Your information and how Insight looks after it
Insight Gloucestershire is the Data Controller.
Insight’s Head Office is registered at: Low Vision Centre, 81 Albion Street, Cheltenham, Gloucestershire, GL52 2RZ.
Insight stores and processes your data for the purpose of providing our services to our clients so that we are able to offer accurate and tailored advice. Insight Gloucestershire uses ‘Legitimate Interests’ as our legal basis for storing and processing client, supporter and volunteer data. For some clients, we will also process and store special category data under Article 9, (2) (d).
Insight makes sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection law. Our legitimate business interests do not automatically override your interests; Insight will not use your personal data for activities where our interests are overridden by the impact it would have on you. You have the right to object to the processing of your personal data at any time.
How we contact you is led by your wishes, for example, as a client, you may wish to have an annual review call, receive our magazine on CD, fundraising updates via post and Resource Centre information (new products and events) via email.
If you have any questions or concerns about how we use your personal data please ring the Insight Helpline on 01242 22 11 70 or send an email to email@example.com.
Insight takes the security of your data and its data protection responsibilities seriously. Your data is held on secure servers within the UK and does not leave the EEA for any reason. These servers are managed by third parties contracted by Insight. Namely GCC Innova Ltd. Insight also has wider IT support provided by ADT Systems Ltd.
Information that Insight collects and stores
Insight processes and records both personal and special category personal data to the extent necessary:
- to enter into or perform a contract with you (for example, to provide services to our clients) It is not compulsory for people to provide their special category data (such as eye condition) but this information does help to inform the advice that we offer people.
- to comply with a legal duty such as financial record keeping
- for our own legitimate interests, (for example, internal record keeping, or to manage the Insights Supporter experience or your volunteer role) provided your rights don’t override these interests.
- We do not use special category data for fundraising purposes.
The personal data Insight holds will come from you or a third party that you have asked to contact Insight on your behalf.
We will not share your data with any third parties who might use it for their own purposes without your prior permission e.g. we may speak to the Adult Helpdesk on your behalf and as ever we will record this interaction on your record.
We may in extreme circumstances rely on vital interest (Article 6 (1) (d)) to pass on your details if we feel that there is a safeguarding concern or immediate threat to life. Please see Insights safeguarding policy.
The personal data we hold will include – names, addresses and other alternative contacts (for example if you wish for us to ring someone else on your behalf)
Special category personal data may include – details about your eye health, eye conditions and registration if you have given this information to us. This information will have been given to us by yourself or someone referring you to our services. We will process this data under Article 6 (f) (Legitimate Interest) and Article 9 (d) of the GDPR.
We do record details of what Insight staff (inc. Volunteers) have discussed with you and any actions that they have taken, for example after you have rung the Helpline. Where applicable we keep electronic copies of referrals that we have received from other organisations that have asked us to contact you directly. We also keep an electronic record of letters and emails we have sent to you. We process and store this data under legitimate interest.
As part of the data we hold for all clients, it will include how and what information you wish to receive from us. We will also retain any consent preference forms in electronic format once we have processed your requests. There may be a short delay between receiving your request and being able to action it. Your paper copy will be destroyed once it has been scanned into the database. You can change your communication preferences at any time by ringing the Insight Helpline on 01242 22 11 70 or sending an email to firstname.lastname@example.org.
Insight is fortunate to have a number of volunteers. Their records are both electronic and paper-based. We record both personal and special category data under the rules of Legitimate Interest.
We record and retain the nature of the Volunteer’s role, details of the volunteers DBS check and other recruitment paperwork contact details and interactions between volunteers, staff and clients.
Your record will be deleted two years after you stop actively volunteering for us.
Insight believes that if people are able and willing to donate to Insight they will – without being bombarded with constant requests. Insights Fundraiser has a duty to seek funding from a variety of sources to ensure that Insight can keep offering its support to people living with sight loss. Requests to our Clients are infrequent but the responses to these appeals are valued.
Our fundraiser will acknowledge your donation or contact you about the administration of donations, gift aid or 200 club membership under legitimate interest.
They will only contact you again in the future if you have given your consent to say that you are happy to receive fundraising requests in your preferred format. You can withdraw this consent at any time.
Before we send any fundraising appeals to Insight clients we do screen records to ensure there is no indication that the client may not be able to make an informed choice due to a vulnerable circumstance such as living in a nursing home or having issues with memory. Insight also aims to ensure that it is sending appeals to clients that wish to receive them.
You can change these and any of your communication preferences at any time just by ringing the Insight Helpline on 01242 22 11 70 or sending an email to email@example.com.
Insight always wishes to say thank you to Insight Supporters. As a small local charity, Insight relies on donations to keep Insight services open for now and in the future
For Insight Supporters we will hold records that include your personal data (for example, your name, address, email address, telephone number). We will also record how and when you have donated, signed up to the 200 Club or set up a standing order. . This information is recorded under Legitimate Interest.
Insight does not share Supporter information with any third parties who might use it for their own purposes.
Many of Insight clients are also Supporters and Insight will record your donation details to supplement your Client record. This information is recorded using Legitimate Interest as our legal basis. If it the first time you have donated to Insight we may ask you if you wish to consent to further updates about Insights fundraising activity if we do not already have your preferences.
As part of the data we hold for all Supporters, it will include information about how and what information you wish to receive from Insight. You can change your communication preferences at any time just by ringing the Insight Helpline on 01242 22 11 70 or sending an email to firstname.lastname@example.org.
How to view your records that we hold about you (known as subject access request)
You have the right to request to see the information that we hold about you and have any inaccuracies corrected. If you would like to use this right please ring Insight Helpline on 01242 22 11 70 or send an email email@example.com.
Your right to be forgotten
If you wish we can delete your record. If you request this it will mean that should you contact Insight again in the future our staff will not be able to see how we have tried to help in the past. Please contact the Insight Helpline on 01242 22 11 70 or send an email firstname.lastname@example.org
Please note that this right to be forgotten will not cover all data we hold for you, for example, copy invoices of products you have purchased have to be kept for seven tax years.
Your right to object/stop processing
If you wish, you have the right to let us know that you no longer wish us to process your data. This will mean for example that we would not contact a client for a review call or send them a magazine in their preferred format. If a Volunteer wishes us to stop processing their information then they will also need to stop volunteering for Insight.
Maintaining Insights Database accuracy
You have the right to have inaccurate data rectified. Please contact the Insight Helpline on 01242 22 11 70 or send an email email@example.com.
From time to time Insight may contract a third party agency (Data-8) to screen our database records so that we can remove records that are no longer accurate.
For example, if database records are returned saying the occupier has moved away we will deactivate these records. Should you contact us within 12 months after we have deactivated your record we can reinstate your old record and update your contact details.
From time to time we may write to you requesting an update to your communication preferences to ensure that we are contacting you in your preferred format.
If any emails bounce back, the email address will be deleted from your record.
If we try to ring you and the number comes up as ‘unattainable’ we will delete the number from your record. In most instances, we will then send you a letter.
If post is returned to us marked ‘addressee unknown’ or ’ no longer at address’ we will deactivate your record.
12 months after the record deactivation your record will be permanently deleted and we will not be able to reinstate it.
What to do if you have any questions or concerns
There are exceptions to the rights above and, although we will try to respond to your satisfaction, there may be situations where we are unable to do so.
In the first instance please contact Steve Martin on 01242 22 11 70 or email firstname.lastname@example.org.
If you are not happy with Insight response to your concern you can contact The Information Commissioners Office (ICO) via their website www.ico.org.uk or phone the ICO on 0303 123 1113.
Changes to this policy