Privacy Policy

Young Gamblers’ Education Trust

Fair Processing Notice/Privacy Notice

____________________________________________________________

1. Scope

This notice applies to all data subjects whose
data is processed by Young Gamblers’ Education Trust (hereby referred to as
YGAM).

2. Responsibilities

The Data Protection Officer (“DPO”) is
responsible for ensuring that all potential data subjects have sight of this
notice prior to the collection and/or processing of their personal data by YGAM.

The registered Data Protection Officer for YGAM is:  
Charles Sladdin   dataprotection@ygam.org  

All employees of YGAM who interact with data
subjects are also required to ensure that this notice is brought to the
attention of all data subjects, securing their consent for the processing of
their personal data.

3. Fair Processing Notice

YGAM will use the personal data collected from
you for the following purposes:

  • To contact you about training sessions and the services YGAM
    offers
  • To register you on our training courses
  • To issue certification and training materials
  • To process prospective candidate data for new paid roles or
    trustee positions
  • To process payments and donations to YGAM

4. What is Personal Data?

The EU’s General Data Protection Regulation
(“GDPR”) defines “personal data” as:

“any
information relating to an identified or identifiable natural person (‘data
subject’); an identifiable natural person is one who can be identified,
directly or indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person”.

The GDPR classifies certain data as belonging
to “special categories”, as follows:

  • Racial origin;
  • Ethnic origin;
  • Political
    opinions;
  • Religious
    beliefs;
  • Membership
    to a trade-union;
  • Genetic
    data;
  • Biometric
    data;
  • Health
    data;
  • Data
    concerning a natural person’s sex life;
  • Sexual
    orientation; and
  • Other.

The GDPR requires that consent is provided by
the data subject for all types of personal data, including those pertaining to
the special categories set out above and otherwise. Consent must be explicitly
provided.

When YGAM requests sensitive data from data
subjects, it is required to confirm why the information is required and how it
will be used.

5. Legal Basis

To store and process personal data, YGAM relies
on four legal bases:

  • Data Subject Consent [GDPR, Art. 6
    (1) (a)]
  • Processing is necessary for the performance of
    a contract with the data subject or to take steps to enter into a contract [GDPR, Art. 6 (1) (b)]
  • Legal obligation [GDPR, Art 6 (1) c)]
  • Legitimate Interest [GDPR, Art. 6
    (1) (f)]

Consent

Data Subject Consent is the main legal basis
for the storing and processing of personal data. When we collect your personal
data, via our online booking forms, for the purpose of storing and processing
it, we will always ask for your consent to do so in the form of a ‘positive
opt-in method’ as recommended by the GDPR.  

Processing Necessary for Performance of a Contract

Sometimes YGAM will collect, store, and process
personal data for contractual purposes. As stated in the GDPR, (Article 6, (1) (a))
“Processing should be lawful where it is necessary in the context of a contract
or the intention to enter into a contract.”

This includes:

  • When YGAM employees new
    volunteers, paid workers and trustees
  • When YGAM forms new partnerships,
    or starts joint work with another charity or business
  • When YGAM receives grants

Legal Basis

In some circumstances YGAM is required to
process personal data for compliance with a legal obligation to which YGAM is
subject.

This includes:

  • Processing personal data for
    compliance with HMRC employment regulations
  • Processing personal data on
    donations for compliance with HMRC regulations
  • Compliance with a police/court
    investigation

Legitimate Interest

“Legitimate Interests” means the interests of
our company in conducting and managing our business to enable us to give you
the best service/products and the best and most secure experience.

It can also apply to
processing that is in your interests as well.

For example, we may process your information to
protect you against fraud when transacting on our website, and to ensure our
websites and systems are secure.

When we process your personal information for
our legitimate interests, we make sure to consider and balance any potential
impact on you (both positive and negative), and your rights under data
protection laws. Our legitimate business interests do not automatically
override your interests – we will not use your Personal
Data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law).

We process personal information for certain
legitimate business purposes, which include the following:

  • Direct Marketing: We will contact you by post and telephone with marketing and
    fundraising asks which furthers our aims and objectives. We will make sure our
    communications are relevant to you, tailored to your interests. Those
    legitimate interests include providing you with information on our appeals,
    campaigning, services, products, fundraising, newsletter requests, feedback,
    competitions and other activities. YGAM only uses legitimate interest for solicited
    marketing where prior consent is not necessary. This includes:
  • Post.
    • Live phone calls when there is no TPS/CTPS
      registration or objection.
    • Emails/text messages to individuals with soft
      opt-ins.
    • Emails/text
      messages to business contacts.

  • Registering online for workshops: In order for us to process your booking,
    contact information collected has to be collected, such as name, DOB, address email
    and telephone number.
  • Your best interest: Processing your information to protect you
    against fraud when transacting on our website, and to ensure our websites and
    systems are secure.
  • Personalisation: Where the processing enables us to enhance, modify, personalise or
    otherwise improve our services/communications for the benefit of our
    supporters.

  • Analytics: To process your personal information for the purposes of customer
    analysis, assessment, profiling and direct marketing, on a personalised or
    aggregated basis, to help us with our activities and to provide you with the
    most relevant information as long as this does not harm any of your rights and
    interests.

  • Research: To determine the effectiveness of promotional campaigns and
    advertising and to develop our products, services, systems and relationships
    with you.

  • Due Diligence: We may need to conduct investigations on supporters, potential
    customers and business partners to determine if those companies and individuals
    have been involved or convicted of offences such as fraud, bribery and
    corruption.

Whenever we process data for these purposes we
will ensure that we always keep your Personal Data rights in high regard and
take account of these rights. You have the right to object to this processing
if you wish, and if you wish to do so please click here [<link to Subject Information Request>]. Please bear in mind
that if you object this may affect our ability to carry out tasks above for
your benefit.

6. What data does YGAM collect, how is it used and who has
access to it?

We may collect the following personal data:

What data is
collected?

 
Why is it
collected?
Who has access to
it?
 
Contact
Data (from our online forms, in person
and other digital communication including, but not limited to, email, phone
and mail)

 
NameAddressEmailMobileTelephone

 
Legal
basis
: Consent (or Legitimate Interest – see
Legitimate Interest section)

 
Marketing
 
YGAM may use your ‘contact data’ to send you
updates about workshops and training, as well as other relevant marketing
material we relevant to you.
 
Correspondence
 
YGAM may also use your ‘contact data’ to
contact you about any other updates within the charity we deem necessary or
in your interest.
 
Feedback
 
YGAM may use your contact data to ask for
feedback, or to issue surveys regarding our performance.
 
Maintenance
and Security

 
YGAM may use your contact data to email you
with regards to your YGAM Academy login details, and in regards to security
issues should they arise.
 
  Within YGAM all employees have access to contact data via our online CRM database. Our marketing campaigns our carried out by our approved third party processor, Kent Creative Design.  
 
Certification
Data

 
Contact data (as above)Date of Birth

 
Legal
basis
: Consent (or Legitimate Interest – see
Legitimate Interest section)
 

 
Certification

 
YGAM uses contact data and your Date of Birth
to certificate any practitioners who have been trained at our sessions and
have consented to being certificated.
 
 
Within YGAM, all employees have access to
certification data, the process is managed by our Head of Quality Assurance.
 
Certification data is also collected, stored
and processed by our approved third party processors, ASDAN and Pearson in
order to release certificates.
 
 
Website
Usage Data (from our analytics tracking
system
)

 
your IP addressgeographical locationbrowser type and versionoperating systemreferral sourcelength of visitpage views and website navigation pathsinformation about the timing, frequency and pattern of your service
use

 
Legal
basis
: Legitimate Interest
 

 
Website Analysis,
Development and Maintenance

 
YGAM may use your website usage data to:
Administer our website and
businessAnalyse web traffic to our website

 

 
Our website usage data is collected,
processed and stored by our approved third party processor, Kent Creative
Design.
 
You can find their details below in Section
7.
 
Transaction Data (from our online PayPal donation page,
other donations pages and from invoices sent out by employees)

 
Contact Data (as above)Your Card DetailsYour bank account detailsTransaction details

Legal
basis
: Consent

 
To process payments
and donations to YGAM

 
YGAM will use ‘transaction
data’ provided to process online donations and corporate/business donations
(by sending receipts/invoices/proposals).
 
YGAM may also use your
transaction data to send statements, invoices and payment reminders to you,
and collect payments from you
 
 
Within YGAM, only the CEO and employees authorised
by him/her and the Board of Trustees have access to your Transaction Data.
 
Contact
Data, card details, bank account details and transaction details are
processed by our approved third party processor, PayPal and Stephen Hill Mid
Kent to process your payments, refunding such payments and
dealing with complaints and queries relating to such payments.
 
You
can find their details below in Section 7.
 
YGAM
may also use your transaction data to send statements, invoices and payment
reminders to you, and collect payments from you
 

Recruitment Data (from our Careers Page Form)
 
NameEmail addressContact Telephone/MobileContact Details (from attached
CV/Covering Letter)Financial Details (if employed)

 
Legal
basis
: Consent and Legitimate Interest

 
To process
prospective candidate data for paid/volunteer employment or trustee positions

 
YGAM
will use ‘recruitment data’ to process applicants for paid/volunteer
employment and trustee positions
 
YGAM
will use your financial details (if employed) to process payments to you.
 
Within YGAM, your ‘recruitment data’ is
processed by the CEO, Head of Operations and other members of the Senior
Team, as authorised by the CEO and Board of Trustees.
 
Recruitment
data, is processed by our approved third party processor Stephen Hill Mid
Kent to process your payments, refunding such payments and
dealing with complaints and queries relating to such payments.
 
Recruitment
data, are processed by our approved third party processor Ropes and Gray LLP to
process applications and write up contracts.
 

7. Providing your personal data to others

YGAM is committed to ensuring the safe
collection, storage and processing of all personal data it collects. YGAM shall only engage with third party data processors
that are able to provide security, including technical, physical or
organisational security, to all personal data that they process on YGAM’s
behalf. 

The Data Protection Officer will ensure that a
full Privacy Impact Assessment (PIA) has been carried out on all third party
data processors before any personal data is transferred as per our Third Party
Access to Data Policy (DP3).

YGAM may disclose your information to third
party processors for the following reasons:

  • We may disclose your personal data
    to our insurers and/or professional advisers insofar as reasonably necessary
    for the purposes of obtaining and maintaining insurance coverage, managing
    risks, obtaining professional advice and managing legal disputes.

  • We may disclose your ‘contact’, ‘correspondence’ and
    ‘website usage’ data to our IT contractors (Kent Creative Design) insofar
    as reasonably necessary for the
    distribution of marketing material via email and analysis of web traffic.
    You can find our IT contractors’ privacy policies here: [http://www.kentcreativedesign.co.uk/privacy-policy/].

  • Financial transactions relating to small,
    public donations are handled by our payment services providers, PayPal and
    JustGiving. We will share transaction data with our payment services providers
    only to the extent necessary for the purposes of processing your payments,
    refunding such payments and dealing with complaints and queries relating to
    such payments and refunds]. Larger donations and accounts are handled by our
    accountants, Stephen Hill Mid Kent. You can find our payment services
    providers’ privacy policies and practices at [https://www.paypal.com/gb/webapps/mpp/ua/privacy-full], [https://www.justgiving.com/info/privacy] and  [http://www.stephenhillmidkent.co.uk/legal/privacy.php].

  • We may disclose ‘recruitment data’
    to our legal advisors, Ropes and Gray LLP during the recruitment and/or
    employment of employees. You can find our legal advisors’ privacy policies and
    practices at [https://www.ropesgray.com/en/footer/Legal-Notices/Privacy-Policy].
  • In addition to the specific
    disclosures of personal data set out in this section, we may also disclose your
    personal data where such disclosure is necessary for compliance with a legal obligation
    to which we are subject, or in order to protect your vital interests or the
    vital interests of another natural person.

YGAM does not use any
third party processors outside of the European Economic Area (EEA).

8. Retaining and deleting personal data

This section
sets out YGAM’s data retention policies and procedures, which are designed to
help ensure that we comply with our legal obligations in relation to the
retention and deletion of personal data.

Personal data
that we process for any purpose or purposes shall not be kept for longer than
is necessary for that purpose or those purposes.

We will retain
and delete your personal data as follows:

Website Usage Data
Contact and Correspondence Purposes
6
years
Training Certification (Contact Data)

(stored and processed by YGAM’s
certification partners, ASDAN and Pearson
)

7
years
Recruitment Data and HR Records 6
years
Transaction & Financial Records 6
years

9. Your rights

As per the General Data Protection Regulations, you, the data subject, have certain rights that you are free to exercise. We have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

i The right to access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

ii The right to rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

iii The right to erasure
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include:

  • the
    personal data are no longer necessary in relation to the purposes for which
    they were collected or otherwise processed
  • you
    withdraw consent to consent-based processing
  • the
    processing is for direct marketing purposes
  • the
    personal data have been unlawfully processed

However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].

iv The right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are:

  • you
    contest the accuracy of the personal data
  • processing
    is unlawful but you oppose erasure
  • we
    no longer need the personal data for the purposes of our processing
  • you
    require personal data for the establishment, exercise or defence of legal
    claims
  • you
    have objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, we may continue to
store your personal data. However, we will only otherwise process it:

  • with your consent
  • for the establishment, exercise or defence of legal claims
  • for the protection of the rights of another natural or legal person
  • for reasons of important public interest.

v The right to object to processing/profilingYou have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:

  • the
    performance of a task carried out in the public interest or in the exercise of
    any official authority vested in us
  • the
    purposes of the legitimate interests pursued by us or by a third party

If you make such an objection, we
will cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your interests,
rights and freedoms, or the processing is for the establishment, exercise or
defence of legal claims.

          Similarly,
you have the right to object to our processing of your personal data for direct
marketing purposes and to object to our processing of your personal data for
scientific or historical research purposes or statistical purposes on grounds
relating to your particular situation. If you make such an objection, we will
cease to process your personal data for this purpose, unless the processing is
necessary for the performance of a task carried out for reasons of public
interest.

vi The right to data portability
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

vii The right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

viii The right to withdraw consent
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights
in relation to your personal data by written notice to us using our Subject Information Request Form (DP7).

10. Cookies

YGAM’s
websites use cookies, a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored by the
browser. The identifier is then sent back to the server each time the browser
requests a page from the server.

Cookies
may be either “persistent” cookies or “session” cookies: a persistent cookie will
be stored by a web browser and will remain valid until its set expiry date,
unless deleted by the user before the expiry date; a session cookie, on the
other hand, will expire at the end of the user session, when the web browser is
closed.

Cookies
do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.

We use session
cookies
on our website.

Most
browsers allow you to refuse to accept cookies; for example:

  • in Internet Explorer (version 11)
    you can block cookies using the cookie handling override settings available by
    clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
  • in Firefox (version 47) you can
    block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use
    custom settings for history” from the drop-down menu, and unticking “Accept
    cookies from sites”; and
  • in Chrome (version 52), you can
    block all cookies by accessing the “Customise and control” menu, and clicking
    “Settings”, “Show advanced settings” and “Content settings”, and then selecting
    “Block sites from setting any data” under the “Cookies” heading.

Blocking all cookies will have a negative
impact upon the usability of many websites.

If you block cookies, you will not be able to
use all the features on our website.

You
can delete cookies already stored on your computer; for example:

  • in Firefox (version 47), you can delete
    cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use
    custom settings for history” from the drop-down menu, clicking “Show Cookies”,
    and then clicking “Remove All Cookies”; and
  • in Chrome (version 52), you can
    delete all cookies by accessing the “Customise and control” menu, and clicking
    “Settings”, “Show advanced settings” and “Clear browsing data”, and then
    selecting “Cookies and other site and plug-in data” before clicking “Clear
    browsing data”.

11. Our details

The data controller, and manager of this website, is
the Young Gamblers’ Education Trust.

We are a registered charity in [England and Wales] under registration number 116242.

We are registered at the Information Commissioner’s
Office (ICO) under registration number ZA125536

Our registered office is at:

71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

You can contact us:

  • by post, using the postal address
    above
  • using our website contact form
  • by telephone, on 0203 837 4963
  • by email, on hello@ygam.org (please note, if your request is
    for the Data Protection Office, please use the details at the top of this
    document).

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