The Warrior Programme (TWP) Privacy Notice
This privacy notice sets out the data processing practices of TWP for personal information in electronic and manual form.
- Who are we?
- Your personal information – what is it?
- How do we process your personal information?
- The purposes for which we use your personal information
- What is the legal basis used by TWP for processing your personal information?
- Sharing your personal information
- How long do we keep your personal information?
- Your rights to your personal information
- Transfer of your personal information
- Updates to this notice
- Other websites
- Contact Details
1. Who are we?
The Warrior Programme is a company limited by guarantee (no. 6263721) and a registered charity (no. 1120893) registered in England and Wales. We provide help and support to veterans and their families through courses and other activities. We are the organisation that decides how your personal information is processed and for what purposes when you provide it to us or we otherwise collect it. Under data protection law, we are a controller. Our contact details are The Warrior Programme, First Floor, 1 Thorpe Close, London W10 5XL, and firstname.lastname@example.org and 08088 010898
2. Your personal information– what is it?
Personal information relates to information about a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession, or likely to come into such possession. So it includes a person’s name and email address but can also include an IP address. From 25 May 2018, the processing of personal information in the UK is governed by the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
3. How do we process your personal information?
TWP complies with its obligations under relevant legislation. This means that, where necessary, we keep personal information up to date; we put in place measures to store it and to destroy it securely where required. We don’t collect or retain excessive amounts of personal information; we protect personal information from loss, misuse, unauthorised access and disclosure, whilst ensuring that appropriate technical measures are in place to protect personal information.
4. The purposes for which we use your personal information
- To ensure that you are suitable for the 12 month programme we offer and provide you with an effective service suitable for your needs whilst you remain engaged with TWP
- Provide a personalised service to you when you visit our website(s) – this could include customising the content and/or layout of our pages for individual users, for both visitors and contributors
- To carry out evaluation on the demographics, interests and behaviour of our beneficiaries. This will help us gain a better understanding of different audiences and enable us to improve our service. This analysis may be carried out internally by our employees or we may ask another organisation to do this work for us. Data will be effectively anonymised for this purpose.
- Communicate with you, our employees, our supporters, donors and beneficiaries, including providing you with information that may be of interest to you.
- To involve other relevant health care professionals or social services or where we consider this is strictly necessary to support your wellbeing if you participate in one of our programmes
- To process your donations
- To maintain our own accounts and records
- To inform policy and service improvement through evaluation of anonymised data
- For the prevention of fraud or misuse of services
- For the establishment, defence or enforcement of legal claims
- To protect TWP, our staff or any other person when reasonably required
5. What is the legal basis used by TWP for processing your personal data?
We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:
Where you have provided your consent for our use of your personal information in a certain way, for example, where we ask for your consent to send you a newsletter via email. You always have the right to withdraw your consent.
- Legal obligation
Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject, for example where we have to share your personal information with regulatory bodies which govern our work, or where we claim Gift Aid on donations.
- Contractual relationship
Where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract), for example, we might do this where you volunteer with us.
- Legitimate interests
Where applicable law allows us to collect and use personal information for our legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights.
We may rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent. For instance, we rely on the legitimate interest ground to process your personal information in order to protect the security of our networks e.g. when we receive external emails we will scan such emails for any threats.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
If you become a participant on one of our programmes, we will collect certain sensitive personal information about you. Data protection law recognises certain categories of personal information as sensitive and therefore requiring more protection. These categories of data include information about your health, ethnicity, and political opinions. Additionally, there are rules around the collection of criminal data.
When we collect your health information and criminal data from you, we do so in reliance on the basis that we are a not-for-profit body providing support to individuals with a particular medical condition. In certain circumstances, we may rely on your explicit consent to collect sensitive personal information. You always have the right to withdraw your consent.
A cookie is a small file that is stored on your computer’s hard drive by your web browser. It enables our website to remember you when you return to visit us. Cookies help us to provide you with a better experience by allowing us to understand what areas of the website are of interest to our visitors. These cookies do not track individual information.
7. Sharing your personal information
Your personal information will be treated as strictly confidential within TWP and will only be shared internally with those employed or those volunteering with TWP in order to carry out a service or for purposes connected with the charity.
We do not share your personal information with third parties for marketing purposes. We may share your personal information with third parties outside of the charity when those third parties act as service providers to us. In such circumstances, we put in place appropriate agreements and ensure that those service providers only use your personal information as instructed by us.
We reserve the right to disclose your personal information to third parties:
- where we consider this is strictly necessary to benefit your health and care;
- in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the (prospective) seller or buyer of such business or assets;
- if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
- for auditing purposes e.g. finance audits where we employ chartered accountants;
- if we are under any legal or regulatory obligation to do so e.g. by a law enforcement agency legitimately exercising its powers or if compelled by a court order;
- to obtain professional advice from lawyers, auditors or accountants;
- where we consider this is necessary to protect our rights, property or the personal safety of our staff or any third party; and
- in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.
8. How long do we keep your personal information?
We will keep all your personal information on our secure CRM database for 6 years from the date on which we collected it. If you are a participant on our programme, 12 months after the programme has ended we will restrict access to all your sensitive personal information to the Monitoring Co-ordinator, Lead Co-ordinator and Director Operations. By doing so we can recover your records should you require ongoing support or return for a refresher day at a later date.
If you wish us to destroy or return your personal information at anytime then please contact us: The Office Manager, The Warrior Programme, First Floor, 1 Thorpe Close, London W10 5XL or email@example.com. Please note that we will do what we can to comply with your request but there may be circumstances where we will need to retain your personal information.
9. Your rights to your personal information
Unless subject to an exemption under legislation, you have the following rights with respect to your personal information: –
- The right to request a copy of your personal information which TWP holds about you
- The right to have all your personal information deleted as far as we are legally required to do so
- The right to ask that we correct any personal information that we hold about you which you believe to be inaccurate.
- The right to object to the processing of your personal information where we: (i) process on the basis of the legitimate interests ground; (ii) use the personal information for direct marketing; or (iii) use the personal information for statistical purposes.
- The right to ask for the provision (data portability right) of your personal information in a machine-readable format to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us: (i) in reliance on your consent; or (ii) because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means.
- The right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
If you decide you do not want to receive any further emails from TWP, please tell us and we will remove you from the mailing list. At any point you can request to unsubscribe from our mailing by contacting us using the details listed below.
Please note that where you ask us to delete your personal information for marketing purposes we will maintain a skeleton record comprising your name and contact details to ensure that we do not inadvertently contact you in the future. We may also need to retain some financial records for statutory purposes, for example Gift Aid.
Please note that you also have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns.
Please contact us: The Office Manager, The Warrior Programme, First Floor, 1 Thorpe Close, London W10 5XL or on firstname.lastname@example.org.
10. Transfer of your personal information
We store your personal information on our computers located in the UK. We may also store information in paper files that are held in secured locations.
We may transfer your personal information to our partners as explained above. Where your personal information is transferred outside the UK or the European Economic Area we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information (such as by entering into the standard contractual clauses).
11. Updates to this notice
TWP may update this privacy notice by posting a new version on this website or by providing you with a new version. If we update this privacy notice in a way that significantly changes how we use your personal information, we will bring these changes to your attention where possible. Otherwise, we recommend that you periodically review this privacy notice which is available on our website to be aware of any other revisions.
This notice was last revised on 26 July 2018.
12. Other websites
TWP is not responsible for the privacy practices or the content of linked web sites. Please review the privacy notices of such websites.
13. Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact:
The Office Manager, The Warrior Programme, First Floor, 1 Thorpe Close, London W10 5XL and email@example.com.
If your complaint has not been resolved, you can also contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.