Great Yarmouth Community Trust Digital Media Privacy Notice
Effective Date: 25 May 2018
Last Revised: 25 May 2018
This Privacy Notice defines how Great Yarmouth Community Trust (GYCT) uses (collects, stores, uses and discloses and otherwise uses) your Personal Data and other information described in this Privacy Notice.
This Privacy Notice is based on the European Union General Data Protection Regulation (2016/679) or GDPR, introduced on 25th May 2018, to provide a higher standard with respect to the protection of Personal Data.
However, as the GDPR regulation only applies to EU countries, depending on where you live, other privacy laws and regulations may apply as well. This Privacy Notice applies to residents of every country worldwide.
GYCT will, and will cause its partners and any other affiliates to establish and maintain business procedures that are consistent with this Privacy Notice.
WHO IS RESPONSIBLE FOR DATA PROCESSING AT GYCT?
GYCT is technically the Data Controller (via a staff representative), who determines the purpose and means for processing Personal Data.
The Data Controller is supported by a Data Protection Officer and Communications Officer.
GYCT PROTECTS YOUR PRIVACY
GYCT is committed to the protection of the privacy of Personal Data and strives to conform its privacy practices to applicable laws, codes, and regulations.
HOW IS YOUR PERSONAL DATA COLLECTED?
Your Personal Data will always be collected by fair and lawful means, for specific purposes. For example, GYCT may collect your Personal Data when you access our website or social media platform, complete any online surveys or register for or participate in a group or service offered.
WHAT PERSONAL DATA IS COLLECTED AND PROCESSED?
When you voluntarily agree for GYCT to collect your data, the Personal Data that is processed may include your name, address, telephone number, e-mail address, date of birth, and other similar information. We may also occasionally ask your permission to take photographs for marketing purposes if you or your child or dependent are participating in a group or activity delivered by GYCT.
GYCT may also obtain Personal Data from partners or stakeholders, who have assured us that their databases comprise only individuals who have consented to be included and have their Personal Data shared.
From time to time GYCT may collect Sensitive Personal Data which depending on your participation with GYCT and may include, racial or ethnic origin, health and financial information. If GYCT collect your Sensitive Personal Data, GYCT will always obtain your explicit consent.
HOW IS PERSONAL DATA COLLECTED AND PROCESSED?
GYCT may collect and process your Personal Data for a variety of reasons, including:
- profiling information about you so GYCT can better target specific programmes and other services for you;
- updating our records of your Personal Data;
- responding to any messages or requests you may send to us;
- providing consistent service and support to you;
- investigating suspected fraudulent activity or violation of another party’s rights;
- responding to duly authorised information requests of governmental authorities or where required by law;
- in the unlikely event of any sale, assignment, or other transfer of GYCT, we will make all reasonable efforts to ensure that any such buyer agrees to treat Personal Data in accordance with this Privacy Notice; or as otherwise authorised by you.
WHAT INFORMATION IS COLLECTED BY AUTOMATED TECHNOLOGIES?
GYCT may collect certain information automatically. Depending on the country in which you live, such information may be considered Personal Data. Such information includes, but is not limited to information about your device and device capabilities including, but without limitation, the device operating system, the other applications on your device, cookie information, IP address, device network provider, device type, time zone, network status, browser type, browser identifier, unique device identification number (such as Identifiers for analytics or advertising), network provider user ID (a number uniquely allocated to you by your network provider), Media Access Control (MAC) address, location and other information that alone or in combination may be used to uniquely identify your device. Specific technology is specified below:
A cookie is simply a small text file containing information about the user that is placed by a website on a user’s computer or device. GYCT places cookies on your computer or device for program control and fraud prevention purposes.
GYCT may also use tracking cookies, tags, and scripts to track certain information about you based on your activity on our site or third party sites. GYCT may use this information to determine whether you have seen, clicked on, or otherwise interacted with a partner site that GYCT is working on to help improve our services to you.
If you wish, you can choose not to consent to cookies or choose not accept cookies by adjusting your web browser’s privacy settings to delete cookies upon exiting websites or when you close your browser. You may also configure your browser to block cookies.
A web beacon (also known as a tag, clear gif or 1×1 pixel) consists of a small string of code that is embedded within a web page or email. They may or may not be a visible graphic image associated with the web beacon, and often the image is designed to blend into the background of a web page or email.
GYCT may use web beacons in our email messages to help determine whether our messages are opened and to verify any clicks through to links within the email or in website research to determine if a Participant has viewed online content that GYCT is measuring. GYCT may link Personal Data to web beacons for operational and research purposes.
GYCT may collect geo-location information from your computer or device. GYCT may use your geo-location data for research purposes. GYCT will obtain your consent if GYCT collects or uses your geo-location information.
GYCT may use digital fingerprinting technology to gather certain data about you and/or your computer or device. This data may include Personal Data such as an IP address, as well as non-Personal Data such as a computer operating system or browser version number.
Social Media Information
On rare occasions, you may also be offered the opportunity to participate in surveys and other research programs through or with social media platforms. If you choose to participate through or with social media platforms, GYCT may, with your consent, collect certain profile information stored in your social media platform account.
GYCT automatically gathers and stores certain information, as our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. This information is periodically deleted as part of normal maintenance routines.
Information GYCT Collects from Third Parties:
GYCT may obtain Personal Data, behavioural and/or demographic information from third parties, including, without limitation, data management platforms and/or social media platforms. GYCT may use the Personal Data, behavioural and/or demographic data received from these third parties for various purposes, including, but without limitation, data validation, data append, development of research insights, fraud detection purposes.
WHO DOES GYCT SHARE PERSONAL DATA WITH?
GYCT will not make your Personal Data available to any third party without your consent, unless it is required by law, as further specified below. If a survey or other market research program or other activity includes making Personal Data available to a third party, GYCT will only share your Personal Data with your consent. If data collected is used for statistical modelling to better understand trends and preferences amongst specific groups or audiences, only limited Personal Data shared will be used only for research purposes and again only with your consent. GYCT may disclose your Personal Data, profiling data, or other research data to third parties as follows:
- partners that offer and support similar, complimentary services; however, such parties are restricted from using your Personal Data in any way other than to provide services or information to GYCT;
- in connection with the request or requirement of any lawful request by public authorities, to meet national security or law enforcement requirements;
- pursuant to required legal process, to the related compelling party;
- when GYCT believes that disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity;
- as otherwise authorised by you.
GYCT may maintain Personal Data or machine identifiable information in order to satisfy your requests and/or GYCTs’ business requirements. For instance, GYCT may retain the email address of Participants who opted out to ensure GYCT conform to any such wish. Any retention of Personal Data is done in compliance with applicable laws and regulations.
Again, GYCT will only share your personal data with your consent.
DOES GYCT COLLECT INFORMATION FROM CHILDREN?
GYCT does not knowingly collect Personal Data from children below the age where parental consent is required. If GYCT becomes aware that GYCT has inadvertently collected Personal Data from a child below the age where parental consent is required, GYCT will use delete such Personal Data from our database.
WHAT SAFEGUARDS HAS GYCT IMPLEMENTED TO HELP ENSURE THE SECURITY OF YOUR PERSONAL DATA?
The security of your Personal Data is very important to us. Accordingly, GYCT has put in place reasonable technical, physical, and administrative safeguards to protect the information GYCT collects. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Data.
Despite the safeguards GYCT implements, transmissions over the Internet and/or a mobile network are not totally secure and GYCT does not guarantee the security of online transmissions. GYCT is not responsible for any errors by individuals in submitting Personal Data to GYCT.
RETENTION OF PERSONAL DATA
GYCT will store Personal Data no longer than necessary for the purpose of the processing activity or as authorised by you. This period may also be based on GYCTs’ applicable periods of limitation or according to applicable law.
You have the right to review, correct, or delete your Personal Data, subject to applicable laws and regulations. Specifically:
- Right of access — You have the right to obtain confirmation and information about the processing of your Personal Data
- Right to rectification — You have the right to have any inaccuracies about your Personal Data corrected
- Right to erasure — You have the right to have your Personal Data deleted (this right is limited to data which according to law and regulation may only be processed with your consent, if you withdraw your consent for processing)
- Right to restriction of data processing — You have the right to require that the processing of your Personal Data be restricted (during the course of any investigation into honouring your request, GYCTs’ access your Personal Data will be limited)
- Right to data portability — You have the right to have your Personal Data transferred to another party (this right is limited to data provided by you)
If you want to exercise any of your rights, you may contact us with such a request using the contact details provided in the “CONTACT US” section below.
Upon receiving a request from an individual, GYCT will attempt to provide the requested information within 30 days, providing that the request is such that it can be reasonably be responded to in that time frame. If more time is required, GYCT will notify you within thirty days.
In certain situations, however, GYCT may not be able to provide access to some Personal Data. This may occur when:
- providing access to Personal Data would be likely to reveal Personal Data about a third party;
- disclosing the information would reveal confidential information; or
- the information has been collected for the purposes of a legal investigation.
If GYCT denies an individual’s request for access to their Personal Data, GYCT will advise the individual of the reason for the refusal.
HOW DO I OPT-OUT?
If you wish to opt out, please contact us in writing, using the contact details provided in the “CONTACT US” section below.
LINKS TO THIRD PARTY WEBSITES
This Privacy Notice applies solely to our surveys and programme interactions and information, and not to any other product or service. Our website may contain links to a number of third party websites that GYCT believes may offer useful information. The policies and procedures GYCT describes here do not apply to those websites. GYCT recommends that you carefully read the privacy notices or policies of each site that you visit for information on their privacy, security, data collection and distribution policies. By accessing our website and other social media platforms, you freely and specifically give us your consent to collect, use, transfer and disclose your Personal Information in the manner specified in the current Privacy Notice.
GYCT very much values your opinion and feedback. If you want to review, correct, or delete your Personal Data or have questions, comments or suggestions, or have questions about your Personal Data, please contact us:
via email at: firstname.lastname@example.org
or in writing at:
Data Processing Officer
24 Church Plain