PRIVACY POLICY

1. The Policy:

This privacy policy notice is served by 15 Square, Charity Hub, First Floor, 69 High Street, Stone, Staffordshire ST15 8AD under the website; www.15Square.org.uk. The purpose of this policy is to explain to you how we control, process, handle and protect your personal information through 15 Square and while you use our services. If you do not agree to the following policy you may wish to refrain from submitting your personal data to us or viewing the 15 Square website. The management of consent is covered in our GDPR Policy, and further privacy issues can be found within our Cookie Policy.

2. Policy Key Definitions:

“I”, “our”, “us”, or “we” refers to 15 Square.
“You”, “the user” refer to the person(s) using our website or services.
GDPR means General Data Protection Act.
PECR means Privacy & Electronic Communications Regulation.
ICO means Information Commissioner’s Office.
EMS means Express Mail Service (email).
Cookies mean small files stored on a user’s computer or device.

3. Key Principles of GDPR:

Our privacy policy embodies the following key principles;

a. Lawfulness, fairness and transparency
b. Purpose limitation
c. Data minimisation
d. Accuracy
e. Storage limitation
f. Integrity and confidence
g. Accountability

4. Processing of Your Personal Data

Under the GDPR (General Data Protection Regulation) we control and process any personal information about you electronically using the following lawful baseis.

• We are exempt from registration in the ICO Data Protection Register due to the contingency made for exemption for ‘not-for-profit’ organisations.

• Lawful basis for our data processing: Consent, legal obligations, vital interests, public tasks, legitimate interests, special category data, criminal offence data.

• Where our purpose for processing is: Contacting members and interested parties, retaining email content for data analytics, sending updates and complying with legal obligations.

• Which is necessary because: We require correspondence addresses to share information that may find useful with regards to 15 Square and our work. This is vital to our services as we provide information requested by correspondents, or information that may be useful to them. We use data analytics to improve our services, and to ascertain the prevalence of certain issues and the quality of information provided by doctors.

• We process your information in the following ways: We record email addresses and written addresses for paper members. These are recorded on a database for the purpose of correspondence. We also extract data from emails and record these in an anonymous separate database so that identifying information is removed.

• Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.

• Sharing your information: We do not share your information with third parties or individuals unless explicit permission is requested by you personally.

5. Changes to the legal basis

If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.

6. Individual Rights

Under the GDPR your rights are as follows. You can read more about your rights in details at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

• the right to be informed;

• the right of access;

• the right to rectification;

• the right to erasure;

• the right to restrict processing;

• the right to data portability;

• the right to object; and

• the right not to be subject to automated decision-making including profiling.

You also have the right to complain to the ICO at www.ico.org.uk if you feel there is a problem with the way we are handling your data.

We handle subject access requests in accordance with the GDPR.

7. Internet Cookies

We use cookies on this website to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen particular messages that we display, to keep you logged into the website where applicable, to display relevant adverts or content, referred you to a third party website.

Some cookies are required to enjoy and use the full functionality of the 15 Square website.

We use a cookie control system which allows you to accept the use of cookies, and control which cookies are saved to your device / computer. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options. In addition to those set out below, we have a dedicated Cookies Policy, which has comprehensive reasons for use of cookies as well as greater details.

Website cookies that we use are;

8. Data security and protection

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement, and more details can be found in our GDPR Policy.

9. Fair & Transparent Privacy Explained

We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.

10. Sponsored links, affiliate tracking & commissions

Our website may contain external links to other web pages. These may include cookies and tracking tools of their own and are not covered under the 15 Square Privacy Policy. For details on this, please read the GDPR Policy and our Cookies Policy.

11. Email marketing messages & subscription

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. You can read more in our GDPR Policy.

Email messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time by simply replying to the origin email with a request. Where applicable, some email campaigns will have a clickable option to unsubscribe.

When using an EMS (Express Mail Service), the provider is; Mail Chimp. We hold the following information about you within our EMS system;

• Email address

• I.P address

• Subscription time & date

You may request that this data be deleted, or by clicking unsubscribe you are withdrawing consent from contact, resulting in this data being deleted.

12. Other General Principles

Requests for medical advice or support will be forwarded within 15 Square to a doctor or other specialist who has the knowledge to help with the enquiry.

Personally identifiable information will be held in accordance with the 15 Square Data Security Procedures.

Some enquiries will be made anonymous and retained in a form which is not personally identifiable.

Correspondence which is received and has been made anonymous by removal of identifiable data may be passed on to trustees, helpers or researchers for use in research, training or the development of policy.

13. How to Make Data Access Requests

Anyone who requires details of the data held upon them may request a copy of their data. When a request – known as a Subject Access Request is made, 15 Square will supply the data held within 40 days. Requests should be submitted to info@15square.org.uk or in a letter to the address given on our website.