Data Management and Privacy (GDPR) Policy

Introduction

This policy describes how Cape Farewell gathers and uses certain information about individuals in accordance with General Data Protection Regulation (GDPR) to ensure that it:

• Complies with data protection law and follows good practice;
• Protects the rights of customers/audiences, staff and partners;
• Is transparent about how it stores and processes individuals’ data.

1. Data Protection Law

The General Data Protection Regulation (GDPR) 2018 requires personal data must be:

• Processed lawfully, fairly and in a transparent manner in relation to individuals;
• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes – further processing for archiving purposes in the public interest, scientific or historical research or statistical purposes shall not be considered to be incompatible with the initial purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date, with every reasonable step being be taken to ensure that inaccurate personal data is erased or rectified without delay;
• Kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data is processed – personal data may be stored for longer periods insofar as it will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by GDPR in order to safeguard the rights and freedoms of individuals;
• Processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. The kind of information we hold

A Data Subject is an identifiable individual about whom Cape Farewell holds personal data.

Personal Data means any information by which the Data Subject is identifiable, including, but not limited to:

• Full name (including any preferences about how they like to be called)
• Postal address
• Telephone/mobile number(s)
• E-mail address(es)
• Social media IDs/User Names
• Date of birth
• Gender
• Next of kin and emergency contact information
• National Insurance number
• Bank account details, payroll records and tax status information
• Salary, annual leave, pension and benefits information and other employment records
• Employment or freelance contracts
• Copy of passport and right to work documents and recruitment information
• Information about health, including medical conditions
• Photographs and videos

3. How Data is Collected

By Consent

People who are interested in, and wish to be kept informed of, the activities of Cape Farewell.
Subject to consent, this may include information selected and forwarded on activities relevant to those of Cape Farewell by other organisations. NB. this will not involve providing the person’s personal data to another organisation.

By Contract

People who provide services and/or goods to Cape Farewell, and/or purchase goods and/or services from Cape Farewell.
The information collected will additionally contain details of the services/good being provided or purchased

By Legal Obligation

People where there is a legal obligation on Cape Farewell to collect, process and share information with a third party.
e.g. with HM Revenue & Customs 

By Legitimate Interest (Volunteers, including Trustees)

In order to be able to operate efficiently and effectively, it is in the legitimate interests of Cape Farewell to hold such personal information on its volunteers and trustees as will enable it to communicate on matters relating to the operation of Cape Farewell

4. How Data is Used

Cape Farewell will only use personal information when the law allows, most commonly in the following circumstances:

• To carry out a contract we have entered into
• To comply with a legal obligation
• Where it is necessary for the purposes of the legitimate interests pursued by us or a third party and the Data Subject’s interests and fundamental rights do not override those interests
• Where specific consent to use data has been given

5. Data Retention

Cape Farewell will only retain personal information for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. At the end of the retention period, data will either be deleted completely or anonymised.

6. Rights of access, correction, erasure, and restriction

By law, Data Subjects have the right to:

• Request access to the personal information held about them
• Request correction of their personal information
• Request erasure / Withdraw consent of their personal information
• Request the restriction of processing of their personal information
• Request the transfer of their personal information to another party
• Make a complaint with the Information Commissioner’s Office (ICO) https://ico.org.uk

7. Use of cookies on our website

What is a cookie?

A cookie is a small data file that is downloaded on to ‘terminal equipment’ (like a computer, smartphone or other device) when you access a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions.

There are two main types of cookies, first and third party: First party cookies are those set by the website you are viewing. Third party cookies are set by other sites; for example, if a video has been embedded from YouTube, YouTube may set a cookie of its own.

Cookies can also last for different durations. Session cookies last until you leave the site, others may last for days or months so the site can recognise you and your preferences on subsequent visits.

Cookies set by capefarewell.com

We use a number of different cookies on the Cape Farewell website (www.capefarewell.com), these are:

• Performance cookies – that collect information about how users use the site, such as which pages are the most visited. These cookies collect anonymous information only and we only use any information to improve the site. We use Google Analytics on the site that uses cookies to collect this sort of information. You can read Google’s privacy policy here. And you can opt out of being tracked by Google Analytics on all sites.
• Third party cookies – Our site, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video. Some third party services embedded within this website set their own cookies. These are known as third party cookies because they are not set by our website. We have no control over the cookies that are set by third party services. Disabling these cookies will likely break the functions offered by these third parties.

Name	Purpose	Expires	Company	Type
_ga	Analytics	02 years	Google	Performance
_gid	Analytics	24 hours	Google	Performance
_gat	Analytics	1 minute	Google	Performance

Granting us permission to use cookies

If the settings on your software that you are using to view this website (your browser) are adjusted to accept cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below. You can learn more about all the cookies set by our website above.

Turning cookies off

You can change your browser settings to remove, block or withdraw your consent for cookies at any time. But in some cases, this may impact on your ability to use our website. Browsers recognise different types of cookies and allow you to treat them differentially, as desired.