Your privacy is important to us. To better protect your privacy, we provide this information explaining our information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available throughout the website and at every point where personally identifiable information may be requested.
Any questions relating to Data Privacy within Capstone Care Leavers Trust or this Policy should be sent by email to Maggie.firstname.lastname@example.org or by writing to Capstone Care Leavers Trust, 28 The Green, Kings Norton, Birmingham, B38 8SD. Alternatively, you can contact Maggie on 0121 374 2601.
This privacy notice tells you what to expect when the Capstone Care Leavers Trust collects personal information. It applies to information we collect about:
Visitors to our website
People who apply for a grant
Complainants and other individuals in relation to data protection
Visitors to our Website
When someone visits www.capstonetrust.org we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. The information is held for 26 months for statistical reporting purposes only. We do not make, and do not allow Google to make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
People who apply for a grant with the Capstone Care Leavers Trust
By applying for a grant with the Capstone Care Leavers Trust, we will need to capture and record information about you such as your name, date of birth, telephone number, email address, postal address, ethnicity for monitoring purposes, financial income and outgoings and brief history of your time in care and circumstances since leaving care.
All information will be captured in our online application database system which is a MySQL software solution provided by Webglu and will be held in line with our retention policy. Webglu are third party providers who manage our website and our database system. Our Website and database system are stored on servers in the UK with a company called Layershift.
We will use your consent to provide authorisation for us to share your information with organisations and referees to complete necessary checks in support of your application.
We will also collect and process the following data from you:
Information you consent to provide to Capstone Care Leavers Trust that is required to carry out our obligations arising from any contracts entered between you and us, or potential contracts that may be in liaison between you and us.
Information that you consent to provide by filling in forms on our website, or as part of any direct marketing or sales activities. This includes and is not limited to personal information about you such as your name, telephone contact number, geographical address/location, email address and interests.
If you contact us by telephone or in writing, we may keep a copy of your correspondence or communication.
If you have provided us with the personal data of another person, there is a clear requirement imposed by Capstone Care Leavers Trust for you to confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a Data Controller and the nature of the processing taking place. Records will be retained as evidence of this consent.
We use information held about you in the following ways:
Performance of a contract - We use information held about you to carry out our obligations arising from any contracts or agreements entered between you and us; and to notify you about changes to our services.
Legitimate Interests – We use legitimate interest as the basis for processing information relating to your application for a grant. For us to process a request we are required to obtain, store and process information on you as detailed in the application form that you complete and by way of reference information to verify the application.
Consent (Direct Marketing)- We will not send you direct marketing information neither will we share your data with third parties for other marketing purposes.
Our commitment to Data Security
To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect.
Your rights relating to Personal Data
Under the General Data Protection Regulations (GDPR) you have a number of ‘rights’ to ensure you are treated fairly by The Capstone Group.
The right of access – GDPR gives you the right to access information held about you. Your right of access can be exercised at any time. Capstone Care Leavers Trust operate both a Data Subjects Rights procedure and a Subject Access Rights Procedure to ensure that all rights exercised by data subjects relating to personal data are managed appropriately. You have the right to access personal information we hold on you by making a request in writing to your local office at any time
The right to rectification – If any of your personal data changes, or if you have any questions about how we use data which relates to you, please contact us in writing where we will ensure that we make the necessary rectifications
The right to erasure (The Right to be Forgotten) – You have the right to have your personal information erased and to prevent processing in some specific situations.
The right to restrict processing – you can request that we restrict processing your personal information, e.g. if you decide during the application process that you no longer want to continue with the application we will restrict processing but will continue to store your data in line with our retention policy.
The right to data portability – you have the right to request personal information that you have provided to us for your own purposes. To request information please contact us in writing.
The right to object to processing– once you have consented to us to process information with regards to your application you have the right to object to processing but we will continue to store your data in line with our retention policy.
Automated decision-making and profiling – Safeguards for individuals have been introduced by GDPR to protect against decisions being made without human intervention – the Capstone Care Leavers Trust does not use automated decision making or profiling in its work.
From time to time, our website may contain links to and from our strategic partner(s), partner network(s), strategic sponsor(s), advertiser(s) and affiliate(s). If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Retention of your information
Capstone Care Leavers Trust operate a clear Retention policy and associated Retention Schedule to ensure personal data is kept only for so long as is necessary for the purpose for which such information is used.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, strategic partner(s) or strategic sponsor(s) our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.
As part of our GDPR compliance obligations, we are duty bound to check when personal data may be shared with third parties to ensure that they apply the same or greater controls in terms of data protection. The use of non-disclosure agreements form part of our third-party data sharing controls.
We may disclose your personal information to third parties
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets; or
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply other agreements; or
to protect the rights, property or safety of Capstone Care Leavers Trust, our customers or others.
Capstone Care Leavers Trust has risk assessed where personal information may be transferred outside the EEA. As part of our own due diligence we have identified that personal data held for and by Capstone Care Leavers Trust resides in the EU. We will continue to monitor this considering any 3rd party provider changes in the future. Should a requirement for data to be transferred outside of the EU in future, Capstone Care Leavers Trust will implement controls and safeguards to ensure that equal to or greater data protection measures are enforced and records retained to evidence this.
Making a Complaint
If you are not happy with the way that Capstone Care Leavers Trust has handled collecting and using your personal information and you want to make a complaint you can contact us by sending an email to Maggie.email@example.com or by writing to Maggie at Capstone Care Leavers Trust, 28 The Green, Kings Norton, Birmingham, B38 8SD.
Alternatively, or if you are not happy with our response to your complaint, you can contact the Information Commissioners Office directly to report a concern on 0303 123 1113 or via their website which is https://ico.org.uk/concerns