1of7May2018,CBF Privacy Policy,Please read this Privacy Policy carefully to understand our practices ,regarding your personal data and how we will collect, use and store your ,personal data.We may update this policy from time to time so please check ,it regularly.,We are committed to protecting the privacy of your personal data.
We will respect ,any personal data you share with us and keep it safe.
We aim to be clear when we ,collect your personal data and not do anything you wouldn’t reasonably expect.
We ,nevershare or sell your data with any 3parties who may use it for their own ,rd,purposes.
,This policy is intended to inform you how and why The Challenging Behaviour ,Foundation uses personal data.
When we refer to “we” or “us” in this policy we are ,referring to The Challenging Behaviour Foundation.,Who we are: The Challenging Behaviour Foundation (CBF)isa registered charityin ,England and Wales(No 1060714) for people withsevere learning disabilitiesand ,behaviours described as challenging and their families.Our vision is for anyone with ,severe learning disabilities who displays challenging behaviour to have the same life ,opportunities as everyone else.We work toimprove understanding of challenging ,behaviour, empower families with information and support, and help others to ,provide better services and more opportunities.,Why do we collect Data:We will use your personal information to provide you ,with the services, products or information you have requested.
We also collect and ,store data to help us improve our servicesto you.
We can record your ,communication preferences and keep you up to date with latest research, ,resources and information, fundraisingevents and sharing best practice.
We can ,tailor our invites to take part in surveys, focus groups, research or eventsthat are ,relevant to you.
We also use our anonymised data statistics to support our ,campaigning and influencing work and in funding applications.,How we collect Data:,Direct contact with the CBF-Email/phone/post,•We will collect and record personal information about you that you voluntarily ,provide whencontacting the CBF.
Due to the type of support we provide we ,may collect and use special categories of personal sensitive data about you ,or a 3party you may tell us about (for example, information about a learning ,rd,disability diagnosis, challenging behaviour being displayed, health, ,safeguarding, ethnic origin etc.).
We do not use a caller display system so ,we cannot identify or use your telephone number unless you provide it to us.
,2of7May2018,This information is treated as confidential and for the purposes of providing ,support and internal analysis (for example trends in enquiries).
,•We may share your information, with your consent, to other professionals we ,work with as part of our service to you.
This will always be with your explicit ,agreement.
The exceptions to this are if there isa safeguarding concern or ,we are bound by lawand in these circumstances we will still seek to gain your ,consent first,but if you choose not to consent we must follow our ,safeguarding policy or legal obligations.
A copy of our safeguarding policy ,can be providedon request.,•If you sign up to join a support or campaigning network (for example CB-NSG ,associate membership) we will record your name, job title (if relevant) and ,email address.
We do not sign people up to our networks without consent.,•We may also collect information voluntarily provided such as requests for ,resources or attending an event.
,•If you send a queryor complaint to us, we will use the personal information ,you provide to us (for example, your name and the name(s) of any other ,individuals involved) in order to process your query or complaint and ,respond to you.A copy of our Complaints Policy can be provided on ,request.,•We are sometimes required to collect personal sensitive information to ,satisfy the terms of a funding grant, for example, age, ethnic background, if ,English is the first language.,•We neverbuy or sellpersonal dataor use it for automated decision making ,or profiling.,•We will gain permission/consent to use any photo/image used in our work ,(for example on our website or in publications).
,•By providing us with your personal data, including sensitive personal data ,such as your age or ethnic background, you consent to the collection and ,use of any information you provide in accordance with the purposes in this ,privacy statement.,If your personal details change, please help us to keep your information up to date ,by notifying us.
You can do this by emailinginfo@thecbf.org.ukor telephoning 01634 ,838739,Website: ,•We will collect personal information that you voluntarily provide us if you fill ,in a contact form on our website, such as your name, email address or ,telephone number.
This is treated as confidential information,•Your email address will never be sold to 3parties or spammed,rd,•Collecting Domain Information: we use a 3party service, Google Analytics, ,rd,to collect standard internet log information and details of visitor behaviour ,patterns.
The CBF also collects domain information (e.g.
IP address and ,3of7May2018,referring URL’s) as part of its analysis of the use of the website.
This data ,enables us to become more familiar with how people visit our site, how often ,they visit and what parts of the site they visit most often.
This information is ,collected automatically and requires no action on your part.This information ,is only processed in a way which does not identify anyone.
We do not make, ,and do not allow Google to make, any attempt to find out the identities of ,those visiting our website.
,•Use of Cookies*: Some pages on our website use “cookies” which are small ,files that the site places on your hard drive for identification purposes.
,These files may be used for site registration and customisation the next time ,you visit us, and to make navigating the website more user-friendly.
,*A cookie is a piece of data that a website can send to your browser, which may ,then be stored on your computer as an anonymous tag that identifies your ,computer but not you.
You should note that cookies cannot read data of your ,hard drive.
Your web browser may allow you to be notified when you are ,receiving a cookie, giving you the choice to accept it or not.
By not accepting ,cookies, some pages may not fully function and you may find it harder to access ,certain information on the website.,•We collect relevant information through the 3party organisation “PayPal” ,rd,when you purchaseresources through our website.This information is ,treated as confidential and never passed on.,Researchand evaluation:We use a 3party provider, SurveyMonkey, to ,rd,carry out surveys for researchand evaluationpurposes.
The information ,gathered will be provided by you voluntarily and used only for purpose for ,which it was obtained.
We may share the findings of the researchor ,evaluationwith other organisations but data will be anonymised and individuals ,will not be identifiable.You may be asked to provide contact details for any ,follow up discussions which will be shared on a need to know basis within the ,CBF or evaluation/research teams.
Case studies will be anonymised unless ,you have givenus consent to use your name.,Direct engagement/focus groups,Sometimes as part of specific projects or to inform consultations we run focus group ,or engagement activities to better understand the views, experiences and ,perspectives of families and individuals with severe learning disabilities.
The aim of ,such work is to inform policy making through lived experience.
Such discussions ,necessarily involve sharing individual experiences and personal, or difficult ,experiences which will be written up and sharedwith policy makers.
Families who ,agree to take part are made aware that any experiences shared outside of the room ,will be anonymised unless families explicitly ask to be named (for exampleto secure ,a direct response from a statutory organisation to the problems they are ,4of7May2018,encountering).
Consent will be gained for direct engagement with individuals with a ,learning disability using our consent policy which includes best interest meetings if ,needed.,Fundraising:Charitable giving is very important to CBF’sability to achieve its ,aims.
We collect and record information voluntarily provided to us through:,•Online Giving –Virgin Money Giving,•100 Club applications,•Recording one off donations,•Standing order/regular giving donations,•Event sign-up &.
supporters news (for example quiz nights),•Gift Aid declarations,Training Workshops:We will record your name, job title (if relevant) and email ,address to keep you up-to-date with workshop information and to record your ,attendance at a workshop.
You may additionally choose to sign up to support ,networks and our newsletter.,Recruitment &.
Volunteering:If you apply for a job/vacancy,including casual ,work and volunteering at the CBF, we will retain the application and scoring ,sheets for one yearafter which they will be destroyed.
If you are selected for ,interview we will retain photocopies of your ID and qualifications (if relevant) ,until a decision on recruitment is made.
If unsuccessful following aninterview, ,yourID, certificate of qualificationsand any references obtainedwill be ,destroyed immediately.
If successful they will be held on your employment ,record which will be retained for a minimum of 6 yearsafter you cease working ,with us.
With your consent we may retain your details for further employment ,opportunities.
Equal Opportunities and Monitoring information provided by ,applicants and staff maybe stored for up to two years andpresented to the ,Trustee Board as anonymised data then destroyed.,Working with the CBF:If you are employed, a free-lance consultant, casual ,worker or volunteer, we will hold personal data for contractual, internal and ,financial reasons.
For example, we require your bank details in order reimburse ,expenses and pay wages.
We will delete your bank details immediately but ,retain relevant personal data for a minimum of 6 years after you cease working ,with us.We will abide by the DBS Code of Conduct when disclosures and ,basic checks are carried out.,Supplier information (providing goods/services):Where the CBF uses 3party ,rd,suppliers to deliver some of our internal services (for example, IT &.
HR support), we ,will ensure there is a signed confidentiality agreement in place and these suppliers ,only access the information to explicitly assist the CBF.
,5of7May2018,GDPR Principles,The following principles are complied with when processing personal data:,•Data is processed fairly and lawfully,•Data is processed only for specified and lawful purposes,•Processed data is adequate, relevant and not excessive,•Processed data is accurate and, where necessary, kept up to date,•Data is not kept longer than necessary,•Data is processed in accordance with an individual’s consent and rights,•Data is kept secure,•Data is not transferred to countries outside of the European Economic Area ,(EEA) without adequate protection,Lawful Basis of Processing Data:The lawful basis of processing of data will ,always be determined prior to any data being processed.
The laws for processing ,personal data under the GDPR are as follows:,•Consent –the individual has given their Consent to the processing of their ,personal data,•Contractual –processing of personal data is necessary for the performance ,of a contract to which the individual is a party, or for CBF to take pre-,contractual steps at the request of the individual,•Legal Obligation –processing of personal data is necessary for compliance ,with a legal obligation to which CBF is subject,•Legitimate Interests –processing of personal data is necessary under the ,Legitimate Interests of CBF, unless these interests are overridden by the ,individual’s interest or fundamental rights,•Public Task–processing of personal data is necessary for the performance ,of a task carried out in the public interest or in the exercise of official authority,•Vital Interests –processing of personal data is necessary to protect the vital ,interests of the individual or another individual,CBF processes personal data under one, or more, of the following Lawful Bases:,•Consent,•Contractual,•Legal Obligation,•Legitimate Interest,Data security,•We have appropriate security measures in place to prevent your personal ,information from being accidentally lost, used or accessed in an unauthorised ,way, altered or disclosed.,6of7May2018,•We hold data electronically in our secure database and document ,management system.We protect our network infrastructure byusing firewalls ,and anti-malware software.
We encrypt data leaving the CBF on removable ,media and email, using industry standard encryption method that encrypts the ,data in transit.
,•We store papers in lockable cabinets in our offices when not being actively ,used and we have a secure off-site document storage facility for archived ,papers.
Our offices are secure and only CBF staff can access areas where ,personal data are stored.,•When necessary, we dispose of or delete your data securely.,•We ensure that our employees, and contractors are aware of their privacy and ,data security obligations and we take reasonable steps to ensure that ,employees of 3parties working on our behalf are aware of their privacy and ,rd,data security obligations.,•We limit access to yourpersonal information to those employees and other 3,rd,parties on a need to know basis.Access to family support enquiries and ,subsequent personal sensitive data is restricted to the Family Support Team.
,•The transmission of information via the internet isnever completely secure.
,Although we will do our best to protect your personal data, we cannot ,guarantee the security of your electronic information transmitted to us and any ,transmission is at your own risk.,•We do not transfer the information you give usto countries outside the ,European Economic Area (EEA).,Data retention-Personal data processed for any purpose or purposes shall not be ,kept for longer than is necessary for that purpose or those purposes it was obtained ,for in the first place, or by as required by law (for example, tax and audit purposes).,We review the personal data (and the categories of personal data) we are holding on ,a regular basis to ensure the data we are holding is still relevant to the CBF is ,accurate.
If we discover that certain data we are holding is no longer necessary or ,accurate, we will take reasonable steps to correct or delete this data as may be ,required.,Individual’s right to access:Under certain circumstances, by law individualshave ,the right to:,•access their personal data, commonly referred to as subject accessrequests.,This enables you to receive a copy of the personal information we hold about ,you and to check that we are lawfully processing it.,•ask us to correct any information that we hold about you which is incorrect, ,incomplete or inaccurate,•ask us to erase your personal information from our files and systems where ,there is no good reason for us continuing to hold it,7of7May2018,•object to us using your personal information to further our legitimate interests ,(or those of a 3rdparty) or where we are using your personal information for ,direct marketing purposes,•ask us to restrict or suspend the use of your personal information, for ,example, if you want us to establish its accuracy or our reasons for using it,•ask us to transfer your personal information to another person or organisation,•If you have given your consent to us processing your personal information (for ,example, consent to receive information about our seminars and events), you ,have the right to withdraw your consent at any time.
To withdraw your ,consent, please contactinfo@thecbf.org.uk.
Once we have received notification ,that you have withdrawn your consent, we will no longer process your ,personal information and,subject to our retention policy, we will dispose of ,your data securely.,•Individuals can make a subject access request verbally or in writing.,•We will follow the guidance from theInformation Commissioners Office,•To make a subject access request you should email: info@thecbf.org.ukor ,telephone 01634 838739,Reporting Concerns: If you have a complaint or concern about the CBF’s ,information rights practices you can report it to the Information Commissioners Office,(ICO),the UK supervisory authority for data protection issues.You can call their ,helpline on 0303 123 1113 or visit their website https://ico.org.uk/concerns/for ,further information.
,Details of person in charge of GDPR at CBF:If you have any questions about ,how your data is handled and stored then please contact Helen Marron, ,helen@thecbf.org.ukor telephone 01634 838739