Bromley Brighter Beginnings is committed to protecting the data and privacy of the clients, referrers, donors and volunteers with whom we work. We aim to ensure that any information we are given is held securely and appropriately.
Bromley Brighter Beginnings strives to follow sector best practice regarding how we collect, store and use personal data. This policy explains how we do that – if you have any further questions, please contact us:
Chair: Emma Martin
or Referrals Coordinator: Lorelei Freeman
1. Who we are
Bromley Brighter Beginnings (‘BBB’) is a registered charity (number 1162113). You can find out more about our work at www.bromleybrighterbeginnings.org.uk
In this policy, BBB may be referred to as ‘we’ or ‘us’.
2. What information do we collect and why do we collect it?
The only information we collect relates to the referrers, clients, volunteers and supporters with whom we work. We will always try to be clear, honest and open whenever we collect and use personal data. The bullet points below detail the different reasons why we may collect and use personal data.
- details of clients referred to BBB: we record quite detailed personal information about the individuals who are referred to us in order for us to provide them with essential items for their child(ren). This information is collected via a referral form which referrers complete on behalf of their client. A copy of this form can be found at www.babypacks.org.uk/make-a- referral/. The kind of information we require, and record, includes:
o name, address and contact details for the client (so that we can liaise with the client
and deliver the items to them) o children’s names and dates of birth (so we can source age/gender appropriate items
and personalise our donations) o any risk attached to our volunteers delivering items to the client’s home (to protect
our volunteers) o monitoring information such as gender, disability status, age and ethnicity – we use
this to ensure we are reaching a wide section of society, and also to help us produce statistics which we can use in funding applications, to enable us to help more people.
- details of referrers who ask us to help their clients: we hold a database of contact details for referrers who have submitted referrals on behalf of families with whom they are working. We use this to enable our volunteers who are undertaking specific referrals to liaise with referrers and to contact them with any questions, information etc.
- details of volunteers who volunteer for BBB: we hold contact details such as address, phone number, and email for our team of volunteers, as well as emergency contact details for next of kin, for use in an emergency e.g. whilst a volunteer is delivering items to a client. This
enables the team to stay in touch with each other and the volunteer coordinator to manage the volunteers effectively, track their training, etc.
- details of organisations and individuals who have made financial donations to BBB for the purpose of supporting and furthering our work in helping local families in financial need: we log this information for financial control and audit purposes, and to enable us to thank donors appropriately.
3. Lawful processing
Like all organisations in the UK, we need a lawful basis to collect and use personal data. The law allows for six legitimate purposes which organisations can rely on to legally process people’s personal data. Of these, only two are relevant to BBB for the type of activities listed above:
- a) information is processed based on an individual’s consent: where a client give us consent to
process their data (whether that be directly or via the referrer who passes that consent to us), we will always keep a clear record of how and when this consent was obtained. We will always ask the consent of our clients before we share any information about them with any third parties (e.g. other organisations who can provide additional assistance). All requests for items come in to BBB as referrals on behalf of the client – the onus is on the referrer to make the client aware of how their data will be used by us (detailed on the referral form), and to indicate that this consent has been given by ticking the appropriate box.
- b) information is processed on it being a legitimate interest for us to do so: the law allows
personal data to be legally collected and used by an organisation if it is necessary for a legitimate business (or in our case charitable) interest of the organisation – as long as its use is fair and balanced and does not unduly impact the rights of the individual concerned. This basis covers the majority of the personal information we collect.
Our ‘legitimate interests’ means delivery of our charitable aims, which include:
- to provide essential baby, child or household items to local families in financial hardship;
- to signpost or refer families to other local sources of support as necessary;
When we use clients’ personal information, we will always consider if it is fair and balanced to do so and whether it would be within their reasonable expectations that we would use their data in this way. We will balance their rights and our legitimate interests to ensure that the way in which we use their data never goes beyond what they would expect and is not unduly intrusive or unfair.
4. Data retention
We remove personal data from our systems in line with our data retention policy below. The length of time each category of data will be retained will vary on how long we need to process it, the reason it is collected, and in line with any statutory requirements. After this point the data will either be deleted or rendered anonymous.
We store all client records on our secure database which is only accessible by trained BBB volunteers. We will keep client records for a period of 5 years, to ensure we can provide further assistance if a client subsequently needs our help, and for regulatory and audit purposes to ensure we are able to manage any future complaints and enquiries. It is important for our work that we are able to see the history of interactions with a particular client, the items we have provided for them, the volunteers who worked on the referral etc. Referrer records: We will keep these for up to 2 years since the last referral received from a particular referrer, to enable us to access contact details of current and previous referrers, including for addressing enquiries and complaints. Volunteer records: We will only keep volunteer records during the time someone is volunteering with us; if they leave, their details will be deleted from our database immediately. Supporter records: Our treasurer will hold records of donations for seven years to enable BBB to carry out financial reconciliations, and for the purposes of audit. Volunteer expenses: Our treasurer will hold details of volunteers claimed by and reimbursed to volunteers, to enable BBB to carry out financial reconciliations, and for the purposes of audit.
5. Data sharing
We will never share client information with another organisation for marketing purposes, and we will never sell their information for any reason whatsoever. The only instances that we would share a client’s information with another organisation are if we were to make a referral on their behalf to enable them to access services we are not able to provide e.g. to Foodbank. We will always obtain client’s specific and individual consent to such referrals before making them and will document this communication on our secure database for reference. We may be obliged to share personal information when we are compelled to do so by a legal authority acting in compliance with the law.
6. Clients’ data rights
Where we are using clients’ personal information based on their consent, they have the right to withdraw that consent at any time. The law also gives them a number of other rights in relation to their personal data – see below. Please contact us by emailing firstname.lastname@example.org and we will amend the necessary details accordingly.
Right to be informed: clients have the right to be told how their personal information will be used. This policy document, and shorter summary statements used on our referral forms and other communications, are intended to be a clear and transparent description of how their data may be used.
Right of access: clients can write us asking what information we hold on them and to request a copy of that information. We have 30 days to comply once we are satisfied they have rights to see the requested records and we have successfully confirmed their identity.
Right of erasure: in certain circumstances clients have the right to be forgotten (i.e. to have their personally identifiable data deleted). If this applies, we will ensure that client data remains secure and is not used for any purpose other than those allowed. Please contact us with any questions about this.
Right of rectification: if someone believes our records are inaccurate they have the right to ask for those records to be updated.