering, making a donation or just browsing our website.

This website will only ask for your personal information, such as your name, address or email address, when it is required – for example, to join our mailing list or to register for events.

Personal information, which is information that identifies you and relates to you, such as your name and contact details, is subject to Data Protection legislation including the General Data Protection Regulation (GDPR). While YWB collects personal information and, sometimes, sensitive personal information, we are committed to protecting the privacy and security of your personal information.

Please see the specific headings below for details of information YWB collects from you, what we do with that information and how we keep it safe.

As the service we provide changes or there are any further changes to the law, we may need to alter our privacy policy. Any changes to the policy will be posted on the website.

Contacting us

If you have any queries about this policy, please contact: Yarl’s Wood Befrienders, 43 Bromham Road, Bedford MK40 2AA or email: info@ywbefrienders.org or telephone 01234 867219 / 07789 520640.

Use of cookies

Like most websites, our website uses cookies. A cookie is a small file placed onto your device that enables YWB’s features and functionality to operate on the device you are using to view our website. Cookies may record your IP address and other information about your computer, however, those we use do not collect any other personal information about you.

Your rights under General Data Protection Regulation (GDPR) including subject access requests

Data Retention – YWB will only hold the information we need and only for as long as it is needed.

There are different retention periods depending, for example, on whether you are using our service or making an online donation. Please read the section that relates to you to find the appropriate retention period for your data.

Rights to access and control your personal data

Regardless of whether you use our service, volunteer, or make an online donation, you may exercise the following data protection rights: the right of deletion; the right to amend or rectify your personal data; the right to object to the use of your personal data; the right to restrict processing of your data; the right of access; and the right of portability.

Please contact us at: info@ywbefrienders.org if you require any help accessing your rights.




If you would like to complain


Reporting complaints or concerns

The Information Commissioner’s Office (ICO – a government body) gives free guidance both to organisations and the public about handling data safely, making subject access requests*, raising a concern or claiming compensation, or checking that information is held correctly. For more details see the ICO website at: https://ico.org.uk/for-the-public/ You have the right to make a complaint at any time to the ICO but, if you do have any concerns regarding how YWB is handling your information, we would appreciate the chance to deal with your concerns first, and ask that you contact us at: info@ywbefrienders.org so we can attempt to resolve any issues.

*Subject access requests/right(s) of access

You may apply to YWB at: info@ywbefrienders.org for a copy of any information we hold about you. YWB will endeavour to send you a free, electronic copy of any information held within one month. If your request is unfounded, repetitive or excessive, we may charge a reasonable fee or refuse to comply with your request. We will give you reasons why we think this is so and why we cannot comply. If your request is particularly complex or you have made a number of requests, we may require longer than one month to respond to your request. We will notify you that this is the case and keep you updated.




Data retention and security


We seek to use reasonable organisational, technical, and administrative measures to protect your personal information within our organisation from loss, misuse, unauthorised access or disclosure, alteration and/or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us at: info@ywbefrienders.org

We will retain your Personal Information for as long as needed or permitted in light of the purposes for which it was obtained. The criteria used to determine our retention periods include the length of time we have an ongoing relationship with you and provide our services to you, our legal obligations, or whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)., For specific details relating to information held about you, please see the section that relates to you below.

Transfers of information outside the European Economic Area (EEA)

Most of your personal information will be stored electronically in cloud-based applications and will remain within the EEA. However, please see the section ‘If you would like to volunteer with us as a Befriender or Office volunteer’ if you are a prospective volunteer or ‘If you donate to YWB’ if you are an online donor, as your information WILL be transferred outside the EEA, including the United States, to countries which may have different data protection rules from those of your country.

Some of the non-European Economic Area (“EEA”) countries are recognised by the European Commission as providing an adequate level of data protection according to EEA standards, and the full list of these countries is available here. For example, the United States (US) EU-US Privacy Shield has been recognised as adequate data protection by the European Commission, more details are available here.

Please email us at info@ywbefrienders.org for more information.




What information do you hold about me?


Please see the following headings below for information that specifically details what information we hold and about you, how we collect it and why, how long we retain it for and how we keep it secure:

  • if you volunteer or would like to volunteer with us as a Befriender or in the office
  • if you donate to YWB.

If you volunteer or would like to volunteer with us as a Befriender or in the office

  

How and when we collect information about you

When you apply to become a volunteer, you will register online to attend an information session and, if you wish, a later training and selection day. This is done via Eventbrite, an American company which may transfer your data outside the EU. Eventbrite has subscribed to the EU-US privacy shield framework which has been recognised by the European Commission as providing adequate protection for data. Some of that personal information (eg email address) will also be stored by us for the purpose of contacting you. 

To apply to become a volunteer, we will ask you to complete a personal information form. If you complete the form but do not ultimately become a volunteer, your application form will be securely destroyed. If you continue with the process and become a volunteer, we will store your form and any other relevant information (eg notes of your interview process, joint visits feedback, and references) securely in a locked cabinet while you are volunteering with us. Once you have confirmed that you wish to stop volunteering, we will securely destroy all of your information within three months.   

The information will we collect about you and how we use it

Privacy law requires us to inform you what data we collect and on what legal basis we process it. We will collect and process the following data, and we rely on the following basis to do so:   

Essential information: your name, address and contact details, date of birth, health and disability information (if relevant) and next of kin details; the names and contact details of two suitable referees. This information is required to: contact you, to notify someone in the event of an emergency and to help us verify your suitability to volunteer with us. We may also collect your bank details for reimbursement of expenses.  We also need to know if you have any previous convictions in order to safeguard the people we visit and support and, for this purpose, will ask you to complete a Standard Disclosure and Barring Service Check and allow us to access the details. This will provide us with confirmation of any unspent or spent convictions which you may have. This information is considered to be special or sensitive and requires a higher level of protection. We, therefore, ask for your written consent (on your personal information form) to collect and store this. If you choose not to supply this information, however, we may not be able to progress your application to volunteer with us.

Additional information: it is your choice whether you provide us with information about your religion, your sexuality, your ethnicity and other languages spoken. This type of information is considered to be special or sensitive and requires a higher level of protection. We, therefore, ask for your written consent (on your personal information form) to collect and store this. Legally, this does not affect your rights to opt out (or stop) your information from being processed by us at any time. To do this, you need to email us at info@ywbefrienders.org entering ‘Volunteer Opt-out’ in the subject heading and stating your full name and email address in the body of the email. Please note that this will only be effective as to future processing, and some processing may have already taken place. 




Who will we share your information with?


We will only share your personal information with:    

  • YWB staff and volunteers   
  • third parties, such as Eventbrite, Mailchimp, or Survey Monkey (used for event booking, newsletter or survey purposes), may retain information about you (see comments above)
  • Yarl’s Wood Immigration Removal Centre (‘the Centre’) requires us to provide your name, address, phone number and date of birth in order to book a joint (accompanied) visit for those wishing to become a Befriender
  • any person you may visit at the Centre.




How do we keep information secure and how long will we store it?   


Whenever we collect or process your personal information, we will only keep it for as long as is necessary for the purpose for which it was collected (or as required under law). YWB will shred and delete any information about you securely as soon as possible after you notify us that you have stopped volunteering. We aim to shred all paper records within three months. Minimal details about you, eg contact details, are stored on our electronic database and will be deleted as soon as possible after you cease volunteering with us. 

If you donate to YWB

Online donations

Your payment information including your credit card or bank number, expiration date, billing address and transaction amount is collected on our payment page by a third-party, payment processors (currently Virgin Money Giving and JustTextGiving by Vodafone, please see further details below) and will be subject to the third party’s privacy policy. We have no control over, and are not responsible for, the third party’s collection, use and disclosure of your personal information. We receive information on payment amount only; no other payment information is stored or saved within our systems, subject to the comments made about GiftAid below.

JustTextGiving by Vodafone has subscribed to the EU-US privacy shield framework which has been recognised by the European Commission as providing adequate protection for data and is committed to ensuring that all countries in which data is being transferred have adequate compliance.

Virgin Money Giving will take ‘all steps reasonably necessary’ to ensure that countries in which data is being transferred or stored comply with data protection legislation and, specifically, its privacy policy.

While YWB makes all reasonable checks that the third parties processing these donations comply with data protection legislation and, specifically, YWB’s privacy policy, it is for the individual donor to be satisfied that they are happy to provide their details in this manner.

If you GiftAid your online donation, please note that we may be required to retain details for legal, accounting and statutory reasons, eg to comply with any requests from HM Revenue & Customs (HMRC). We will treat your personal information as confidential and your details will not be passed on (except as required by law), or sold to anyone.

Funders and institutional donors

YWB does not engage in any direct marketing, as most requests for funding are completed on the requisite institution’s application form and are not unsolicited.

Funders’ details and application forms and letters of acceptance and refusal are retained for as long as necessary to retain details of payments made and contact details for future applications.

If you subscribe to our emails

Occasionally, we will send subscribers to our email list, carefully selected emails supplying information and details of events relating to YWB which subscribers have requested. This service is operated by Mailchimp. As emails are not a secure method of sending information, no confidential information is contained in emails we send using Mailchimp.

Mailchimp is a US company, so this service does involve transfers of data outside the EEA. However, Mailchimp has certified its compliance with the EU-US Privacy Shield which has been recognised as being compatible with EU Data Protection laws.

You can opt out of receiving emails at any time by unsubscribing from the Mailchimp list. Alternatively, you can notify us directly by emailing us at: info@ywbefrienders.org putting ‘Mailchimp – stop’ in the subject heading and stating your full name and email address in the body of the email.