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Seashell Privacy Promise
The privacy and security of your personal information is extremely important to us. This privacy promise explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.
We’ll keep this promise updated to show you all the things we do with your personal data. This promise applies if you’re a supporter of the Trust ; member, donor, volunteer, customer, supporting parent/carer or legal guardian, employee, ex- employee, governor, trustee, supplier, facilities user, health, education or social care partner, placement trainee, student, pupil, child, young person. Additionally when you use any of our services, visit our website, message us on social media, email, call or write to us.
In certain circumstances we may also provide an additional privacy notice, which will always refer to this promise.
We will only provide this privacy promise to you once, generally at the start of our relationship with you. However if this privacy promise is updated substantially, then we may provide you with details of the updated version. You are encouraged to check back regularly for updates.
Last updated: 22 November 2018
Privacy Information
Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us or just managing our relationship with you.
You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten.
We will never sell your personal data that we hold to another party and will only share it with organisations we work with when it’s necessary and the privacy and security of your data is assured.
When we hold or use your personal information we do so as data controller, in the majority of circumstances.
A data controller is a person or organisation which controls how personal information is processed and used. A data processor is a person or organisation which processes and uses personal information in accordance with the instructions of another party, i.e. the data controller.
Who are we?
In this promise, whenever you see the words ‘we’, ‘us’, ‘our’, ‘Seashell Trust’, it refers to the legal entity, Seashell Trust, Company Registration number 042216714
Seashell Trust is an education & care charity founded in 1823 in Manchester; originally for the education of deaf children.
Today, we offer specialist school and college services; Royal School & Royal College, Manchester, providing highly specialist education and care for over 120 severely disabled children and young people, all of whom have consequent complex learning and communication difficulties.
In addition, we provide specialist, registered care homes for children and young adults to ensure that their needs are met when they cannot live with their own family. Children and young people may be resident in our care homes for short periods, including short breaks, or in the longer term, with a view to moving on to adulthood and more independent living. The homes are a place for children and young adults to develop and grow.
Seashell Trust is a registered charity (Reg. Charity number 1092655) and our ICO registration number is Z1633500.
If you have any questions in relation to this privacy promise or how we use your personal data they should be sent to the Data Lead : Seashell Trust, Stanley Road, Cheadle Hulme, Cheshire, SK8 6RQ Tel: 016 610 0100, email: data@seashelltrust.org.uk
What personal data do we collect?
Information which identifies you, or which can be identified as relating to you personally will be collected and used by us. We will only collect the personal data that we need.
The personal data you give us may include the following classifications: personal details, family details, lifestyle and social circumstances, membership details, goods and services details, financial details, education and employment details, including background checks and work place welfare,
Due to the nature of the services that we provide we do collect special categories of personal data in addition to other personal data. These may include: physical or mental health details, racial or ethnic origin, religious or other beliefs of a similar nature, sexual orientation, criminal history, occupational health information, dietary requirements, medical diagnosis/history, family medical details and description, behaviour details, GP details etc We have further safeguards in place for these special categories of data.
We collect personal data in connection with members, staff, volunteers, trustees and governors, complainants, supporters’ enquirers, advisers and representatives of other organisations, event attendees, facilities users, vendors and suppliers, clinical and teaching work placement professionals.
Personal data provided by you
Your personal data can be provided to us in many ways, communicating with us: by phone, email or post, through our website or social media, and meetings. Additionally you may give us your personal data by completing forms, and using forms on our website and other applications when booking for events.
For example:
* Personal details (name, date of birth, email, address, telephone, and so on) when applying for our products and services;
* Financial information (payment information and whether donations are gift-aided);
* Becoming a student or applying to live at Seashell Trust (or being part of a child or young person’s support network) – medical history, medical diagnosis, current prescriptions etc.
If you are the parent/carer/legal guardian of a child or young person who uses our services, or who volunteers for us, your details and your relationship with that child/young person will also be recorded.
Personal data created by your involvement with us
Your activities and involvement with us will result in personal data being created. This could include details of how you’ve helped us by volunteering or being involved with our campaigns and activities or if you have provided further medical information for one of our children and young people etc.
Information we generate
Whilst you maintain a relationship with us we could supplement the data initially collected at the start of our relationship. For example, this may be through completion of forms, collection of additional registration details for additional services you choose to be involved in.
We conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analyzing your interests and involvement with our work we may be able to build a profile which helps us decide which of our communications are likely to be of most interest to you.
Information from third parties
As part of the application process to join our Education,Residential Care and Medical Services we request information via you from any previous Education, Medical, and Residential Care providers and any additional information you feel would contribute to the provision of our services to you. We may seek further clarification with those parties regarding this information.
Sensitive personal data
At times we will collect sensitive personal data to enable us to provide our services to you and to allow us to comply with relevant employment, equal opportunities and similar legislation.
Online Identifiers
We do not currently use cookies on our website. We are not responsible for cookies on any sites that are signposted from our website. For students and residents at Seashell Trust we also record the MAC address and IP address of their own devices when connecting to our services.
Staff, Volunteers, Governors and Trustees, people working with our Children and Young People
We collect extra information about you (e.g. references, criminal records checks, details of emergency contacts, medical conditions etc.). This information will be retained for legal or contractual reasons, to protect us and for safeguarding purposes.
Handling your card information
(Debit/credit cards)
Where we collect this sensitive information over the internet, or when using hand held card processing terminals we us partner services that encrypt the data sent. Seashell Trust uses external Payment Card Industry (PCI) compliant providers to collect this data on our behalf. We do not hold any PCI data on our systems.
How we use your personal data
We’ll only use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation, the UK Data Protection Act (2018) and Privacy of Electronic Communication Regulation 2003.
We will notify you at the time of collection of the personal data of how we intend to use that data and will only use that data in accordance with that notification and any preferences you express.
Marketing and fundraising to young people
Our newsletter may sometimes include competitions or ideas about how to raise money, but they are for individual consideration. Most newsletter content is about our work, events and activities.
Making our communications relevant to you
As our data is collected from various different sources, for data quality purposes we will analyse your data to ensure we do not have multiple versions of information about you in our databases.
Additionally if you are one of our supporters we will decide on the relevant information.
We also hold information about you so that we can respect your preferences for being contacted by us. You can update this at any point, please email data@seashelltrust.org.uk or via post to Data Lead: Seashell Trust, Stanley Road, Cheadle Hulme, SK8 6RQ.
Keeping your information up to date
To make sure that we always have the most up to date information about you, we may from time to time request that you confirm your personal details in the records that we hold.
How long will we keep your personal information?
We will not retain any information for longer than is necessary in relation to the purposes for which it was originally collected, or for which it was further processed, subject to all relevant legal obligations of the Trust for example the collection of Gift Aid or to support certain financial transactions. We retain personal data in accordance with our data retention schedules. Legislation informs the retention periods for our data at the Trust in many areas for example Health and Safety, Human Resources legislation, financial legislation.
Where do we store your information?
We store the majority of your data on our own servers. This is held in line with our Information Security and Data Protection policies.
Where we work with service providers to process and hold your data for us we will ensure this is defined in a contract/sharing agreement and we will take reasonable steps to make sure that your data is treated securely in accordance with this privacy promise. We will endeavor to protect your personal data and ensure that it will be held in compliance with European data protection regulations.
In cases where we use external websites provided by other organisations e.g. Twitter, Facebook, Blue Octopus, Kinetic then we would ask that you consult their privacy policies.
Posting or sending content
We have the right to disclose your identity to any legal authorities claiming to own any content that you post or send.
If we believe that any content sent or posted by you is inappropriate or the content is in breach of any laws, (e.g. potentially defamatory content), we may use your personal information to inform law enforcement agencies.
Sharing your information with third parties – keeping your information safe
When we use an external service provider to process data on our behalf, we disclose only the personal information that is necessary to deliver the service and will have a contract in place that requires the provider to comply with Seashell Trust and GDPR data protection and information security requirements.
We may disclose your personal information to third parties if we are legally obliged to; or other agreements; or to protect the rights, property, or safety of the Seashell Trust and persons associated with the Trust.
Additionally we share details with various other parties:
Whilst you are living at Seashell Trust: Local and Central Government, Ofsted, CQC, TV Licencing Authority, Activity providers, NHS services, and multi teams around a young person, safeguarding boards, Seashell Trust staff and representatives.
Whilst you are learning at Seashell Trust: Department for Education, Ofsted, NHS Services, exam accreditation boards, multi-disciplinary teams around a child or young person, activity providers, our governors, technology learning solution providers, safeguarding boards, Seashell Trust staff and representatives
Whilst you are working at Seashell Trust: HMRC, Department for Work and Pensions, Staff benefit package providers, Learning and development providers, accreditation providers, activity providers, Health and Safety, background check and reference service providers, Safeguarding boards, our Trustees, Seashell Trust staff and representatives, work experience establishments, current, past and prospective employers.
Whilst you are volunteering at Seashell Trust: Volunteer portal provider, background check and reference providers, Seashell Trust staff and representatives
Whilst you are supporting us at Seashell Trust: HMRC – Gift Aid, to our volunteers helping at events where applicable, Trust fund providers where applications are made, offsite location providers for Health and Safety purposes, Seashell Trust staff and representatives
Whilst you are using Seashell Trust sports and community services: Seashell Trust staff and representatives, Health and Safety, NHS Services, activity providers, multi teams around a child or young person
Whilst you are using Seashell Trust Outreach services: Seashell Trust staff and representatives, Health and Safety, NHS Services, activity providers, learning and development providers, accreditation providers, offsite location providers for Health and Safety purposes.
Your Rights
If you wish to exercise any of your rights as listed below please write to us via the data@seashelltrust.org.uk email address, or to the Data Lead at our postal address on the website:
- Access your personal data – ask for a copy of your personal data at any time
- Ask us to correct, delete or update your personal information
- Ask to send your personal information to you or another organisation
- To object to processing, this can include automated decision making
- To restrict processing if this is contested or unlawful
Any request that you make will be considered in accordance with all applicable data protection laws and regulations. No administration charge will be made for considering or complying with a request, unless it is deemed to be excessive in nature.
Once verification of identity and entitlement to obtain or exercise the rights has been completed by us, we will complete the request to timescale.
Find a guide to accessing your information online here or download the PDF below
Updates or changes to our privacy policy
We reserve the right to make changes to the privacy policy. We recommend that each time you access the website you check the policy to review sections that are important to you. Where significant changes are made we will notify you by email.
Complaints
If you have any questions and concerns about this policy and our practices, or if you wish to file a complaint, please contact our Data Lead via data@seashelltrust.org.uk or calling 0161 610 0100. Or in writing to: Data Lead, Seashell Trust, Stanley Road, Cheadle Hulme SK8 6RQ.
You also have the right to lodge a complaint with the Information Commissioners Office (ICO) if you believe your data has been processed in a way that does not comply with existing data protection legislation. You can do so by calling the ICO helpline on 0303 123 1113 or via their website https://ico.org.uk. However we are here to help and would encourage you to contact us to resolve your complaint first.
