1. INTRODUCTION

1.1 At GSAP we are committed to respecting and safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.3 This privacy policy was last updated on 15th May 2018

1.4 We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.

  1. CREDIT

2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).

  1. WHO ARE WE?

3.1 GSAP is a core community support agency operating across Galliagh, Shantallow, Skeoge, Carnhill, Culmore, Pennyburn, Ballynashallog and the wider Derry City & Strabane District Council Area. We work with local residents, community/voluntary sector groups and statutory/private organisations to help improve the social, community, economic and physical regeneration of the area.

3.2 GSAP is a registered Charity (NIC 100209) and Company Limited by Guarantee (NI 34587) and our registered address is Unit C3 & C4 Northside village Centre, Glengalliagh Road, Derry, BT48 8NN.

  1. HOW WE COLLECT PERSONAL DATA

4.1 We only collect information that we need or that helps us to provide the best possible service and fulfil our charitable aims and objectives.

4.2 In this Section 4 we have set out how we collect personal data from you:

* When you visit our site www.shantallow.net and create a user account

* When you register to attend an event, programme, seminar or training/education programme

* When you subscribe to GSAP monthly newsletter

* When you make a donation online

* When you contact us for advice and support

* When you contact us about products and services

* When you request information from our services team, for example A Talking to our Babies Resource pack.

* When you take part in online surveys, questionnaires or get involved with our campaigns

* When you make a purchase of a product from our online shop

* When you make a payment to confirm a booking.

* When you contact us to make an enquiry about a service

* When you contact us to apply for GSAP affiliated C/V group membership

* When you complete an online evaluation form on the service you received from GSAP

* Contact us or become involved with us in any other way not listed above.

  1. HOW WE USE YOUR PERSONAL DATA

5.1 In this Section 5 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

5.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

5.3 We may process your account data ("account data"). The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, processing a booking for an event and/or programme or registering for our newsletter, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

5.4 We may process your profile data ("profile data"). The profile data may include your name, email address, address, telephone number, email address, profile pictures, gender, date of birth, and social media ids. The profile data may be processed for the purposes for enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

5.5 We may process information relating to transactions, including processing a donation that you made, processing sponsorship that you made or purchases of goods or services,  that you enter into with us through our website (“transaction data”).  The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.  The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

5.6 We may process information contained in any enquiry you submit to us regarding products and/or services or information contained in or relating to any communication that you send to us ("enquiry data and correspondence data"). The enquiry data may be processed for the purposes of dealing with enquiries on programmes, events, marketing and selling relevant products and/or services to you. The correspondence data may be processed for the purpose of communicating with you, sending you communications which you have requested and that may be of interest to you such as information about campaigns, programmes, support available, seminars, volunteer, training and employment opportunities and record keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

5.7 We may process information that you provide to us for the purpose of subscribing to our newsletter (“notification data”). The notification data may be processed for the purposes of sending you the relevant notification and/or newsletter. The legal basis for this processing is consent.

5.8 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

5.9 In addition to the specific purposes for which we may process your personal data set out in this Section 4, we may also process any of your personal data where such processing 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.

5.10 Please do not supply any other person's personal data to us, unless we prompt you to do so.

  1. PROVIDING YOUR PERSONAL DATA TO OTHERS

We will not sell or rent your information to third parties.

We will not share your information with third parties for marketing purposes.

6.1 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 or obtaining professional advice and managing legal disputes.

6.2 We may disclose your personal data contact details to our third party service providers and other associated organisations for the purposes of completing tasks and providing services to you on our behalf  for example to secure your place on a specific programme, event or service requested by you. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own marketing purposes.

6.3 When you are using our secure online payment and donation pages, your payments and donations are processed by third party payment processors who specialise in the secure online capture and processing of credit/debit card transactions. Financial transactions relating to our website and services are handled by our payment service providers, Stripe, GoCardless and Paypal. We will share transaction data with our payment service providers only to the extent necessary for the purposes of processing your payments, refunding such repayments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment service providers privacy policies and practices at:

Stripe (URL https://stripe.com/gb/privacy)

GoCardless (URL https://gocardless.com/legal/privacy/)

Paypal (URL https://www.paypal.com/ie/webapps/mpp/ua/privacy-full)

6.4 Your data may also be available to our website service provider “Raising IT” to enable us and them to deliver their service to us, carry out analysis and research on demographics and behaviour of our users and supporters to help us gain a better understanding of them to enable is to improve our services. Your personally identifiable data will only be used where necessary for the analysis required and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:

a) Your data will be made available to our website provider ‘Raising IT’

b) The data that may be available to them include any of the data we collect as described in section 4 above.

c) Our website provider will not transfer your data to any other third party or transfer your data outside of the EEA.

d) They will store your data for a maximum of [7] years.

e) This processing does not affect your rights under section 12 or 16 of this privacy policy.

6.5 In addition to the specific disclosures of personal data set out in this Section 6, 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.

  1. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

7.1 Our website provider ‘Raising IT’ do not transfer data outside of the EEA. The hosting facilities for our website provided by Raising IT are situated in Ireland and Amsterdam. Transfers to each of these countries will be protected by appropriate safeguards, namely adherence to the GDPR.

7.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

  1. RETAINING AND DELETING PERSONAL DATA

8.1 This Section 8 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

8.2 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 apply our retention schedule when we no longer require personal data and ensure its secure deletion or disposal. We will make sure that we don’t collect more personal information than we need in order to carry out our activities and we will review our practices regularly.

8.3 When we use third party services to process personal data we will take due diligence to make sure that they are reputable and have appropriate data protection practices.

8.4 Notwithstanding the other provisions of this Section 8, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject (for example invoices, payment information, job application), or in order to protect your vital interests or the vital interests of another natural person.

  1. AMENDMENTS

9.1 We may update this policy from time to time by publishing a new version on our website. The date this policy was last updated is given in paragraph 1.3.

9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

9.3 We may notify you of changes to this policy by email.

  1. YOUR RIGHTS

10.1 In this Section10, 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.

10.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

10.3 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.You can access your profile data and adjust your privacy settings by visiting www.shantallow.net 'My Details' when logged into the website.

10.4 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.The accuracy of your information is important to us. If you change email address or any other information we hold is inaccurate or out of date please email us at:[email protected] or write to us at GSAP, Unit C3 & C4 Northside village Centre, Glengalliagh Road, Derry, BT48 8NN. Alternatively, you can telephone 02871358787.

10.5 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; and 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.

10.6 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, but you require personal data for the establishment, exercise or defence of legal claims; and 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; or for reasons of important public interest.

10.7 You 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; or 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.

10.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

10.9 You have the right 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, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

10.10 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.

10.11 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.

10.12 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.

10.13 You may exercise any of your rights in relation to your personal data by written notice to us.

  1. THIRD PARTY WEBSITES

11.1 Our website includes hyperlinks to, and details of, third party websites.

11.2 This privacy policy only governs our website and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them.  If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data.

11.3 We operate a number of social media pages (including Facebook, Twitter, YouTube and Instagram).  Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information.  Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

  1. PERSONAL DATA OF CHILDREN

12.1 We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under, please get your parent/guardian’s permission beforehand whenever you provide us with personal information.

  1. UPDATING INFORMATION

13.1 Please let us know if the personal information that we hold about you needs to be corrected or updated. (See section 17 for contact details)

  1. ABOUT COOKIES

14.1 A cookie is 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.

14.2 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.

14.3 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.

  1. COOKIES THAT WE USE

15.1 Our service provider for the website ‘Raising IT’ use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

The list of cookies that Raising IT have automatically set on our website have the following names: (_ga,_gid,_gat,_utma,_utmt,_utmb,_utmc,_utmz and _utmv).

  1. MANAGING COOKIES

16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

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

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

  1. OUR DETAILS

17.1 This website is owned and operated by GSAP

17.2 You can contact us:

(a) by post, using the postal address given below;

Unit C3 & C4 Northside village Centre, Glengalliagh Road, Derry, BT48 8NN.

(b) using our website contact form;

(c) by telephone, on the contact number published on our website from time to time (02871358787); or

(d) by email, using the email address ([email protected]) published on our website from time to time.

  1. COMPLAINTS

18.1 You have the right to lodge a complaint with the Information Commissioner’s office which enforces data protection laws: https//ico.org.uk/concerns